United States v. Charles Grim Rudolph

CourtCourt of Appeals for the Eleventh Circuit
DecidedSeptember 30, 2025
Docket24-12817
StatusUnpublished

This text of United States v. Charles Grim Rudolph (United States v. Charles Grim Rudolph) 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
United States v. Charles Grim Rudolph, (11th Cir. 2025).

Opinion

USCA11 Case: 24-12817 Document: 44-1 Date Filed: 09/30/2025 Page: 1 of 7

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-12817 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

CHARLES GRIM RUDOLPH, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 9:24-cr-80002-KAM-1 ____________________

Before ABUDU, KIDD, and MARCUS, Circuit Judges. PER CURIAM: Charles Grim Rudolph appeals his conviction for knowingly possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). He argues that the district court erred in denying his motion for a USCA11 Case: 24-12817 Document: 44-1 Date Filed: 09/30/2025 Page: 2 of 7

2 Opinion of the Court 24-12817

judgment of acquittal because the evidence was insufficient for a reasonable jury to convict him. After thorough review, we affirm. We review a challenge to the sufficiency of the evidence and the denial of a Rule 29 motion for a judgment of acquittal de novo. United States v. Beach, 80 F.4th 1245, 1258 (11th Cir. 2023). When reviewing the denial of a motion for judgment of acquittal, we view all facts and inferences in the light most favorable to the gov- ernment. Id. at 1255. The evidence need not exclude every rea- sonable hypothesis of innocence for a reasonable jury to find guilt beyond a reasonable doubt, and the jury is free to choose among alternative, reasonable interpretations of the evidence. Id. at 1255– 56. We will not overturn a jury’s verdict if there is any reasonable construction of the evidence that would have allowed the jury to find the defendant guilty beyond a reasonable doubt. Id. at 1255. The test for sufficiency of evidence is the same regardless of whether the evidence is direct or circumstantial, with no distinc- tion in the weight given to each. United States v. Guevara, 894 F.3d 1301, 1307 (11th Cir. 2018). But where the government relies on circumstantial evidence, “‘reasonable inferences, not mere specu- lation, must support the conviction.’” United States v. Estepa, 998 F.3d 898, 908 (11th Cir. 2021). It is unlawful for any person convicted of a crime -- punish- able by more than one year of imprisonment -- to possess, in or affecting commerce, any firearm or ammunition. 18 U.S.C. § 922(g)(1). The elements of possession of a firearm by a felon are: (1) the defendant was a felon; (2) the defendant knew he was barred USCA11 Case: 24-12817 Document: 44-1 Date Filed: 09/30/2025 Page: 3 of 7

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from possessing a firearm; (3) the defendant knowingly possessed a firearm; and (4) the firearm affected or was in interstate com- merce. Rehaif v. United States, 588 U.S. 225, 237 (2019); United States v. Seabrooks, 839 F.3d 1326, 1336 (11th Cir. 2016). Possession can be actual or constructive. United States v. Ochoa, 941 F.3d 1074, 1104 (11th Cir. 2019). Actual possession ex- ists if the defendant had physical possession or personal dominion over the object at issue. Id. Constructive possession may be exclu- sive or shared with others, and it exists where the defendant exer- cises ownership, dominion, or control over the firearm, or has the power and intention to exercise dominion or control. United States v. Flanders, 752 F.3d 1317, 1332 (11th Cir. 2014); United States v. Gunn, 369 F.3d 1229, 1235 (11th Cir. 2004). A defendant has con- structive possession of ammunition or a firearm if he “(1) was aware or knew of the firearm’s presence and (2) had the ability and intent to later exercise dominion and control over that firearm.” United States v. Perez, 661 F.3d 568, 576 (11th Cir. 2011). “A defendant’s mere presence in the area of an object or awareness of its location is not sufficient to establish possession.” United States v. Green, 873 F.3d 846, 852–53 (11th Cir. 2017) (citation modified). So, we’ve held that the evidence that the defendant was walking with another person who carried a suitcase containing a firearm with no forensic evidence tying the defendant to the fire- arm was insufficient to show possession, since it merely proved that the defendant was near the firearm. United States v. Pedro, 999 F.2d 497, 501–02 (11th Cir. 1993). On the other hand, the presence USCA11 Case: 24-12817 Document: 44-1 Date Filed: 09/30/2025 Page: 4 of 7

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of a firearm under the driver’s seat of a car, in which the defendant was a passenger, shows that the defendant had sufficient access to the firearm to establish possession. United States v. Gates, 967 F.2d 497, 499 (11th Cir. 1992). We’ve also held that a firearm found in the glove compartment of the defendant’s car along with a copy of the defendant’s tag receipt showing his ownership of the car, com- bined with the fact that the defendant was in the driver’s seat be- fore the search and had a prior conviction for possession of a fire- arm was “sufficient to establish constructive possession.” United States v. Howard, 742 F.3d 1334, 1341 (11th Cir. 2014). Here, Rudolph argues that the district court erred in denying his motion for judgment of acquittal on his claim that the evidence was insufficient for a jury to convict him of possessing a firearm. The record reflects that Rudolph was driving the car in which the firearm was discovered when a law enforcement officer initiated a traffic stop. The firearm was in the purse of the passenger, Laticia Bradley, and the purse was located next to the center console. Ru- dolph says that the firearm’s proximity to him was insufficient to prove the knowing possession element of his conviction, see Pedro, 999 F.2d at 501–02, the only element he challenges on appeal. Viewing the evidence in the light most favorable to the gov- ernment, we cannot say that the evidence was insufficient for a jury to convict him of knowingly possessing a firearm. Most signifi- cantly, La’Nisha Gittens, a forensic scientist from the police foren- sic biology unit, gave testimony that tied Rudolph to the firearm. She reported that there was “very strong support” that Rudolph’s USCA11 Case: 24-12817 Document: 44-1 Date Filed: 09/30/2025 Page: 5 of 7

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DNA was on the firearm’s trigger -- where Rudolph’s DNA con- tributed 84% of the trigger swab -- and on the grip -- where Ru- dolph’s DNA contributed 94% of the grip swab.

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Related

United States v. Manuel Gunn
369 F.3d 1229 (Eleventh Circuit, 2004)
United States v. Perry Lee Gates, Michael Todd Burley
967 F.2d 497 (Eleventh Circuit, 1992)
United States v. Manuel Pedro, A/K/A Manuel Condiles
999 F.2d 497 (Eleventh Circuit, 1993)
United States v. Perez
661 F.3d 568 (Eleventh Circuit, 2011)
United States v. Frank M. Howard
742 F.3d 1334 (Eleventh Circuit, 2014)
United States v. Lavont Flanders, Jr.
752 F.3d 1317 (Eleventh Circuit, 2014)
United States v. Isaac Seabrooks
839 F.3d 1326 (Eleventh Circuit, 2016)
United States v. Robert William Green
873 F.3d 846 (Eleventh Circuit, 2017)
United States v. Geovanys Guevara
894 F.3d 1301 (Eleventh Circuit, 2018)
United States v. Javier Estepa
998 F.3d 898 (Eleventh Circuit, 2021)
United States v. William Raymond Beach
80 F.4th 1245 (Eleventh Circuit, 2023)

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United States v. Charles Grim Rudolph, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-charles-grim-rudolph-ca11-2025.