Bruen and Rahimi Do Not Abrogate Eleventh Circuit Precedent Upholding 18 U.S.C. § 922(g)(1) (Rozier Controls) Introduction In United States v. Brady Castro (11th Cir. Dec. 31, 2025) (unpublished),...
Automobiles as Per Se Instrumentalities of Interstate Commerce for § 1201(a) Kidnapping Jurisdiction (Even When Used Intrastate) I. Introduction In United States v. Derick Irisha Brown (11th Cir....
Constructive Notice Jury Question for Defective Store Fixtures When Evidence Suggests Ongoing Disrepair Case: Helon Dollar v. Walmart Stores East LP (11th Cir. Dec. 30, 2025) (unpublished) Posture:...
EMTALA Pleading Sufficiency: Malnutrition as a Plausible Emergency Medical Condition and Mandatory Leave to Amend When Limitations Make Dismissal Effectively With Prejudice 1. Introduction Case: Lisa...
MDLEA Reaffirmed: EEZ Treated as “High Seas,” Statelessness Defined by Statute, No U.S. Nexus Required, and “Nationality” Equals “Registry” Case: United States v. Jose Marin (consolidated with United...
Unpreserved Sentencing-Explanation Challenges Trigger Plain-Error Review; Minimal Reasons Suffice for Within-Guidelines Illegal-Reentry Sentences in “Conceptually Simple” Cases I. Introduction United...
United States v. Patel: Jointly Proposed Jury Instructions as Invited Error; No Double Counting When §2H1.1(b)(1) Adds Unaccounted “Color of Law” Harm to a §2A3.4-Derived Base Level 1. Introduction...
Uncorroborated Co‑Conspirator Trial Testimony Can Sustain a § 846 Conviction; Suppression Arguments Waived Absent Pretrial Motion Are Reviewed Only for Plain Error Case: United States v. Demarcus...
MDLEA Reach Confirmed: EEZ as “High Seas,” No Nexus Requirement, and Broad Stateless-Vessel Jurisdiction 1. Introduction United States v. Rodolfo Rodriguez Vazquez (consolidated with appeals by Jose...
MDLEA Enforcement in Foreign EEZs and “Stateless Vessel” Determinations; No Minor-Role Reduction for Essential High-Seas Couriers Case: United States v. Stanley Cabrera (consolidated with appeals by...
United States v. Day: Count-Specific Limits on Substantial-Assistance Departures Below Mandatory Minimums I. Introduction In United States v. Erika Kelley Day, No. 24-13312 (11th Cir. Dec. 23, 2025),...
Knowledge, Necessity, and Objective Reasonableness in Fair Housing Act Accommodation and Retaliation Claims: Commentary on Cano v. 245 C&C, LLC (11th Cir.) Disclaimer: This commentary is for...
Strict Preservation and Proof Requirements in Fair Housing Act Litigation: Commentary on Carlos Alonso Cano v. 245 C&C, LLC (11th Cir.) I. Introduction This consolidated Eleventh Circuit decision,...
Clarifying Language-Based Harassment and EEOC Religious Exhaustion: Commentary on Elena Mukhina v. Walmart, Inc. I. Introduction The Eleventh Circuit’s published decision in Elena Mukhina v. Walmart,...
Conditioning FMLA Leave on Medical Disclosure as an ADA “Inquiry”: A Commentary on Aileen Mullin v. Secretary, U.S. Department of Veterans Affairs (11th Cir. Dec. 22, 2025) I. Introduction This...
No Plain Error in Failing to Explain Rejection of Mandatory Minimum Sentence: Commentary on United States v. Gito St. Fort (11th Cir. 2025) I. Introduction This commentary analyzes the Eleventh...
Substance Over Caption: Liberal Construction of Pro Se Filings as Complaints in Malvezzi v. State of Florida I. Introduction This Eleventh Circuit decision, though marked “NOT FOR PUBLICATION” and...
Substance Over Label in Pro Se Civil Rights Filings: Commentary on James Malvezzi v. State of Florida (11th Cir. 2025) I. Introduction The Eleventh Circuit’s unpublished, per curiam decision in James...
Derivative Workers’ Compensation Subrogation and Mootness After Dismissal of the Employee’s Tort Claim: Commentary on Zurich American Insurance Co. v. Walker I. Introduction This commentary examines...
Sua Sponte State Supreme Court Stays and AEDPA Finality: A Commentary on Luis Ralphy Torres v. Secretary, Department of Corrections I. Introduction This commentary examines the Eleventh Circuit’s...