United States v. James Pettway

Court of Appeals for the Eleventh Circuit·Decided July 10, 2025·No. 24-10422·Unpublished

Opinion

[DO NOT PUBLISH]

In the

United States Court of Appeals For the Eleventh Circuit

No. 24-10422

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus JAMES PETTWAY,

Defendant-Appellant.

Appeal from the United States District Court for the Southern District of Alabama D.C. Docket No. 1:23-cr-00138-TFM-B-1

2 Opinion of the Court 24-10422

Before ROSENBAUM, ABUDU, and MARCUS, Circuit Judges. PER CURIAM:

James Pettway appeals his conviction and 180-month sentence for knowing possession of a firearm by a convicted felon, in violation of 18 U.S.C. § 922(g)(1). On appeal, Pettway argues that: (1) the district court erred in admitting at trial allegedly irrelevant, prejudicial evidence; (2) the district court erred in calculating his base offense level; (3) his upward-variance sentence was substantively unreasonable; and (4) § 922(g)(1) is unconstitutional, both facially and as applied. After thorough review, we affirm.

I.

We review the admissibility of evidence for abuse of discretion . United States v. Troya, 733 F.3d 1125, 1131 (11th Cir. 2013). However, if we find that a district court abused its discretion in admitting evidence, we review for harmless error. United States v. Martin, 794 F.2d 1531, 1533 (11th Cir. 1986). Under that standard, “[r]eversal is warranted only if [the error] resulted in actual prejudice because it had substantial and injurious effect or influence in determining the jury’s verdict.” United States v. Phaknikone, 605 F.3d 1099, 1109 (11th Cir. 2010) (quotations omitted). In making this determination, we consider whether there was overwhelming evidence of guilt. Id.

We review a district court’s fact findings for clear error, and its interpretation of the Sentencing Guidelines de novo. United States v. Cenephat, 115 F.4th 1359, 1367 (11th Cir. 2024). To find clear

24-10422 Opinion of the Court 3

error, we must be left with “a definite and firm conviction that a mistake has been committed.” Id. (quotations omitted). We review the sentence imposed, including those that involve variances, for abuse of discretion. Gall v. United States, 552 U.S. 38, 51 (2007). Ordinarily, we review the constitutionality of a statute de novo as a question of law. United States v. Wright, 607 F.3d 708, 715 (11th Cir. 2010).

The prior-panel-precedent rule requires us to follow a prior binding precedent unless it is overruled by us en banc or by the Supreme Court. United States v. White, 837 F.3d 1225, 1228 (11th Cir. 2016). “To constitute an overruling for the purposes of this prior panel precedent rule, the Supreme Court decision must be clearly on point,” and “actually abrogate or directly conflict with, as opposed to merely weaken, the holding of the prior panel.” United States v. Kaley, 579 F.3d 1246, 1255 (11th Cir. 2009) (quotations omitted). To abrogate a prior panel decision, “the later Supreme Court decision must demolish and eviscerate each of its fundamental props.” United States v. Dubois, 139 F.4th 887, 893 (11th Cir. 2025) (quotations omitted).

II.

First, we are unpersuaded by Pettway’s claim that the district court abused its discretion in admitting at trial evidence of an alleged attempted robbery. In general, we recognize three tiers of admissible evidence. For starters, “[r]elevant direct evidence of a crime charged is always admissible unless it falls under a rule of exclusion.” Troya, 733 F.3d at 1131. Second, evidence is admissible

4 Opinion of the Court 24-10422

as “intrinsic” to the crime itself if it arose from the same transaction or series of transactions as the charged crime, it completes the story of the crime, or it is intertwined with evidence of the charged crime. Id. Third, “extrinsic” evidence may be admissible -- pursuant to Federal Rule of Evidence 404(b) -- if it is relevant to an issue other than character and if the jury reasonably may conclude that the defendant committed the act at issue. Id.

In analyzing whether evidence is “intrinsic,” we’ve said that “[e]vidence, not part of the crime charged but pertaining to the chain of events explaining the context, motive and set-up of the crime, is properly admitted if linked in time and circumstances with the charged crime, or forms an integral and natural part of an account of the crime, or is necessary to complete the story of the crime for the jury.” United States v. McLean, 138 F.3d 1398, 1403 (11th Cir. 1998) (quotations omitted). Evidence typically constitutes a series of transactions if the contested evidence has a temporal and factual connection with the charged offense. United States v. Muscatell, 42 F.3d 627, 630 (11th Cir. 1995) (explaining that the evidence implicated the same actors in common roles with the same modus operandi).

Regardless of whether evidence is admissible as direct, intrinsic or extrinsic, a district court may exclude it if its probative value is substantially outweighed by the danger of unfair prejudice. Fed. R. Evid. 403. We’ve said that the exclusion of relevant evidence is extraordinary relief, so a district court should deploy that strong medicine sparingly. United States v. McGregor, 960 F.3d 1319,

24-10422 Opinion of the Court 5

1324 (11th Cir. 2020). We view the disputed evidence “in a light most favorable to admission, maximizing its probative value and minimizing its undue prejudicial impact.” Id. (quotations omitted). Moreover, the risk of undue prejudice can be reduced by an appropriate limiting instruction. United States v. Ramirez, 426 F.3d 1344, 1354 (11th Cir. 2005); see also United States v. Diaz-Lizaraza, 981 F.2d 1216, 1225 (11th Cir. 1993).

Here, the district court did not abuse its discretion in admitting at Pettway’s felon-in-possession trial evidence of an attempted robbery. As the record reflects, Pettway’s felon-in-possession conviction arose out of a report the Mobile Police Department received of a robbery in November 2022, where the suspect was described as having used a motorized scooter or bicycle. When the investigating officer canvassed the scene two days later, a witness claimed that a person named “Jimmy” committed the robbery and described a nearby location where the officer likely could find “Jimmy.” At that location, the investigating officer saw a person “on a motorized black bike” who matched the suspect’s description . The investigating officer approached the individual, whom he later identified as Pettway, and noticed a handgun inside Pettway’s waistband. Pettway was taken into custody, and during the subsequent interview, he admitted that he’d had the gun for about three weeks and was a convicted felon. Investigators later concluded that the casing from the robbery scene matched the handgun officers found on Pettway during his arrest, and images from the body camera footage of another officer at the scene suggested that a firearm was in Pettway’s waistband.

6 Opinion of the Court 24-10422

On this record, the district court did not abuse its discretion in admitting evidence of the attempted robbery. At trial, Pettway questioned the investigating officer’s credibility and investigative decisions, highlighting the lack of fingerprint and DNA testing on the firearm and problems with the video evidence of the incident and the interview. In response, the government presented the robbery evidence to complete the story of how Pettway came to be investigated by police and found to be a felon in possession of a firearm, just two days after the attempted robbery.

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