'I Regret My Error:' 11th Circuit Judge Issues Apology in Ruling
Judge Robin Rosenbaum apologized for a 2015 opinion that a colleague had called "wrong-headed."
June 25, 2020 at 04:16 PM
4 minute read
The original version of this story was published on Daily Report
It's not something one usually sees in a federal appellate ruling—an apology.
But Judge Robin Rosenbaum did just that Wednesday in a separate concurrence with an en banc ruling from the U.S. Court of Appeals for the Eleventh Circuit that revoked an opinion she penned in 2015 in a Florida criminal case, United States v. Sparks.
"As the writer of the Sparks opinion, I regret my error and appreciate the court's correction of our circuit's jurisprudence," Rosenbaum wrote.
The Sparks opinion stemmed from an appeal of a Florida trial judge's refusal to suppress evidence of child pornography seized without a warrant from a lost cellphone that was turned over to law enforcement. Rosenbaum's majority opinion in Sparks held that, where a defendant has abandoned a premises, or a cellphone, from which evidence is subsequently seized, that defendant suffers no legal injury and has no standing to appeal, either on its merits on Fourth Amendment grounds or, more broadly, in federal court at all.
Rosenbaum was not the only one to issue a mea culpa of sorts in the en banc opinion handed down Wednesday in a separate Florida criminal case, U.S. v. Wali Ebbin Rashee Ross.
In remanding Ross' appeal, Judge Kevin Newsom, writing for the Eleventh Circuit, vacated his own 2019 panel opinion in Ross' case. That panel also included Judges Charles Wilson and David Proctor of the Northern District of Alabama, sitting by designation.
"Sometimes courts make simple mistakes," Newsom wrote in Wednesday's opinion. "And simple mistakes call for simple fixes."
Newsom's opinion cited his own misgivings about the 2015 Sparks decision that he spelled out in a separate concurrence with himself in the now-vacated 2019 ruling for Ross.
At the time, Newsom urged the en banc court to revisit the issue, writing that the 2015 Sparks opinion "seems not just wrong to me, but also wrongheaded."
"The rule that we adopted in Sparks threatened unintended consequences," Newsom explained in Wednesday's opinion. "Namely, (1) producing incongruous results among Fourth Amendment cases, (2) jeopardizing the fairness of judicial proceedings, and (3) impeding sound judicial administration. Scrapping it will minimize those threats."
Ross' appeal arose out of the denial of a motion to suppress evidence seized in two separate warrantless searches of a motel room where he was staying but wasn't registered. A trial court denied Ross' suppression motion, and he subsequently pleaded guilty to possession of a firearm and ammunition by a convicted felon and possession with intent to distribute heroin. But he maintained, and later exercised, his right to appeal.
In defending Ross' conviction, prosecutors raised a new issue at the Eleventh Circuit, claiming Ross abandoned the motel room, which law enforcement officers were then free to search.
The appeals court's 2019 opinion, relying on Sparks, addressed questions over whether Ross even had standing to challenge the search and whether prosecutors had standing to introduce a new issue on appeal.
Last year, Newsom made clear his concerns with the Sparks opinion. "By permitting the government to raise abandonment for the first time on appeal as a 'jurisdictional' issue, Sparks thrusts this court into the uncomfortable position of making a de novo determination of a purely factual issue, with respect to which there has been no fact-finding and no lower-court analysis," he said. "That strikes me as more than a little a little topsy-turvy—and unnecessarily so."
In Wednesday's en banc opinion, Newsom said the legal tenets embraced in Sparks contravene U.S. Supreme Court precedent and violates the justice's directive that courts should avoid "jurisdictionalizing" issues that are more properly characterized as "claim-processing" rules or aspects of a litigant's merits case.
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