United States v. Jerome Kiggundu

CourtCourt of Appeals for the Eleventh Circuit
DecidedMay 12, 2025
Docket22-12011
StatusUnpublished

This text of United States v. Jerome Kiggundu (United States v. Jerome Kiggundu) 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. Jerome Kiggundu, (11th Cir. 2025).

Opinion

USCA11 Case: 22-12011 Document: 68-1 Date Filed: 05/12/2025 Page: 1 of 8

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 22-12011 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus JEROME WALTER KIGGUNDU,

Defendant- Appellant.

Appeal from the United States District Court for the Southern District of Georgia D.C. Docket No. 1:20-cr-00089-JRH-BKE-1 ____________________ USCA11 Case: 22-12011 Document: 68-1 Date Filed: 05/12/2025 Page: 2 of 8

2 Opinion of the Court 22-12011

Before JORDAN, LUCK, and LAGOA, Circuit Judges. PER CURIAM: Jerome Kiggundu appeals his sentence for bank fraud, bank- ruptcy fraud, and making a false statement under oath in the South- ern District of Georgia. On appeal, Kiggundu argues that the dis- trict court erred when it failed to orally articulate the standard con- ditions of supervised release at his sentencing and included them in the written judgment. Kiggundu also contends that the district court’s cursory mention of the “standard conditions of supervision adopted by this court” was not sufficient to incorporate the stand- ard conditions listed in Southern District of Georgia Local Rule 32.1, which are different from the conditions imposed in his written judgment. We ordinarily review the imposition of discretionary condi- tions of supervised release for abuse of discretion, but when a de- fendant fails to raise his objection in the district court, we review for plain error. United States v. Hayden, 119 F.4th 832 (11th Cir. 2024). However, we review de novo whether a defendant “had no opportunity to object at sentencing because the court included the [condition] for the first time in its written final judgment.” Id. at 838 (quotation marks omitted, alteration in original). “An appellate court may not correct an error the defendant failed to raise in the district court unless there is: (1) error, (2) that is plain, and (3) that affects substantial rights.” United States v. Ro- driguez, 75 F.4th 1231, 1241 (11th Cir. 2023). “If all three conditions USCA11 Case: 22-12011 Document: 68-1 Date Filed: 05/12/2025 Page: 3 of 8

22-12011 Opinion of the Court 3

are met, an appellate court may then exercise its discretion to no- tice a forfeited error, but only if (4) the error seriously affects the fairness, integrity, or public reputation of judicial proceedings.” Id. Deviation from a legal rule is error unless the rule has been waived. United States v. Olano, 507 U.S. 725, 732-33 (1993). “Plain” is synon- ymous with “clear” or, equivalently, “obvious.” Id. at 734 (quotes in original). An error is plain if it is clearly contrary to settled law at the time of sentencing or at the time of appellate consideration. United States v. Shelton, 400 F.3d 1325, 1331 (11th Cir. 2005). “Where the explicit language of a statute or rule does not specifi- cally resolve an issue, there can be no plain error where there is no precedent from the Supreme Court or this Court directly resolving it.” Rodriguez, 75 F.4th at 1241. “Normally, although perhaps not in every case, the defendant must make a specific showing of prej- udice to satisfy the ‘affecting substantial rights’ prong.” Olano, 507 U.S. at 735. “In most cases, [a plain error affecting substantial rights] means that the error must have been prejudicial: It must have affected the outcome of the district court proceedings.” Id. at 734. However, some rights are so substantial that prejudice can be presumed from the record without a need for the defendant to independently show that the outcome of the proceedings would have been different. See United States v. Perez, 661 F.3d 568, 585-86 (11th Cir. 2011) (holding that “we presume that the denial of a de- fendant’s right to allocute was prejudicial whenever the possibility of a lower sentence exists”). “A plain error affecting substantial rights does not, without more, satisfy the plain-error test, for oth- erwise the fourth prong and the discretion afforded by the fourth USCA11 Case: 22-12011 Document: 68-1 Date Filed: 05/12/2025 Page: 4 of 8

4 Opinion of the Court 22-12011

prong would be illusory.” Shelton, 400 F.3d at 1333. If no miscar- riage of justice will result if the error is not noticed, a court may decline to notice it. See Johnson v. United States, 520 U.S. 461, 470 (1997) (declining to notice an error, even after finding it was plain, because the error regarded something “essentially uncontroverted at trial,” and reversal would have more seriously affected the fair- ness, integrity, or public reputation of judicial proceedings than af- firming would have). Under 18 U.S.C. § 3583, a court must impose several man- datory conditions of supervised release and may order further dis- cretionary conditions. 18 U.S.C. § 3583(d). The Sentencing Guide- lines permit a court to impose other discretionary conditions of su- pervised release. U.S.S.G. § 5D1.3(b). Additionally, the Guidelines recommend, as a policy statement by the U.S. Sentencing Commis- sion, the imposition of 13 “standard” conditions. Id. § 5D1.3(c), p.s. Other than minor stylistic alterations, these conditions are substan- tially identical to the 13 conditions contained in Kiggundu’s written judgment. See id. Under the Fifth Amendment’s Due Process Clause, a de- fendant has the right to be present and represented by counsel when the district court pronounces their sentence. Rodriguez, 75 F.4th at 1247. To satisfy due process, the district court must pro- nounce the sentence in a manner that “giv[es] the defendant notice of the sentence and an opportunity to object.” Id. (quotation marks omitted). Thus, “[d]ue process concerns arise when a district USCA11 Case: 22-12011 Document: 68-1 Date Filed: 05/12/2025 Page: 5 of 8

22-12011 Opinion of the Court 5

court’s in-court pronouncement of a sentence differs from the judg- ment that the court later enters.” Id. In Rodriguez, we held that the district court violated Rodri- guez’s Fifth Amendment due process rights by imposing additional discretionary conditions in its written judgment without first orally pronouncing the conditions in his presence. Id. at 1246. During the sentencing hearing, the district court did not identify any con- ditions of supervised release, but merely told Rodriguez that, “[u]pon release from imprisonment, you’ll be placed on supervised release, $100 special assessment, no fine.” Id. at 1240 (quotation marks omitted). After sentencing, the district court issued a writ- ten judgment imposing 13 discretionary conditions of supervised release, which were taken from a 1988 administrative order in the Southern District of Florida that required the court to impose the conditions “unless altered or modified by special order.” Id. In ad- dition, ten of these conditions “closely tracked the standard condi- tions contained in the Sentencing Guidelines.” Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Terrance Shelton
400 F.3d 1325 (Eleventh Circuit, 2005)
United States v. Olano
507 U.S. 725 (Supreme Court, 1993)
Johnson v. United States
520 U.S. 461 (Supreme Court, 1997)
United States v. Perez
661 F.3d 568 (Eleventh Circuit, 2011)
United States v. Jesus Rodriguez
75 F.4th 1231 (Eleventh Circuit, 2023)
United States v. Willie D. Hayden
119 F.4th 832 (Eleventh Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Jerome Kiggundu, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-jerome-kiggundu-ca11-2025.