United States v. Corey Jermaine Burroughs

Court of Appeals for the Eleventh Circuit·Decided August 28, 2026·No. 25-11948·Unpublished

Opinion

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 25-11948

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus

COREY JEREMAINE BURROUGHS, Defendant-Appellant.

Appeal from the United States District Court for the Middle District of Alabama D.C. Docket No. 2:23-cr-00187-MHT-SMD-1

Before ROSENBAUM, GRANT, and LUCK, Circuit Judges. PER CURIAM:

Corey Burroughs appeals his convictions for possessing methamphetamine with intent to distribute, possessing fentanyl

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with intent to distribute, and maintaining a drug premises. He argues that the district court erred in denying (1) his motion to suppress all evidence derived from a stop of his vehicle, (2) his motion in limine to exclude certain videos extracted from his phone, and (3) his motion for judgment of acquittal. After careful review, we affirm.

FACTUAL BACKGROUND

Police began investigating Burroughs after they recovered multiple cell phones in Alabama prisons with phone numbers registered to him. Through their investigation, police learned that Burroughs was smuggling synthetic cathinones (a category of drugs commonly referred to as flakka or bath salts) into Alabama prisons by spraying the drugs onto fake legal papers to sneak them past the prisons’ mail inspection.

As part of the investigation, Detective Tyler Curlee of the Montgomery Police Department surveilled a house at 2100 Locust Street in Montgomery, Alabama, which Burroughs had listed as his residence when he was released from prison in 2019. On April 18, 2023, Curlee saw Burroughs leave the house in his car and began following him. After Curlee observed Burroughs speeding in a residential zone and failing to use turn signals, he pulled Burroughs over.

As Curlee approached the driver-side window, he smelled marijuana coming from the vehicle. Curlee explained to Burroughs the reason for the traffic stop, informed Burroughs that he

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could detect the odor of marijuana coming from the vehicle, and ordered Burroughs to step out of the car.

Once Burroughs was secured by another officer, Curlee searched the vehicle. He found a marijuana cigarette in the driver- side door pocket and, in a backpack on the front passenger seat, legal papers later determined to have been soaked with flakka.

Based on the evidence from the car search and the surveillance of the house, police obtained and executed a search warrant for 2100 Locust Street. In the kitchen, police found over 500 grams of methamphetamine, over 50 grams of fentanyl, indeterminate amounts of marijuana and flakka, a square kilo press, a vacuum sealer, baggies, and other drug paraphernalia.

PROCEDURAL BACKGROUND

Burroughs was indicted on one count of possession with intent to distribute 500 grams or more of methamphetamine, see 21 U.S.C. § 841(a)(1), one count of possession with intent to distribute fentanyl, see id. § 841(a)(1), and one count of knowingly maintaining a drug premises, see id. § 856(a)(1). We’ll focus on the parts of the district court proceedings relevant to Burroughs’s appeal : (1) his motion to suppress evidence resulting from the stop; (2) his motion in limine to exclude videos found on his phone; and (3) his motion for judgment of acquittal.

A. Motion to Suppress

After the indictment, Burroughs moved to suppress the evidence derived from the traffic stop, arguing that the stop violated

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the Fourth Amendment because it was pretextual. At a suppression hearing before a magistrate judge, Detective Curlee testified that he’d been monitoring 2100 Locust Street because the state suspected Burroughs of smuggling flakka into its prisons. He stopped Burroughs after witnessing him commit multiple “traffic offenses under Title 32 of the Alabama Code” as Burroughs drove away from the house. Curlee knew Burroughs had driven “well over the speed limit” because Curlee had to drive ten or fifteen miles per hour above the posted speed limit “just to keep up.” He’d also “personally observed” Burroughs make three turns without signaling .

After the hearing, the magistrate judge issued a recommendation denying the suppression motion, concluding that Curlee had probable cause for the stop because Burroughs had violated traffic laws and Curlee’s subjective motivations for conducting the stop were irrelevant. The district court adopted the magistrate judge’s recommendation over Burroughs’s objection.

B. Motion in Limine

The day before trial, Burroughs moved to exclude videos extracted from his phone that showed Burroughs handling drugs at 2100 Locust Street and other locations between 2021 and 2023. One video showed Burroughs counting out ounces of marijuana at 2100 Locust Street next to a drug press and a sealer. Another depicted Burroughs at 2100 Locust Street with wet paper laid out to dry, stating that he was “in the kitchen with his cooking a--.” A

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third video showed Burroughs standing outside a vehicle with vacuum -sealed drugs saying he was “about to flood this place with this sh-t.” A fourth showed Burroughs remodeling and putting in tile and carpet inside the home. Still others showed Burroughs displaying or counting out various drugs, including methamphetamine, marijuana, and fentanyl.

According to Burroughs, these videos were inadmissible because they were “irrelevant” and would “unlawfully taint [his] character.” The government responded that the videos established that Burroughs constructively possessed the drugs found in the kitchen and rebutted Burroughs’s defense that he didn’t know that drugs were being made and kept inside the house.

The district court denied the motion, explaining that the videos were relevant because they tended to show that Burroughs “clearly knew what was going on and was using that house to manufacture drugs,” which was “the thrust of this case.” This “circumstantial evidence” also “show[ed] a pattern” of Burroughs’s involvement with the house, which “refute[d] [Burroughs’s] . . . theory ” that he didn’t know what was going on inside. The district court therefore found that any prejudice to Burroughs from the videos “d[id] not substantially outweigh the[ir] probative value” and allowed the government to introduce the videos into evidence. See Fed. R. Evid. 403.

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C. Motion for Judgment of Acquittal At trial, following the government’s case-in-chief, Burroughs moved for a judgment of acquittal. He argued that the government failed to show “direct evidence of [his] possessing the narcotics found . . . during the[] search warrant” or “evidence of who ha[d] ownership of” the Locust Street residence. The government responded that police apprehended Burroughs leaving the home with narcotics shortly before they executed the search warrant and that the videos extracted from his phone showed “an ongoing pattern of him maintaining these premises for drug trafficking purposes .” The district court denied the motion.

Burroughs then took the stand in his own defense. He admitted that he was the person handling drugs in the videos extracted from his phone, but testified that the drugs actually belonged to someone named Tamika. Burroughs also told the jury that he never lived at 2100 Locust Street and did not possess any drugs found at that address. The defense then rested.

After closing arguments, the jury convicted Burroughs on all counts, and the district court sentenced him to 195 months’ imprisonment .

DISCUSSION

The district court didn’t err in denying Burroughs’s three motions. We address them in the order they were litigated below.

USCA11 Case: 25-11948 Document: 39-1 Date Filed: 08/28/2026 Page: 7 of 14

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A. Motion to Suppress

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