Latest Opinions

Judges: MATHESON, PHILLIPS, McHUGH

Issues Presented: Denial of compassionate release under 18 U.S.C. § 3582(c)(1)(A); Extraordinary and compelling reasons for sentence reduction; Impact of COVID-19 on prison conditions; Youthful offender guidelines and sentence enhancements; Family circumstances as a basis for compassionate release

Summary:
Mark R. Davis, a federal prisoner, appealed the district court's denial of his request for compassionate release due to alleged extraordinary and compelling reasons, including medical conditions, harsh prison conditions, and family circumstances. The Tenth Circuit affirmed the district court's decision, finding that Davis did not meet the criteria for compassionate release.

Detailed Analysis:
The Tenth Circuit reviewed the district court's denial for abuse of discretion, concluding that Davis's medical conditions did not qualify as extraordinary and compelling reasons, as he failed to demonstrate an ongoing outbreak of COVID-19 in his facility. Additionally, the court found that harsh prison conditions and family circumstances did not meet the necessary criteria for compassionate release. The court also noted that recent amendments to sentencing guidelines did not apply to Davis's case.

Second Screen Analysis: [+]

Judges: B. RASHER, ED CARNES, WILSON

Issues Presented: Appealability of an interlocutory order denying absolute and qualified litigation privileges in a defamation action; Vicarious liability of the defendant for his attorney's actions

Summary:
Ronald Rubin appealed the district court's denial of his motion for summary judgment, which claimed that letters sent by his attorney were protected by Florida's absolute and qualified litigation privileges. The court affirmed the denial of the absolute privilege, stating the letters were sent outside the litigation process, but dismissed the appeal regarding the qualified privilege and vicarious liability.

Detailed Analysis:
The court held that the denial of Florida's absolute litigation privilege is immediately appealable under the collateral order doctrine, as it conclusively determines an important issue separate from the merits of the case. However, the qualified litigation privilege involves factual determinations that are intertwined with the merits of the case, making it non-appealable at this stage. The court also found that the vicarious liability issue was not appealable as it pertains to the merits of the case.

Second Screen Analysis: [+]

Judges: B RANCH, LAGOA, W ILSON

Issues Presented: Improper rejection of subjective testimony regarding pain; Improper discounting of medical opinions; Residual functional capacity not supported by substantial evidence

Summary:
Michael Hayes appealed the decision of the Social Security Administration denying his application for disability insurance benefits. The court found that the administrative law judge's (ALJ) residual functional capacity determination was not supported by substantial evidence, leading to a reversal and remand for further proceedings.

Detailed Analysis:
The court concluded that the ALJ's reliance on post-date-last-insured improvements and lack of medical opinions supporting the RFC determination were insufficient. The ALJ failed to conduct a proper function-by-function assessment of Hayes's physical abilities and did not adequately explain how the evidence supported the RFC finding.

Second Screen Analysis: [+]

Judges: BRASHER, ABUDU, MARCUS

Issues Presented: Whether the district court erred in dismissing T & B Holding Group's complaint for lack of subject matter jurisdiction.; Whether T & B's claims of procedural error are reviewable.

Summary:
T & B Holding Group, LLC appeals the dismissal of its complaint challenging the USCIS's revocation of Vito Tuozzolo's I-140 petition and denial of his I-129 petition. The district court dismissed the complaint for lack of subject matter jurisdiction under the INA. The Eleventh Circuit affirmed the dismissal of substantive claims but vacated and remanded for consideration of T & B's procedural error claim regarding a mismatch in the NOIR.

Detailed Analysis:
The court analyzed the jurisdictional bar under 8 U.S.C. § 1252(a)(2)(B) and determined that while substantive challenges to USCIS's decisions are unreviewable, claims of procedural error may be reviewable. The court found that T & B's mismatch claim was a valid procedural error claim that warranted further consideration.

Second Screen Analysis: [+]

Judges: NEWSOM, LAGOA, BRASHER

Issues Presented: Timeliness of notice of appeal; Revocation of supervised release

Summary:
The court granted the government's motion to dismiss the appeal as untimely, ruling that Christopher Summers's notice of appeal was filed after the deadline to challenge the district court's judgment revoking his supervised release.

Detailed Analysis:
The court applied the prison mailbox rule to determine the filing date of the notice of appeal. It concluded that the appeal was untimely as it was filed more than 14 days after the district court's judgment, which is a requirement under Federal Rules of Appellate Procedure.

Second Screen Analysis: [+]