11th Circuit Case Commentaries

Eleventh Circuit Holds Court‑Ordered Batterers’ Intervention Programs Are Government Speech, Foreclosing Free Speech and Free Exercise Challenges to State‑Mandated Curricula

Date: Sep 8, 2025

Eleventh Circuit Holds Court‑Ordered Batterers’ Intervention Programs Are Government Speech, Foreclosing Free Speech and Free Exercise Challenges to State‑Mandated Curricula Introduction In Joseph...

Part‑Specific Proof or No Price Increase: Eleventh Circuit Clarifies Supplier Obligations, Upholds Severe Rule 37 Sanctions, and Elevates Settlement Memoranda in Defining Contract Scope

Date: Sep 8, 2025

Part‑Specific Proof or No Price Increase: Eleventh Circuit Clarifies Supplier Obligations, Upholds Severe Rule 37 Sanctions, and Elevates Settlement Memoranda in Defining Contract Scope Introduction...

Eleventh Circuit Clarifies ALJ Articulation Duties and Appeals Council’s Materiality Review of New Evidence under the 2017 Regulations

Date: Sep 8, 2025

Eleventh Circuit Clarifies ALJ Articulation Duties and Appeals Council’s Materiality Review of New Evidence under the 2017 Regulations Introduction In Bryan Dubose v. Commissioner of Social Security,...

Surplus-or-Standing: Eleventh Circuit Clarifies that a Chapter 7 Debtor’s “Party in Interest” Status Under § 502 Does Not Bypass Article III Redressability

Date: Sep 8, 2025

Surplus-or-Standing: Eleventh Circuit Clarifies that a Chapter 7 Debtor’s “Party in Interest” Status Under § 502 Does Not Bypass Article III Redressability Introduction This commentary analyzes the...

Eleventh Circuit Reaffirms MDLEA Reach into Foreign EEZs, No Nexus Requirement, and Denial of Minor‑Role Reductions for Go‑Fast Crews

Date: Sep 8, 2025

Eleventh Circuit Reaffirms MDLEA Reach into Foreign EEZs, No Nexus Requirement, and Denial of Minor‑Role Reductions for Go‑Fast Crews Introduction This commentary analyzes the Eleventh Circuit’s...

Jones-Stage Objections Preserve Challenges to Supervised-Release Conditions; Minor-Contact Restrictions Upheld in SORNA Failure-to-Register Sentences (United States v. Louis‑Jean, 11th Cir. 2025)

Date: Sep 8, 2025

Jones-Stage Objections Preserve Challenges to Supervised-Release Conditions; Minor-Contact Restrictions Upheld in SORNA Failure-to-Register Sentences Introduction This commentary analyzes the...

EEZ as “High Seas,” No U.S. Nexus Required, and Narrow Minor‑Role Relief for Go‑Fast Crews: Eleventh Circuit’s Consolidated MDLEA Ruling in United States v. Jhon Henry Alvarado‑Valencia (and Codefendants)

Date: Sep 8, 2025

EEZ as “High Seas,” No U.S. Nexus Required, and Narrow Minor‑Role Relief for Go‑Fast Crews: Eleventh Circuit’s Consolidated MDLEA Ruling in United States v. Jhon Henry Alvarado‑Valencia (and...

EEZ-as-High-Seas, No-Nexus Requirement, and a Narrow Minor-Role Inquiry Under the MDLEA: Commentary on United States v. Quijije‑Mero (11th Cir. 2025)

Date: Sep 8, 2025

EEZ-as-High-Seas, No-Nexus Requirement, and a Narrow Minor-Role Inquiry Under the MDLEA: Commentary on United States v. Quijije‑Mero (11th Cir. 2025) Introduction In United States v. Jhon Yandry...

EEZ Equals “High Seas” for Felonies Clause: Eleventh Circuit Reaffirms MDLEA’s Extraterritorial Reach and No‑Nexus Rule; Minor‑Role Reductions Narrow for Go‑Fast Couriers

Date: Sep 8, 2025

EEZ Equals “High Seas” for Felonies Clause: Eleventh Circuit Reaffirms MDLEA’s Extraterritorial Reach and No‑Nexus Rule; Minor‑Role Reductions Narrow for Go‑Fast Couriers Introduction In a...

Eleventh Circuit Reaffirms MDLEA’s Reach Into Foreign EEZs and Rejects Nexus Requirement; Affirms Denial of Minor‑Role Adjustments for Go‑Fast Crew

Date: Sep 8, 2025

Eleventh Circuit Reaffirms MDLEA’s Reach Into Foreign EEZs and Rejects Nexus Requirement; Affirms Denial of Minor‑Role Adjustments for Go‑Fast Crew Introduction In United States v. Juan Manuel...

EEZ Is “High Seas” for Felonies Clause; No Nexus Requirement Under the MDLEA; and Role Reductions Must Be Gauged Against Relevant Conduct: Commentary on United States v. Lauro Aguilar-Gomez (11th Cir. Sept. 3, 2025)

Date: Sep 8, 2025

EEZ Is “High Seas” for Felonies Clause; No Nexus Requirement Under the MDLEA; and Role Reductions Must Be Gauged Against Relevant Conduct Case: United States v. Lauro Aguilar-Gomez (consolidated with...

Uncharged Conduct, Officer Video Identification, and the Departure/Variance Label: Eleventh Circuit Affirms a Major Upward Sentence in United States v. White

Date: Sep 8, 2025

Uncharged Conduct, Officer Video Identification, and the Departure/Variance Label: Eleventh Circuit Affirms a Major Upward Sentence in United States v. White Introduction In United States v. Narada...

EFIN Responsibility, Circumstantial Mens Rea, and the Zero‑Point Offender Carve‑Out: The Eleventh Circuit Affirms Managerial Role Enhancement and Loss Extrapolation in Tax‑Preparer Fraud

Date: Sep 8, 2025

EFIN Responsibility, Circumstantial Mens Rea, and the Zero‑Point Offender Carve‑Out: The Eleventh Circuit Affirms Managerial Role Enhancement and Loss Extrapolation in Tax‑Preparer Fraud Case: United...

No Mens Rea Required for DEA Registration Revocations Under 21 U.S.C. § 824; Due Process Satisfied by Opportunity for Hearing

Date: Sep 8, 2025

No Mens Rea Required for DEA Registration Revocations Under 21 U.S.C. § 824; Due Process Satisfied by Opportunity for Hearing Introduction In Sualeh Kamal Ashraf v. United States Drug Enforcement...

Comparable-Sales Over Speculation: Eleventh Circuit Affirms 40% Penalty Where Tax Court’s Independent Valuation Makes Zoning and §6103 Disputes Irrelevant

Date: Sep 4, 2025

Comparable-Sales Over Speculation: Eleventh Circuit Affirms 40% Penalty Where Tax Court’s Independent Valuation Makes Zoning and §6103 Disputes Irrelevant Introduction In Buckelew Farm, LLC (f.k.a....

Eleventh Circuit Reaffirms: Post-Handcuff Strikes Constitute Gratuitous Force; Qualified Immunity Denied

Date: Sep 4, 2025

Reaffirming the Limits of Force: No Qualified Immunity for Post-Handcuff Strikes on a Non-Resisting Suspect Case: Albert Lee St. Clair, Jr. v. DeAngelo M. Anthony, et al. (No. 24-11302) Court: U.S....

Reasoned Consideration and Evidentiary Sufficiency at the Reconsideration Stage: Preliminary Diagnoses and Generalized Violence Do Not Establish Prima Facie Relief

Date: Sep 4, 2025

Reasoned Consideration and Evidentiary Sufficiency at the Reconsideration Stage: Preliminary Diagnoses and Generalized Violence Do Not Establish Prima Facie Relief Introduction In Armando...

No Waiver Without Knowledge: Georgia’s Clear-and-Unmistakable Standard Governs Ownership Conditions in Temporary-Substitute Auto Coverage

Date: Sep 4, 2025

No Waiver Without Knowledge: Georgia’s Clear-and-Unmistakable Standard Governs Ownership Conditions in Temporary-Substitute Auto Coverage Introduction The Eleventh Circuit’s unpublished decision in...

No Prejudice, No Penalty; Months-Long Gaps Break Causation: Eleventh Circuit Clarifies COBRA Penalty Discretion and Title VII Retaliation in Thibodeaux v. City of Atlanta

Date: Sep 4, 2025

No Prejudice, No Penalty; Months-Long Gaps Break Causation: Eleventh Circuit Clarifies COBRA Penalty Discretion and Title VII Retaliation in Thibodeaux v. City of Atlanta Introduction This commentary...

Independent Investigation Breaks the Cat’s Paw: Eleventh Circuit Reaffirms Limits on Mixed‑Motive Title VII Claims in Police Use‑of‑Force Terminations

Date: Sep 4, 2025

Independent Investigation Breaks the Cat’s Paw: Eleventh Circuit Reaffirms Limits on Mixed‑Motive Title VII Claims in Police Use‑of‑Force Terminations Case: Roger Williams v. Unified Government of...

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