In United States v. Brice, No. 22-14126 (11th Cir. Feb. 27, 2026) (Newsome, Brasher, Tjoflat), the Court affirmed the defendants’ Hobbs Act robbery convictions. Addressing an issue of first impression in this circuit, the Court rejected one defendant’s contention that the Indian County Crimes Act and the Major Crimes Act preclude federal prosecution of any crimes not listed in the Major Crimes Act, where such crimes are committed “by an Indian, against an Indian, and in Indian Country.” The Court instead determined that, as an “enclave law” (meaning “the situs of the offense” is “an element of the crime”), “nothing in the Major Crimes Act limits federal jurisdiction to only the crimes it enumerates.” Instead,  the Court held that “generally applicable federal laws”—statutes that do not include the “situs of the offense” as an “element”— “apply by their own terms to everyone, everywhere,” and thus “extend to the acts of Indians committed in Indian country, even if the victim is also an Indian.” And, because the Court concluded that the Hobbs Act is a “generally applicable federal law,” it lawfully applied to the Indian defendants, who committed the instant offense “against an Indian,” “in Indian Country.” The Court also found [...]

United States v. Charlie Holley, No. 24-11843 (11th Cir. Feb 3, 2026) On the morning of June 21, 2021, Charlie Holley barricaded himself inside his Florida City townhouse in the grip of what would later be documented as a severe psychotic episode. Four days earlier, he had begun experiencing what he believed were electrical currents and microwave signals being directed at him by law enforcement. He unplugged his appliances, built interior barricades, and came to believe that his mail had been tampered with to sabotage him. By the time events came to a head, Holley was armed with a loaded, scoped Hi-Point assault rifle. Charlotte Wicker — a USPS mail carrier who had delivered on Holley's route for a decade — arrived to drop off a package addressed to "Whitey White," Holley's nickname. When she refused his demand to open it, he trained the rifle on her and ordered her to move around her postal vehicle. She complied until she could reach the driver's door, then drove away. Approximately forty feet down the street, she stopped and called 911. While she was on the line, she reported hearing something strike the truck. A later examination confirmed a single bullet hole [...]

In United States v. Malachi Mullings, No. 24-11822 (11th Cir. Feb. 10, 2026) (Branch, Luck, Schlesinger (MDFL)), the Court affirmed Mullings’s money laundering conspiracy convictions, following his guilty plea to an 8-count indictment, and his 120-month sentence of imprisonment. In affirming Mullings’s conviction, the Court, applying the factors in United States v. Buckles, 843 F.2d 469 (11th Cir. 1988), found no abuse of discretion by the district court in denying Mullings’s motion to withdraw his guilty plea. Based in part on the district court’s findings after an evidentiary hearing on Mullings’s motion, the Court found that “Mullings had the close assistance of counsel”; “the district court afforded Mullings substantial time to consider whether to plead guilty,” and conducted a thorough colloquy prior to accepting his plea; over a month passed between Mullings’s guilty plea and his motion to withdraw it—and his bond revocation likely influenced his decision to seek withdrawal; and the Court credited the district court’s credibility conclusion that “there was zero evidence of coercion other than Defendant’s uncredible testimony.” The Court gave no weight to the government’s nondisclosure of the fact that a conspirator was cooperating at the time of Mullings’s guilty plea, because, “the government had no [...]

In United States v. Rufino Robelo-Galo  (11th Cir. Feb. 17, 2026) (Brasher, Newson, Tjoflat), the Court held, on an issue of first impression, that a defendant seeking a reduction in sentence pursuant to 18 U.S.C. s. 3582(c)(1)(A)(i) & U.S.S.G. 1B1.13(b)(3)(C), as the “only available caregiver,” the defendant “must demonstrate that no other person is qualified and free to provide the needed care.” The Court also identified several factors for district courts to consider when making this “fact-intensive inquiry,” including: “whether legal barriers prevent the potential caregiver from providing care”; “physical or logistical barriers to caregiving”; “knowledge or capability-based barriers affect the caregiver’s qualifications”; “familial dynamics or relationship history that may bear on an alternative caregiver’s availability”; and “any economic, financial, or employment-related barriers that would impact a caregiver’s availability.” The Court also affirmed the district court’s denial of Robelo-Galo’s motion, finding no “clear error” in the district court’s conclusion that Robelo-Galo was not “the only available caregiver” for his incapacitated grandfather, in Honduras, because another “close family member” was “also available”—even though that family member worked and lived 4 hours away, did not have a car, could not relocate to the grandfather because of his duties to his own children, [...]

In United States v. Myelicia T. Rodgers, No. 24-10638 (11th Cir. Jan. 30, 2026) (CJ Pryor, Abudu, Conway (MDFL)), affirmed Rodgers’s conviction, after a bench trial, for tampering with, and stealing, mail. After the government’s presentation of evidence, the district court denied Rodgers’s Rule 29 motion, and—upon defense counsel’s request—the district court conducted a colloquy about Rodgers’s decision of whether to testify, in which the court told Rodgers that her decision not to testify was “not something I’m going to consider in any way in deciding the ultimate issue in this case.” Rodgers did not testify or present any witness, but she submitted her partially signed Miranda waiver form. At closing, Rodgers (through counsel) argued that her inculpatory statement (introduced during the government’s case-in-chief) was coerced, and pointed to the absence of a recording of the statement in support. The district court responded that there were no facts in the record to support the argument that the interview was coercive, noting specifically that, “your client did not testify as a witness, and so the only evidence that I have as to . . . that interview comes from” the interviewing agent’s testimony.  When Rodgers counsel asked the district court not [...]

In United States v. Stefan Eberhard Zappey, 164 F.4th 1348 (11th Cir. 2026) (Abudu, Rosenbaum, Wilson), the Court affirmed Zappey’s convictions for multiple counts of aggravated sexual abuse, and abusive sexual contact with children under 12. For 20 years, Zappey taught German language classes to children at an American school on a military base in Germany. In 2019 and 2020, four women alleged that Zappey had sexually assaulted them when they were students in his class. A subsequent military investigation concluded that Zappey had abused four students, under the age of 12, from 2006 to 2010. He was indicted accordingly, and exercised his right to a jury trial. Zappey's defense theory was that the women's memories of being abuse by Zappey as children were unreliable. After a 5-day trial, Zappey was convicted of all 8 counts, and he was later sentence to life imprisonment. Zappey claimed on appeal that the district court abused its discretion by limiting one of Zappey’s two childhood memory experts to trial testimony relating only to topics already covered by the government’s memory expert, and by entirely excluding Zappey’s second expert. The Court found no abuse of discretion as to the limitations on Zappey’s first expert [...]