United States v. Albert Pickett

United States v. Albert Pickett, No. 17-13476 (February 20, 2019) The Court remanded the defendant’s second § 2255 motion since the defendant did not have an opportunity to show his conviction was based solely on the ACCA’s residual clause prior to the Eleventh Circuit announcing the heightened standard in Beeman. 28 USC 2255/ACCA – Defendant’s…

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United States v. Stephanie Anor

United States v. Stephanie Anor, No. 17-15608 (February 20, 2019), UNPUBLISHED The Court vacated the defendant’s sentence after the sentencing court erred in attributing the conspiracy’s entire intended loss amount to the defendant. While the defendant was part of a broader fraudulent tax-return scheme, there was insufficient evidence that that she knew the extent of…

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United States v. Paul Harris

United States v. Paul Harris, No. 18-12418 (February 19, 2019) The Eleventh Circuit affirmed a prison guard defendant’s conviction for Hobbs Act extortion based on evidence that he confiscated contraband from inmates for his personal use and that the inmates “consented” by not reporting the defendant out of fear that they would be punished for…

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United States v. Matthew Caniff

United States v. Matthew Caniff, No. 17-12410 (February 15, 2019) The Court affirmed the defendant’s conviction under 18 U.S.C. § 2251(d), holding that the defendant “made a notice” requesting child pornography when he sent a text message soliciting naked pictures from an undercover agent posing as a minor. The Court also found sufficient evidence that…

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United States v. Valois

United States v. Valois, et al., No. 17-13535 (February 12, 2019) Two groups of individuals were intercepted by the Coast Guard and prosecuted separately for drug trafficking on the high seas. The Court affirmed the second group’s convictions, holding that a mistrial was not warranted based on the prosecutor’s references to a conspiracy between the…

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