Plaintiffs Joshua Harris and Donita Olds appealed a district court decision regarding arbitration and delegation provisions in loan agreements. The district court had based its decision solely on the prospective waiver doctrine, and the parties initially framed their appeal arguments around that singular issue.

The court determined that contract formation is a clear prerequisite for delegation and arbitration, providing a narrower path to resolving the case. The court noted that even the most sweeping delegation cannot send the contract-formation issue to the arbitrator. The court affirmed the district court’s judgment on any ground supported by the record, having requested and received supplemental briefing on the formation issue from both parties.

Even the most sweeping delegation cannot send the contract-formation issue to the arbitrator

K.F.C., 29 F.4th at 837

The ruling clarifies that courts must independently assess contract formation before enforcing arbitration clauses, even when the parties have not initially raised the issue on appeal.

Michael Townes filed a complaint seeking declaratory and injunctive relief against the United States and various federal agencies, alleging unconstitutional targeting based on race and poverty. He claimed his conviction for communicating an interstate threat was obtained without proof of the required mens rea and that the resulting threat classification caused ongoing collateral consequences. Townes explicitly stated he did not challenge his conviction, plea, or sentence, but sought a declaration that his criminal record was illegally obtained.

The Eleventh Circuit reviewed the dismissal for abuse of discretion, finding the complaint frivolous under 28 U.S.C. Section nineteen hundred fifteen, subsection (e)(two)(B). The court determined Townes failed to establish Article III standing because he did not allege a real and immediate threat of future harm traceable to the defendants. Additionally, the court applied the Heck bar, ruling that a judgment in Townes’s favor would necessarily imply the invalidity of his conviction. Since the conviction had not been invalidated through habeas corpus or other means, the claims were not ripe for review. The court also affirmed the denial of leave to amend, noting that amendment would be futile because the Heck bar would still apply.

The decision reinforces that individuals cannot use civil lawsuits to challenge the validity of a criminal conviction while the conviction remains intact, even if they seek only declaratory relief regarding their criminal record. It also clarifies that plaintiffs must allege specific, imminent future injuries to maintain standing for prospective injunctive relief.

Dennis Jordan was convicted in Massachusetts state court for offenses including armed assault with intent to murder following a 2002 shooting at an after-hours club. After the Massachusetts Appeals Court affirmed his conviction and the Massachusetts Supreme Judicial Court declined review, Jordan sought a writ of habeas corpus in federal district court, which was denied. Jordan appealed, arguing ineffective assistance of counsel regarding eyewitness identification instructions, improper limitation of cross-examination, and prosecutorial misconduct.

The court reviewed the case under the Antiterrorism and Effective Death Penalty Act, which presumes state court factual findings are correct unless rebutted by clear and convincing evidence. The court found that the Massachusetts Appeals Court reasonably determined that the jury instructions given were sufficient to alert the jury to the possibility of mistaken eyewitness identification. The court noted that additional instructions might have harmed the defense by highlighting the reliability of identification arrays. Furthermore, ample evidence, including the petitioner’s own incriminating statements, supported the conviction. The petitioner failed to show that no fairminded jurist could disagree with the state court’s conclusion.

The decision reinforces the high bar for federal habeas relief under the Antiterrorism and Effective Death Penalty Act, particularly regarding claims of ineffective assistance of counsel and jury instruction errors in state criminal proceedings.

Amazon and iRobot announced a merger in August 2022 that was terminated in January 2024 after failing to secure antitrust approval from US and European regulators. iRobot shareholders filed a securities fraud class action alleging misrepresentations about the likelihood of regulatory clearance. The district court dismissed the complaint, but the appeal was stayed when iRobot filed for Chapter 11 bankruptcy. The parties agreed to dismiss iRobot from the appeal, leaving only the individual defendants, Colin Angle and Julie Zeiler.

The court applied Federal Rule of Civil Procedure twelve point six to evaluate the motion to dismiss. It concluded that the amended complaint failed to plausibly allege material misrepresentations or omissions for most statements made by the defendants. However, the court determined that the August twenty-four, two thousand and twenty-three modified proxy statement contained an actionable opinion regarding expected regulatory approval. This opinion was actionable because it omitted important contrary information regarding European approval and was made under circumstances suggesting scienter.

The ruling limits liability for corporate statements regarding merger approvals unless specific omissions of contrary regulatory information are alleged with particularity.

The U.S. Department of State, under an executive order issued by President Donald J. Trump, promulgated a Passport Policy requiring passports to state the biological sex of the bearer at birth. This policy replaced a prior rule allowing applicants to select a sex marker of male, female, or X without it corresponding to biological sex. Plaintiffs, representing transgender and non-binary Americans, challenged the policy in district court, arguing it was arbitrary and capricious under the Administrative Procedure Act and violated the Equal Protection Clause due to unconstitutional animus. The district court preliminarily enjoined the policy, and the government moved for a stay pending its appeal.

The court applied the four-factor test for a stay pending appeal, focusing on whether the government made a strong showing that it is likely to succeed on the merits. Regarding the Administrative Procedure Act claim, the court rejected the government’s argument that the policy was unreviewable because it implemented a presidential directive. The court noted that agency action carrying out a presidential directive is ordinarily subject to review and that the Executive Order did not leave the agency with no discretion. The government also failed to provide sufficient legal authority to support its claim that the policy was committed to the President’s sole discretion. Regarding the Equal Protection Clause claim, the court observed that the government failed to meaningfully engage with the district court’s analysis of unconstitutional animus, offering only two sentences to challenge the lower court’s findings. The court also found that the government failed to demonstrate that the balance of harms favored a stay, noting the district court’s findings of immediate and irreparable harm to the plaintiffs, including increased risk of harassment and violence while traveling.

The preliminary injunction blocking the Department of State from enforcing the new passport policy remains in effect while the government’s appeal proceeds. Transgender and non-binary Americans may continue to use passports with sex markers that do not correspond to their biological sex.

Shelitha Robertson and her attorney, Chandra Norton, submitted fraudulent applications for Paycheck Protection Program loans during the COVID-19 pandemic. They claimed their businesses employed hundreds of people when, in reality, most had no employees. They secured nearly fifteen million dollars in funding before banks detected the scheme and froze their accounts. Robertson was convicted of wire fraud, conspiracy to commit wire fraud, and money laundering, and sentenced to eighty-seven months in prison. She appealed, challenging the sufficiency of the evidence, evidentiary rulings, and the sentencing and restitution orders.

The Eleventh Circuit reviewed the record in the light most favorable to the government and found the evidence sufficient to support the jury’s verdict. The court noted that Robertson admitted her companies had no employees and that she signed fraudulent applications. The court also found that the district court properly instructed the jury on deliberate ignorance and did not abuse its discretion in admitting lay testimony from an SBA employee or allowing a co-conspirator to explain recorded conversations. Regarding sentencing, the court held that Robertson was not entitled to credit for repaying funds after the banks detected the fraud. The court affirmed that Robertson was jointly liable for the full loss amount and restitution because the conspiracy was a joint undertaking.

The decision reinforces that defendants in PPP fraud cases may be held jointly liable for the total losses caused by their co-conspirators, even if they personally repaid some funds after detection. It also clarifies that lay witnesses with institutional knowledge may testify about program procedures without expert designation.

Defendant Carlos Rafael Tello Cedeno was arrested in 2016 while serving as the master of a go-fast boat involved in a large-scale cocaine smuggling operation. Coast Guard personnel intercepted the vessel in international waters, disabled it with gunfire, and recovered nearly seven hundred eighty-eight kilograms of cocaine that the crew had jettisoned. Cedeno pleaded guilty to conspiracy to distribute cocaine and was sentenced to one hundred sixty-eight months of imprisonment. In 2025, Cedeno filed a motion to reduce his sentence under Section thirty-five eighty-two subsection C two, arguing that Amendment Eight hundred twenty-one to the sentencing guidelines made him eligible for a lower advisory range. The district court denied the motion, citing the seriousness of the offense, the dangerous obstruction of the investigation, and Cedeno’s continued involvement in the drug trade.

The Eleventh Circuit reviewed the district court’s denial for an abuse of discretion. The court explained that Section thirty-five eighty-two subsection C two requires a two-step inquiry: first, calculating the amended guideline range, and second, considering the Section thirty-five fifty-three A factors to determine if a reduction is warranted. The court noted that the district court correctly calculated the new advisory range but found that the second step allowed the court to consider the defendant’s obstructive conduct. The opinion states that conduct related to a possible guidelines enhancement may be considered when balancing the Section thirty-five fifty-three A factors. The court concluded that the district court did not make a clearly erroneous factual finding regarding the dangerous obstruction and did not abuse its discretion in weighing the factors against the reduction.

The decision reinforces that district courts retain broad discretion to deny sentence reductions under Section thirty-five eighty-two subsection C two when the nature of the offense and obstructive conduct weigh heavily against a lower term, even if the defendant is technically eligible for a reduced guideline range.

Jean Henry, proceeding pro se, appealed the denial of his motion for compassionate release under Section eighteen U.S.C. thirty-five eighty-two subsection c one A. The government moved for summary affirmance, arguing the district court did not abuse its discretion.

The court reviewed the district court’s decision for abuse of discretion. It found that the district court expressly considered the applicable factors under Section thirty-five fifty-three A and the mitigating evidence. The court emphasized that a district court need not address each factor or weigh them equally, but may decide what weight to give to any given factor. The district court stressed respect for the law and deterrence based on Henry’s extensive criminal history and the violent nature of his offense. Because the statutory factors did not favor relief, the court did not need to reach the issues of danger to the community or extraordinary and compelling reasons.

This decision reinforces that district courts have broad discretion in compassionate release cases and are not required to provide exhaustive analysis of every sentencing factor to avoid reversal.