11th Circuit Case Commentaries

“All Means All” Under Rule 41(a)(1)(A)(ii): The Eleventh Circuit’s Strict Finality Doctrine in Curlee v. AT&T Mobility Services

Date: Nov 23, 2025

“All Means All” Under Rule 41(a)(1)(A)(ii): The Eleventh Circuit’s Strict Finality Doctrine in Curlee v. AT&T Mobility Services I. Introduction In Amanda Curlee v. AT&T Mobility Services, LLC, an...

Verbal Provocation Alone Cannot Render Otherwise Reasonable Force Excessive: Commentary on Medina v. City of Daytona Beach

Date: Nov 23, 2025

Verbal Provocation Alone Cannot Render Otherwise Reasonable Force Excessive: Commentary on Medina v. City of Daytona Beach I. Introduction Anthony Medina v. City of Daytona Beach, No. 25-10552 (11th...

Anti‑Evasion of FLSA Overtime and Prevailing‑Party Status After Rule 68: Commentary on David Thompson v. Regions Security Services, Inc.

Date: Nov 23, 2025

Anti‑Evasion of FLSA Overtime and Prevailing‑Party Status After Rule 68: Comprehensive Commentary on David Thompson v. Regions Security Services, Inc. I. Introduction This consolidated Eleventh...

Clarifying FLSA Anti‑Evasion and Prevailing‑Party Fees After Rule 68 Judgments: Commentary on Thompson v. Regions Security Services, Inc.

Date: Nov 23, 2025

Clarifying FLSA Anti‑Evasion and Prevailing‑Party Fees After Rule 68 Judgments: Commentary on Thompson v. Regions Security Services, Inc. I. Introduction This consolidated Eleventh Circuit decision...

Bodycam Footage, Hidden Hands, and Qualified Immunity at the Pleading Stage: Commentary on Johnson v. Williams

Date: Nov 23, 2025

Bodycam Footage, Hidden Hands, and Qualified Immunity at the Pleading Stage: Commentary on Johnson v. Williams I. Introduction This commentary examines the Eleventh Circuit’s unpublished decision in...

United States v. Plaza Estacio: Accuracy and Policy-Statement Fidelity in Amendment 821 Sentence-Reduction Proceedings

Date: Nov 23, 2025

United States v. Plaza Estacio: Accuracy and Policy-Statement Fidelity in Amendment 821 Sentence-Reduction Proceedings I. Introduction The Eleventh Circuit’s unpublished decision in United States v....

No Dismissal With Prejudice Without Service: Personal Jurisdiction Limits on Inherent Dismissal Power in Bilal v. Benoit

Date: Nov 22, 2025

No Dismissal With Prejudice Without Service: Personal Jurisdiction Limits on Inherent Dismissal Power in Bilal v. Benoit I. Introduction This Eleventh Circuit decision, Jamaal Ali Bilal v. Jeffrey...

Symptoms Are Not Enough: Functional Impairment and the ERISA Claimant’s Burden in Mental‑Health Disability Claims — Commentary on Stacy Hovan v. Metropolitan Life Insurance Co.

Date: Nov 22, 2025

Symptoms Are Not Enough: Functional Impairment and the ERISA Claimant’s Burden in Mental‑Health Disability Claims Commentary on Stacy Hovan v. Metropolitan Life Insurance Company (11th Cir. Nov. 20,...

United States v. McCray: Explicit Factual Findings and Nexus Requirements for Attempted First-Degree Murder Cross-References under U.S.S.G. § 2K2.1(c)(1)

Date: Nov 22, 2025

United States v. McCray: Explicit Factual Findings and Nexus Requirements for Attempted First-Degree Murder Cross-References under U.S.S.G. § 2K2.1(c)(1) I. Introduction In United States v. Antonio...

"You Break It, You Own It": Eleventh Circuit Clarifies County Monell Liability for Privatized Jail Healthcare in Smothers v. Childers

Date: Nov 22, 2025

"You Break It, You Own It": Eleventh Circuit Clarifies County Monell Liability for Privatized Jail Healthcare in Smothers v. Childers I. Introduction In Pamela Smothers v. Roger Childers, et al. (No....

United States v. Oropesa: Section 241 Applies to Conspiracies to Violate Rights Created by the FACE Act

Date: Nov 22, 2025

United States v. Oropesa: Section 241 Applies to Conspiracies to Violate Rights Created by the FACE Act I. Introduction In United States v. Gabriella Victoria Oropesa, No. 25‑10928 (11th Cir. Nov....

Title VI Discrimination, Retaliation, and “Cat’s Paw” Liability in the School–Contractor Context: Commentary on Quinn v. Columbia County School District

Date: Nov 21, 2025

Title VI Discrimination, Retaliation, and “Cat’s Paw” Liability in the School–Contractor Context: Commentary on Quinn v. Columbia County School District I. Introduction The Eleventh Circuit’s...

EEZ as “High Seas” and Limits on Minor-Role Reductions under the MDLEA: Commentary on United States v. Vasquez (11th Cir. 2025)

Date: Nov 21, 2025

EEZ as “High Seas” and Limits on Minor-Role Reductions under the MDLEA: Commentary on United States v. Vasquez (11th Cir. 2025) I. Introduction This consolidated, unpublished per curiam decision of...

Reaffirming Firearm Foreseeability in Maritime Drug Conspiracies: Commentary on United States v. Garcia‑Castillo (11th Cir. 2025)

Date: Nov 21, 2025

Reaffirming Firearm Foreseeability in Maritime Drug Conspiracies: Commentary on United States v. Garcia‑Castillo (11th Cir. 2025) I. Introduction This commentary analyzes the Eleventh Circuit’s...

MDLEA Jurisdiction in Exclusive Economic Zones and Limits on Minor-Role Reductions: Commentary on United States v. Robles, Vasquez & Pushiana

Date: Nov 21, 2025

MDLEA Jurisdiction in Exclusive Economic Zones and Limits on Minor-Role Reductions for Maritime Couriers: Commentary on United States v. Robles, Vasquez & Pushiana (11th Cir. 2025) I. Introduction...

MDLEA Enforcement in Exclusive Economic Zones and Limits on Minor-Role Reductions: Commentary on United States v. Robles (11th Cir. 2025)

Date: Nov 21, 2025

MDLEA Enforcement in Exclusive Economic Zones and Limits on Minor-Role Reductions: Commentary on United States v. Robles (11th Cir. 2025) I. Introduction This commentary analyzes the Eleventh...

United States v. Starr: Limiting Third‑Party Perpetrator Evidence and Clarifying “Effect-on-Listener” Testimony in Murder‑for‑Hire Cases

Date: Nov 21, 2025

United States v. Starr: Limiting Third‑Party Perpetrator Evidence and Clarifying “Effect-on-Listener” Testimony in Murder‑for‑Hire Prosecutions I. Introduction United States v. Jason Starr & Darin...

Nexus, Not Speculation: Third‑Party Perpetrator Evidence, Hearsay, and Circumstantial Proof in United States v. Starr

Date: Nov 21, 2025

Nexus, Not Speculation: Third‑Party Perpetrator Evidence, Hearsay, and Circumstantial Proof in United States v. Starr I. Introduction In United States v. Jason Starr & Darin Starr, Nos. 24‑10131 &...

Alternative Factual Theories as Waiver Triggers in Proffer Agreements: Commentary on United States v. Steve Bonner

Date: Nov 20, 2025

Alternative Factual Theories as Waiver Triggers in Proffer Agreements: Commentary on United States v. Steve Bonner I. Introduction The Eleventh Circuit’s unpublished decision in United States v....

REACH Air Medical v. Kaiser: FAA-Style Deference and Narrow Judicial Review of No Surprises Act IDR Awards

Date: Nov 20, 2025

REACH Air Medical v. Kaiser: FAA-Style Deference and Narrow Judicial Review of No Surprises Act IDR Awards I. Introduction The Eleventh Circuit’s published decision in REACH Air Medical Services LLC...