Judicial data via CourtListener (Free Law Project). Social links via Wikidata.
Affiliations
District Court, S.D. Florida — appointed by William Jefferson Clinton
Party: Democratic →J.D., George Washington UniversityBA, Saint Anselm CollegeJD, George Washington University
Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
In the Meridian Ventures case the court stressed that the Interstate Land Sales Full Disclosure Act is a consumer-protection statute that should be construed flexibly to effectuate its remedial purposes rather than technically and restrictively. Meridian Ventures, LLC v. One No… ↗
Deference to government powerSkepticism of government power
In Harris the court vacated an ACCA enhancement after finding procedural default overcome by actual innocence, and in Sherrod it protected a teacher’s speech against a school board, reflecting measured skepticism toward government positions. Harris v. United States ↗ Sherrod v. SCHOOL BD. OF PALM BE… ↗
The case involves a federal prisoner's motion under 28 U.S.C. § 2255 to vacate his 15-year mandatory minimum sentence under the Armed Career Criminal Act (ACCA) for being a felon in possession of a firearm. The petitioner argued that one of his prior Florida convictions for resisting arrest with violence no longer qualified as a predicate "violent felony" after the Supreme Court's decision in Begay v. United States, which narrowed the ACCA's residual clause to require purposeful, violent, and aggressive conduct similar to enumerated examples like burglary or arson. The court held that the petitioner could raise this claim on collateral review despite not challenging the predicate convictions at sentencing or on direct appeal, because a showing of actual innocence of the sentencing enhancement overcomes procedural default. It further ruled that the government could not now rely on an additional prior conviction to support the enhancement, as it had waived any objections to the original presentence report. The court therefore granted the motion and vacated the sentence.
This case involved attorney Henry Kaye, who filed suit seeking a declaratory judgment that he was not bound by an arbitration provision arising from a personal injury settlement and related insurance dispute, along with a stay of arbitration proceedings under New York law. After the suit was filed, the arbitrator ruled that Kaye was not subject to the arbitration and denied any claims against him. The court granted the defendant's motion to dismiss, holding that the arbitrator's favorable ruling rendered the case moot because no live controversy remained and the court could no longer provide meaningful relief. Dismissal was also required for lack of subject matter jurisdiction, as the complaint alleged neither diversity (no amount in controversy stated) nor a federal question, and the underlying claims appeared to be state-law breach of contract matters. The court further noted that without federal jurisdiction over the declaratory judgment claim, it lacked jurisdiction over the related state-law stay request.
This case was a patent infringement action brought by Michael Powell against Home Depot concerning a safety guard device for radial arm saws. A jury found that Home Depot willfully infringed claims of Powell's U.S. Patent No. 7,044,039 and awarded $15 million in reasonable royalty damages. After a subsequent bench trial, the court concluded that Home Depot had not proven inequitable conduct by clear and convincing evidence, so the patent remained enforceable. On post-trial motions, the court awarded enhanced damages of $3 million, attorneys' fees of $2.8 million, and prejudgment interest of $3,150,889.13, applying standards under 35 U.S.C. §§ 284 and 285 for willfulness-based enhancements and full compensation.
This case arose after Tiara Condominium Association sued its insurance broker, Marsh, for breach of contract and negligence following disputes over wind-damage policy limits after two 2004 hurricanes; Tiara had settled a related suit against the insurer for less than it sought. Marsh made a $70,000 offer of judgment under Florida Statute § 768.79, which Tiara rejected, and the district court later entered summary judgment of no liability for Marsh. The court adopted the magistrate judge's report recommending partial grant of Marsh's motion for attorneys' fees and costs, overruling objections that the offer was invalid for lacking a certificate of service (as Rule 1.442 is procedural and inapplicable in federal court under Erie), that it was not made in good faith, and concerning the fee amount, while reducing the award after reviewing billing records for reasonableness under the statute's factors. The court awarded $1,775,602.50 in fees and $26,196.08 in costs.
The case involves Curtis Sherrod, a high school history teacher, who alleged that the Palm Beach County School Board and officials retaliated against him for criticizing the district's implementation of a state law requiring infusion of African and African-American history into the curriculum, including by terminating his employment. The court addressed cross-motions for summary judgment on claims including First Amendment retaliation, procedural due process, and equal protection. It determined that Sherrod's speech at school board meetings constituted protected speech made as a citizen on a matter of public concern under the First Amendment, leading to denial of summary judgment on the retaliation claim except in one instance, while granting it on the other claims.
The case involved a condominium association seeking coverage under a directors and officers liability insurance policy issued by Travelers for a lawsuit brought by a unit owner alleging negligence, breach of contract, and breach of fiduciary duty related to the association's failure to maintain the building's roof and air conditioning system, which led to water damage and mold after hurricanes. The court granted summary judgment in favor of Travelers, holding that it had no duty to defend because the claims fell under the policy's exclusion for losses arising out of damage to tangible property, including construction defects and mold. The reasoning was that the unit owner's claims directly arose from property damage and loss of use caused by the association's alleged failures, meeting the but-for causation test for the exclusion, and the amended complaint's additional economic loss allegations did not alter this outcome.