State of Georgia v. Eric A. Heinze

CourtCourt of Appeals for the Eleventh Circuit
DecidedApril 7, 2026
Docket23-12050
StatusPublished

This text of State of Georgia v. Eric A. Heinze (State of Georgia v. Eric A. Heinze) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Georgia v. Eric A. Heinze, (11th Cir. 2026).

Opinion

USCA11 Case: 23-12050 Document: 61-1 Date Filed: 04/07/2026 Page: 1 of 17

FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 23-12050 ____________________

STATE OF GEORGIA, Plaintiff-Appellant, versus ERIC HEINZE, et al.,

Defendants-Appellees.

____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:22-cr-00388-VMC-1 ____________________

Before BRANCH, LUCK, and LAGOA, Circuit Judges. LAGOA, Circuit Judge: USCA11 Case: 23-12050 Document: 61-1 Date Filed: 04/07/2026 Page: 2 of 17

2 Opinion of the Court 23-12050

This appeal asks us to determine whether the State may seek a “limited remand” so that it could bring a superseding indictment against Defendants in state court. Such a remand was needed, the State contended, because 28 U.S.C. § 1442 divested the state court of jurisdiction and, under Georgia law, a superseding indictment can be brought only in a state court with jurisdiction over the case. The district court denied the motion after determining that there was no basis in law for a “limited remand,” and the State appealed. After careful review and with the benefit of oral argument, we dis- miss this appeal for lack of jurisdiction. I. FACTUAL AND PROCEDURAL BACKGROUND In August 2016, Jamarion Robinson had three outstanding felony arrest warrants: two for aggravated assault based on his al- leged pointing of a firearm at police officers, and one for attempted arson based on his alleged attempt to set his mother’s home on fire while she slept. 1 The U.S. Marshal Service’s Southeast Regional Fugitive Task Force was tasked with apprehending Robinson and Defendants Eric Heinze and Kristopher Hutchens were two of the officers on the task force. The task force in 2016 located Robinson at his girlfriend’s apartment and conducted a raid, which resulted in Robinson’s death. Five years later, in October 2021, Defendants were indicted by a state grand jury in Fulton County for felony murder, aggra- vated assault with a deadly weapon, first-degree burglary, making

1 Robinson suffered from schizophrenia. USCA11 Case: 23-12050 Document: 61-1 Date Filed: 04/07/2026 Page: 3 of 17

23-12050 Opinion of the Court 3

a false statement, and violation of oath by public officer. Defend- ants separately filed notices of removal in the district court, arguing that they were federal officers and were entitled to trial in federal district court pursuant to 28 U.S.C. § 1442. The State moved to remand the actions to state court, con- tending that the district court lacked subject matter jurisdiction. The district court consolidated the cases and denied the State’s mo- tion. In March 2023, Defendants filed separate motions to dismiss the indictment because of their alleged immunity under the Su- premacy Clause and Georgia’s self-defense law and because of im- proper venue. In May 2023, the State filed a motion for a limited remand to state court to obtain a superseding indictment. The State wanted to drop the charges related to false statements and add charges for conspiracy, malice murder, and felony murder. The State proposed that it would file a notice within two days of obtain- ing an indictment to return to federal court. At a telephone conference regarding this motion, the district court stated that it planned to issue a written decision denying the motion for a limited remand due to concerns about timing. The State filed its reply the next day, arguing that it had substantial dis- cretion in prosecuting state offenses, was not required to explain the timing for its charging decision, could not ask a federal grand jury to return an indictment on state law charges, and could not locate authority authorizing the district court to convene a state USCA11 Case: 23-12050 Document: 61-1 Date Filed: 04/07/2026 Page: 4 of 17

4 Opinion of the Court 23-12050

grand jury. The State also argued that denial of its motion would effectively enjoin it from filing a superseding indictment. At a second hearing on the motion, the State argued that the district court had authority to remand the case because § 1442 con- templated concurrent jurisdiction, § 1455 provides for the greater power of remanding the whole case, and the All Writs Act and the court’s inherent authority could effectuate this. Defendants argued that the State could “nolle pros” the indictment under Fed. R. Crim. P. 1(a)(4) and restart the proceedings with the additional charges. The State asserted that it could not convene a federal grand jury, but that it possibly could “bring a brand new indictment before state court” or “nolle pros this entirely and go back to state court and bring a new indictment.” The district court orally denied the State’s motion, conclud- ing that it lacked authority to remand, and subsequently entered its written order. In its order, the district court explained that it was “not convinced that it [had] the authority to permit a limited re- mand” given that 28 U.S.C. § 1447(c) allows for remand only where the district court apparently lacks subject matter jurisdiction and that the State cited no precedent supporting its proposal. The dis- trict court also concluded that, even if it could remand, it would not, because it was “not convinced” that the State could not super- sede the indictment through other means and it was concerned that there would be “no limitation on future requests for remands.” The district court said the new charges would not affect the USCA11 Case: 23-12050 Document: 61-1 Date Filed: 04/07/2026 Page: 5 of 17

23-12050 Opinion of the Court 5

Defendants’ defenses and that the motion was untimely under the court’s scheduling deadlines. This appeal ensued. Following briefing, the Court asked the parties to address whether we had jurisdiction to review the denial of the State’s mo- tion for a limited remand and, specifically, whether the district court’s order was appealable under the collateral order doctrine. II. ANALYSIS “We are required to examine our jurisdiction sua sponte, and we review jurisdictional issues de novo.” United States v. Lopez, 562 F.3d 1309, 1311 (11th Cir. 2009) (internal citations omitted). Be- cause we normally have jurisdiction only “of appeals from all final decisions of the district courts of the United States,” 28 U.S.C. § 1291 (emphasis added), we requested the parties to address whether we have jurisdiction to hear this appeal since it concerns a non-final order, see Woodard v. STP Corp., 170 F.3d 1043, 1044 (11th Cir. 1999) (noting, in the civil context, that a “[d]enial of a motion to remand is an interlocutory order”); United States v. Shal- houb, 855 F.3d 1255, 1260 (11th Cir. 2017) (noting that, generally, “[t]he final judgment rule prohibits appellate review of a pretrial order in a criminal case until conviction and imposition of sen- tence” (cleaned up)).

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Bluebook (online)
State of Georgia v. Eric A. Heinze, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-georgia-v-eric-a-heinze-ca11-2026.