The Eleventh Circuit is 0-3 in the October 2025 Supreme Court term. According to SCOTUS blog’s Circuit Scorecard, the Eleventh Circuit joins the Seventh and Eighth Circuit with a 100% reversal rate. Only the First and Tenth Circuits had a greater than 50% affirm rate.
In Havana Docks Corp. v. Royal Caribbean Cruises, Ltd., the Supreme Court decided whether the Cuban Liberty and Democratic Solidarity Act’s use of the phrase “property which was confiscated by the Cuban Government” was limited to the original owner’s property interest or meant the physical piece of property confiscated regardless of whether the original owner still would have held a property interest absent confiscation. The Eleventh Circuit held that the phrase referred only to present property interests, but the Supreme Court disagreed. It held that “property which was confiscated” meant any physical piece of property that was confiscated by the Cuban Government without regard to whether the owner still would have a present property interest today absent confiscation. The Supreme Court therefore vacated the Eleventh Circuit’s opinion.
In Bowe v. United States, the Supreme Court resolved a circuit split related to when a federal prisoner may file for post-conviction habeas relief. The Supreme Court ultimately vacated the Eleventh Circuit’s ruling and remanded the case to the Eleventh Circuit for further analysis consistent with the Court’s opinion.
In Whitton v. Dixon, the Supreme Court vacated the Eleventh Circuit’s denial of habeas relief to a prisoner because the Court held that the Eleventh Circuit should not have considered post-trial DNA evidence in assessing whether the Florida Supreme Court reasonably determined that certain testimony was immaterial to the jury’s verdict. The Supreme Court remanded the case to the Eleventh Circuit for further analysis consistent with the Court’s opinion.