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  • Commentaries
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11th Circuit Case Commentaries

Reaffirming Broad Discretion to Weigh Prior Sentences in Upward Variances: United States v. Carmel Linot (11th Cir. 2025)

Reaffirming Broad Discretion to Weigh Prior Sentences in Upward Variances: United States v. Carmel Linot (11th Cir. 2025)

Date: Oct 28, 2025
Reaffirming Broad Discretion to Weigh Prior Sentences in Upward Variances Under § 3553(a): United States v. Carmel Linot Court: U.S. Court of Appeals for the Eleventh Circuit Date: October 24, 2025...
Guidelines as Starting Point; Public Protection as Dominant Factor: Eleventh Circuit Affirms Substantial Upward Variance for §1470 Despite Mandatory §2260A Term

Guidelines as Starting Point; Public Protection as Dominant Factor: Eleventh Circuit Affirms Substantial Upward Variance for §1470 Despite Mandatory §2260A Term

Date: Oct 28, 2025
Guidelines as Starting Point; Public Protection as Dominant Factor: Eleventh Circuit Affirms Substantial Upward Variance for §1470 Despite Mandatory §2260A Term Introduction In United States v. Imran...
Concurrent Sentence Doctrine Extends to Sentences Consecutive to Life; MVRA Permits Lost-Income Restitution to Deceased Victims’ Family Members (Clarified): Commentary on United States v. Lesley Green (and Philmon Chambers)

Concurrent Sentence Doctrine Extends to Sentences Consecutive to Life; MVRA Permits Lost-Income Restitution to Deceased Victims’ Family Members (Clarified): Commentary on United States v. Lesley Green (and Philmon Chambers)

Date: Oct 27, 2025
Concurrent Sentence Doctrine Extends to Sentences Consecutive to Life; MVRA Permits Lost-Income Restitution to Deceased Victims’ Family Members (Clarified) Commentary on United States v. Lesley Green...
United States v. Philmon Chambers (11th Cir. 2025): Eleventh Circuit Extends the Concurrent-Sentence Doctrine to Life-Plus Sentences and Affirms MVRA Restitution for Deceased Victims’ Family Members

United States v. Philmon Chambers (11th Cir. 2025): Eleventh Circuit Extends the Concurrent-Sentence Doctrine to Life-Plus Sentences and Affirms MVRA Restitution for Deceased Victims’ Family Members

Date: Oct 27, 2025
United States v. Philmon Chambers (11th Cir. 2025): Eleventh Circuit Extends the Concurrent-Sentence Doctrine to Life-Plus Sentences and Affirms MVRA Restitution for Deceased Victims’ Family Members...
Refusal of Reassignment Defeats ADA Claim: Eleventh Circuit holds offering a vacant alternative position is a reasonable accommodation even when the employee requests short-term leave

Refusal of Reassignment Defeats ADA Claim: Eleventh Circuit holds offering a vacant alternative position is a reasonable accommodation even when the employee requests short-term leave

Date: Oct 25, 2025
Refusal of Reassignment Defeats ADA Claim: Eleventh Circuit holds offering a vacant alternative position is a reasonable accommodation even when the employee requests short-term leave Case: Brandon...
Unwillingness, Not Inability: Eleventh Circuit Affirms Upward Variance Based on Willful Nonpayment and Disregard for the Law

Unwillingness, Not Inability: Eleventh Circuit Affirms Upward Variance Based on Willful Nonpayment and Disregard for the Law

Date: Oct 25, 2025
Unwillingness, Not Inability: Eleventh Circuit Affirms Upward Variance Based on Willful Nonpayment and Disregard for the Law Case: United States v. Linda Davis, No. 24-13399 (11th Cir. Oct. 23, 2025)...
Reasonableness of a Single Takedown Kick During a Rapid Arrest; District Courts’ Discretion to Decline Florida Battery Claims After Federal Dismissal

Reasonableness of a Single Takedown Kick During a Rapid Arrest; District Courts’ Discretion to Decline Florida Battery Claims After Federal Dismissal

Date: Oct 25, 2025
Reasonableness of a Single Takedown Kick During a Rapid Arrest; District Courts’ Discretion to Decline Florida Battery Claims After Federal Dismissal Introduction This unpublished, per curiam...
Headlong Flight at a Closed Business Converts Reasonable Suspicion into Probable Cause for Alabama Third-Degree Trespass; Eleventh Circuit Reaffirms § 922(g)(1) Post-Bruen/Rahimi

Headlong Flight at a Closed Business Converts Reasonable Suspicion into Probable Cause for Alabama Third-Degree Trespass; Eleventh Circuit Reaffirms § 922(g)(1) Post-Bruen/Rahimi

Date: Oct 25, 2025
Headlong Flight at a Closed Business Converts Reasonable Suspicion into Probable Cause for Alabama Third-Degree Trespass; Eleventh Circuit Reaffirms § 922(g)(1) Post-Bruen/Rahimi Case: United States...
Actual Notice as a Prerequisite to Civil Contempt for Discharge-Injunction Violations; Broad Discretion over Discovery Sanctions Reaffirmed

Actual Notice as a Prerequisite to Civil Contempt for Discharge-Injunction Violations; Broad Discretion over Discovery Sanctions Reaffirmed

Date: Oct 24, 2025
Actual Notice as a Prerequisite to Civil Contempt for Discharge-Injunction Violations; Broad Discretion over Discovery Sanctions Reaffirmed Introduction In Shirley White‑Lett v. Shellpoint Mortgage...
Inferring the MDLEA’s “On Request” Statelessness Requirement from Standard Boarding Procedures

Inferring the MDLEA’s “On Request” Statelessness Requirement from Standard Boarding Procedures

Date: Oct 24, 2025
Inferring the MDLEA’s “On Request” Statelessness Requirement from Standard Boarding Procedures Introduction In United States v. Santo Rosario‑Rivera (consolidated with United States v. Francisco...
No Records, No Lien: Eleventh Circuit affirms extinguishment of a Georgia attorney’s lien absent credible proof of value

No Records, No Lien: Eleventh Circuit affirms extinguishment of a Georgia attorney’s lien absent credible proof of value

Date: Oct 24, 2025
No Records, No Lien: Eleventh Circuit affirms extinguishment of a Georgia attorney’s lien absent credible proof of value Court: U.S. Court of Appeals for the Eleventh Circuit (Non-Argument Calendar;...
No Gross Disproportionality Under Plain-Error Review: Eleventh Circuit Affirms 600-Month Sentence for Child Pornography Production and Possession

No Gross Disproportionality Under Plain-Error Review: Eleventh Circuit Affirms 600-Month Sentence for Child Pornography Production and Possession

Date: Oct 24, 2025
No Gross Disproportionality Under Plain-Error Review: Eleventh Circuit Affirms 600-Month Sentence for Child Pornography Production and Possession United States v. Angel Antonio Cannella, No. 22-13924...
Implicit Proof of the MDLEA “Request” Requirement for Stateless-Vessel Jurisdiction in the EEZ

Implicit Proof of the MDLEA “Request” Requirement for Stateless-Vessel Jurisdiction in the EEZ

Date: Oct 24, 2025
Implicit Proof of the MDLEA “Request” Requirement for Stateless-Vessel Jurisdiction in the EEZ Commentary on United States v. Francisco Rijo-Rijo, et al. (consolidated), Nos. 23-12779, 23-12828,...
Post-Offense Mail-Inspection Videos Are Admissible Under Rule 404(b); Broad Relevant-Conduct Loss Attribution (Including Acquitted Conduct under pre-2024 Guidelines) Upheld — United States v. Glover (11th Cir. 2025)

Post-Offense Mail-Inspection Videos Are Admissible Under Rule 404(b); Broad Relevant-Conduct Loss Attribution (Including Acquitted Conduct under pre-2024 Guidelines) Upheld — United States v. Glover (11th Cir. 2025)

Date: Oct 24, 2025
Post-Offense Mail-Inspection Videos Are Admissible Under Rule 404(b); Broad Relevant-Conduct Loss Attribution (Including Acquitted Conduct under pre-2024 Guidelines) Upheld — United States v. Glover...
Implied “Request” Satisfies MDLEA Statelessness and EEZ-as-High-Seas Reaffirmed: United States v. Placido Rivera‑Rodriguez (11th Cir. 2025)

Implied “Request” Satisfies MDLEA Statelessness and EEZ-as-High-Seas Reaffirmed: United States v. Placido Rivera‑Rodriguez (11th Cir. 2025)

Date: Oct 24, 2025
Implied “Request” Satisfies MDLEA Statelessness and EEZ-as-High-Seas Reaffirmed: United States v. Placido Rivera‑Rodriguez (11th Cir. 2025) Court: U.S. Court of Appeals for the Eleventh Circuit (per...
Ambiguous Surveillance Video and Storewide Spill Evidence at Summary Judgment: Eleventh Circuit Reverses in Van Dorsten v. Wal‑Mart and Clarifies Florida’s § 768.0755 Constructive-Knowledge Pathways

Ambiguous Surveillance Video and Storewide Spill Evidence at Summary Judgment: Eleventh Circuit Reverses in Van Dorsten v. Wal‑Mart and Clarifies Florida’s § 768.0755 Constructive-Knowledge Pathways

Date: Oct 22, 2025
Ambiguous Surveillance Video and Storewide Spill Evidence at Summary Judgment: Eleventh Circuit Reverses in Van Dorsten v. Wal‑Mart and Clarifies Florida’s § 768.0755 Constructive-Knowledge Pathways...
Generic Objections Don’t Preserve §3553(c)(2) Challenges; Omission of a Written Statement of Reasons Is Plain but Harmless When Oral Reasons Are Clear — United States v. Alexander (11th Cir. 2025)

Generic Objections Don’t Preserve §3553(c)(2) Challenges; Omission of a Written Statement of Reasons Is Plain but Harmless When Oral Reasons Are Clear — United States v. Alexander (11th Cir. 2025)

Date: Oct 22, 2025
Generic Objections Don’t Preserve §3553(c)(2) Challenges; Omission of a Written Statement of Reasons Is Plain but Harmless When Oral Reasons Are Clear — United States v. Alexander (11th Cir. 2025)...
Attempted Solicitation Suffices and NPS Jurisdiction Reaches Private Parcels Within Park Boundaries

Attempted Solicitation Suffices and NPS Jurisdiction Reaches Private Parcels Within Park Boundaries

Date: Oct 22, 2025
Attempted Solicitation Suffices and NPS Jurisdiction Reaches Private Parcels Within Park Boundaries Case: United States v. Rady Williams, Nos. 24-14167 & 24-14168 (11th Cir. Oct. 21, 2025) (per...
No Sale Required, No Private Enclave: Eleventh Circuit Clarifies NPS Solicitation and Interference Rules within Park Boundaries

No Sale Required, No Private Enclave: Eleventh Circuit Clarifies NPS Solicitation and Interference Rules within Park Boundaries

Date: Oct 22, 2025
No Sale Required, No Private Enclave: Eleventh Circuit Clarifies NPS Solicitation and Interference Rules within Park Boundaries Case: United States v. Rady Williams, Nos. 24-14167 & 24-14168 (11th...
Eleventh Circuit Endorses Corps’ Use of Letters of Permission as NEPA Categorical Exclusions—even in a National Seashore—and Declines Size-Based Limits via Ejusdem Generis

Eleventh Circuit Endorses Corps’ Use of Letters of Permission as NEPA Categorical Exclusions—even in a National Seashore—and Declines Size-Based Limits via Ejusdem Generis

Date: Oct 22, 2025
Eleventh Circuit Endorses Corps’ Use of Letters of Permission as NEPA Categorical Exclusions—even in a National Seashore—and Declines Size-Based Limits via Ejusdem Generis Introduction In Center for...
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