United States v. Lagary Williams: Eleventh Circuit Reaffirms No-Notice Rule for Upward Variances and Permits Use of Uncharged Overdose Death Under § 3553(a) Court: U.S. Court of Appeals for the...
No Bona Fide Doubt, No Hearing: Eleventh Circuit Reaffirms Trial-Court Discretion to Decline Mid‑Trial Competency Re‑Evaluation and to Impose an Upward § 3553(a) Variance Case: United States v....
Attaching QWRs Saves a RESPA Claim from Summary Judgment; Borrower Default Bars Contract Claims and Supports Foreclosure — Eleventh Circuit’s Partial Remand in Embry v. Carrington Note: This is an...
Residence Alone Is Not Enough: Eleventh Circuit Reaffirms Plaintiff’s Burden to Allege and Prove Florida Contacts for Personal Jurisdiction Over Nonresident Defendants Court: U.S. Court of Appeals...
Ordinary Criminality Is Not Nexus: Eleventh Circuit Reaffirms Pecuniary-Motive Rule and Rejects Imputed Anti‑Gang Political Opinion in Osorio‑Villalobos Introduction In this unpublished, per curiam...
Reaffirming Deference to Adverse Credibility Findings and the Chenery/Bagamasbad Limits on Appellate Review When the BIA Denies on Credibility Alone Introduction In Sakib Ahmod v. U.S. Attorney...
Eleventh Circuit: Receiving a Non‑EEOC Subpoena Is Not Protected “Participation” Under Title VII; Two Isolated Advances Insufficiently Severe or Pervasive; Stray Age Remarks Don’t Prove Pretext Case:...
Deterrence Without Empirical Proof: Eleventh Circuit Reaffirms District Courts’ Discretion to Rely on Experience When Weighing § 3553(a) Factors Case: United States v. Frank D. Cavanaugh, No....
Good Cause to Defer 404(b) Rulings: Eleventh Circuit Affirms Post‑Opening Admission of Prior Fraud Conviction to Prove Intent Introduction In United States v. Jarnel Sael (11th Cir. No. 25‑10750,...
United States v. Diggs: Distinct Overbreadth Theories Must Be Specifically Preserved; No Plain Error in Treating Florida “Stereoisomer” Cocaine Convictions as ACCA Predicates Introduction In this...
Preservation Matters in ACCA: ioflupane overbreadth does not preserve isomer arguments; no plain error in treating Florida “stereoisomer” cocaine convictions as ACCA predicates Commentary on United...
Major Upward Variances at De Novo Resentencing Post‑Taylor: Eleventh Circuit Upholds 240-Month Term Based on Aged-Out Criminal History and Public Protection Introduction In United States v. John...
When State Drug Law Changes Mid-Prosecution, ACCA Looks to the Offense-Date Law Preserved by State Saving Provisions: Eleventh Circuit Vacates Enhancement in United States v. Miller Introduction This...
Eleventh Circuit reaffirms Florida third-party bad-faith duties: valuation disputes are no shield where the insurer ignores medical risk and fails to communicate settlement opportunities Introduction...
Alternative Sentence + Substantive Reasonableness = Harmless Guideline Error: Eleventh Circuit affirms despite career-offender dispute and recognizes Conage/Rowe superseding Shannon Introduction In...
Inferring Federal “Intended Use” from Historical Plans: Eleventh Circuit Affirms U.S. Title to Wisteria Island under the Submerged Lands Act Introduction In United States v. F.E.B. Corp. (No....
Credible Testimony of Dismissed “Hands‑On” Abuse May Justify Upward Variance in Child‑Pornography Sentencing under § 3553(a): United States v. Robledo (11th Cir. 2025) Introduction This commentary...
Eleventh Circuit Reaffirms Strict “Sound Reasons” Requirement for Coram Nobis and Confirms Rule 11 Errors Are Non‑Jurisdictional Introduction In W. Lawrence LeNeve v. United States, No. 25-11992...
Hall v. Masters: Dual-Standard Failure of Proof in Civil Detainee Water-Safety Claims and Discretion to Deny Court-Appointed Experts and Deposition Assistance Introduction In Wendall Jermaine Hall v....
Extending the Ongoing‑Emergency Doctrine to Sex‑Trafficking Stings: United States v. Carter (11th Cir. 2025) Introduction In United States v. Carter, the Eleventh Circuit upheld four sex‑trafficking...