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 that, while the district court abused its discretion by admitting evidence of one of the defendant’s prior crimes without first making “an on-the-record finding that the probative value of [admission] outweighs its prejudicial effect,” this error was harmless because otherwise admissible evidence established his guilt.
Opinion here: https://media.ca11.uscourts.gov/opinions/pub/files/202214126.pdf