United States v. Dickenson Elan

CourtCourt of Appeals for the Eleventh Circuit
DecidedMarch 6, 2026
Docket24-10495
StatusUnpublished

This text of United States v. Dickenson Elan (United States v. Dickenson Elan) 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. Dickenson Elan, (11th Cir. 2026).

Opinion

USCA11 Case: 24-10495 Document: 49-1 Date Filed: 03/06/2026 Page: 1 of 21

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-10495 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

DICKENSON ELAN, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Middle District of Florida D.C. Docket No. 6:22-cr-00148-PGB-LHP-6 ____________________

Before NEWSOM, BRASHER, and ANDERSON, Circuit Judges. PER CURIAM: Dickenson Elan appeals his conviction and his accompany- ing 135-month sentence for 1 count of conspiracy to violate the Racketeer Influenced and Corrupt Organizations (“RICO”) Act, 18 USCA11 Case: 24-10495 Document: 49-1 Date Filed: 03/06/2026 Page: 2 of 21

2 Opinion of the Court 24-10495

U.S.C. § 1962(d). On appeal, he first argues that the district court abused its discretion in admitting as relevant evidence the 2014 tax returns of four people whose identities Elan’s co-conspirators had stolen, and plainly erred in admitting one of those persons’ 2016 tax return. Second, he argues that insufficient evidence supported the jury’s verdict that convicted him of conspiracy to violate the RICO Act. Third, he argues that the court improperly applied a 22-point enhancement under U.S.S.G. § 2B1.1(b)(1)(L) during his sentenc- ing, based on an overcalculation of his offense’s economic loss. Fourth, he argues that the court’s 135-month sentence was sub- stantively unreasonable because the court did not consider the hardship that will result from his removal to Haiti upon his release from custody. We write only for the parties who are already familiar with the facts, so we include only such detail as is helpful in understand- ing this opinion. I. DISCUSSION A. Challenged Evidentiary Rulings “[We] review[] a district court’s evidentiary rulings for a clear abuse of discretion,” United States v. Dodds, 347 F.3d 893, 897 (11th Cir. 2003), including its admission of prior crimes or bad acts under Federal Rule of Evidence 404(b) and its admission of evi- dence over a defendant’s objection under Federal Rule of Evi- dence 403, United States v. Ramirez, 426 F.3d 1344, 1354 (11th Cir. 2005) (involving Rule 404(b)). See also United States v. Bradberry, 466 F.3d 1249, 1253 (11th Cir. 2006) (involving Rule 403). However, USCA11 Case: 24-10495 Document: 49-1 Date Filed: 03/06/2026 Page: 3 of 21

24-10495 Opinion of the Court 3

plain-error review applies where a defendant did not object to an evidentiary ruling. United States v. Edouard, 485 F.3d 1324, 1343 (11th Cir. 2007). To establish plain error, a defendant must show (1) an error, (2) that is plain, and (3) that affects substantial rights. United States v. Brown, 665 F.3d 1239, 1247 n.3 (11th Cir. 2011). If all three conditions are met, we may recognize an error only if the error seriously affects the fairness, integrity or public reputation of judicial proceedings. Id. Additionally, we will not disturb a court’s erroneous evidentiary rulings unless the error affected the defend- ant’s substantial rights. Dodds, 347 F.3d at 897. “Evidence of criminal activity other than the charged of- fense may be admissible if it is ‘intrinsic evidence’ of the charged offense,” meaning that it “arises out of the same transaction or se- ries of transactions as the charged offense, is necessary to complete the story of the crime, or is inextricably intertwined with the evi- dence regarding the charged offense.” United States v. Harding, 104 F.4th 1291, 1296 (citation omitted). “Evidence is necessary to com- plete the story of a crime when the evidence explains the ‘context, motive, and set-up of the crime’ or reveals important details about the criminal scheme.” Id. at 1297 (citation omitted). “Evidence is inextricably intertwined with a charged crime if it ‘forms an inte- gral and natural part of ’ an account of a crime, or is ‘vital to an understanding of the context of the government’s case.’” Id. (cita- tions omitted). USCA11 Case: 24-10495 Document: 49-1 Date Filed: 03/06/2026 Page: 4 of 21

4 Opinion of the Court 24-10495

Rule 404(b) provides that “[e]vidence of any other crime, wrong, or act is not admissible to prove a person’s character in or- der to show that on a particular occasion the person acted in ac- cordance with the character.” Fed. R. Evid. 404(b)(1). However, such “evidence may be admissible for another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.” Fed. R. Evid. 404(b)(2). Rule 403 provides that a “court may exclude relevant evi- dence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.” Fed. R. Evid. 403. “Rule 403 ‘is an extraordinary remedy which the district court should invoke sparingly, and the balance should be struck in favor of admissibil- ity.’” United States v. Lopez, 649 F.3d 1222, 1247 (11th Cir. 2011) (ci- tation omitted). “In reviewing issues under Rule 403, we look at the evidence in a light most favorable to its admission, maximizing its probative value and minimizing its undue prejudicial impact.” Dodds, 347 F.3d at 897 (citation modified). “Unfair prejudice” means “an undue tendency to suggest decision on an improper ba- sis.” United States v. Kent, 93 F.4th 1213, 1220 (11th Cir. 2024) (cita- tion modified). “[T]here is no absolute bar on the introduction of evidence which pre-dates an alleged conspiracy if the evidence is otherwise relevant.” United States v. Cross, 928 F.2d 1030, 1047 (11th Cir. 1991) (citations omitted). USCA11 Case: 24-10495 Document: 49-1 Date Filed: 03/06/2026 Page: 5 of 21

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If we hold that the district court abused its discretion in ad- mitting evidence, we conduct a harmlessness review. Harding, 104 F.4th at 1298. An evidentiary error “warrants reversal only if ‘there is a reasonable likelihood that the error affected the defendant’s substantial rights.’” Id. (citation omitted). When conducting a harmless-error analysis, we ask “whether the error had substantial influence and whether enough evidence supports the result apart from the error.” Id. (citation omitted). Here, the district court did not abuse its discretion in admit- ting as relevant intrinsic evidence the pre-conspiracy 2014 tax re- turns of Ruselan Barthelemy, Thony Dussuaud, Lluberke Hernan- dez, and Paula Reyes because a sham tax preparation firm that Elan participated in, Edvert Tax Prep (“Edvert”), filed unauthorized tax returns in these taxpayers’ names during the 2015 tax year as part of the charged conspiracy.

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United States v. Dickenson Elan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-dickenson-elan-ca11-2026.