United States v. Keith Pharms

Court of Appeals for the Eleventh Circuit·Decided February 5, 2026·No. 24-14191·Unpublished

Opinion

USCA11 Case: 24-14191 Document: 43-1 Date Filed: 02/05/2026 Page: 1 of 17

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 24-14191

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus

KEITH PHARMS, a.k.a. B-Boy,

Defendant-Appellant.

Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:23-cr-00004-JPB-JSA-2

Before JORDAN, ABUDU, and ANDERSON, Circuit Judges. PER CURIAM:

A jury convicted Keith Pharms of five criminal charges arising from his involvement in a shooting at a federal officer in the

2 Opinion of the Court 24-14191

aftermath of a car theft and his subsequent conduct while in custody . He now appeals his 192-month sentence, arguing that it violates the Fifth and Sixth Amendments and is procedurally unreasonable because it is based on clearly erroneous facts. For the reasons which follow, we affirm.

I

Testimony at Mr. Pharms’ trial established the following course of events.

On February 24, 2022, Mr. Pharms and two others, Jokava Harris and Blake Beard, drove a black Chevrolet SS (the “Chevy”) to an apartment complex parking garage where they stopped next to an orange Dodge Charger Hellcat (the “Charger”). Mr. Harris broke into the Charger and drove away. Mr. Pharms and Mr. Beard followed in the Chevy. An Atlanta Police Department (“APD”) Sergeant and FBI Task Force Officer, Will Johnson, was on patrol surveilling for stolen cars and believed the Chevy was suspected to be involved in the thefts, so he followed it. As he was following, Officer Johnson heard two separate rounds of gunfire; in the second round, his vehicle was struck, and a bullet narrowly missed him. Officer Johnson reported the event to dispatch, and after a pursuit, APD officers were able to disable the tires on the Charger, but the Chevy got away.

The next day, the South Fulton Police Department found the Chevy, and APD officers retrieved shell casings at the location of the shooting. Mr. Pharms and Mr. Harris were arrested on state

24-14191 Opinion of the Court 3

charges about a month later, and they and Mr. Beard were ultimately connected with the car theft and shooting.

Mr. Pharms was charged in a superseding federal indictment with one count of assault on a federal officer using a deadly and dangerous weapon, in violation of 18 U.S.C. §§ 111(a)(1) & (b); one count of using a firearm during a crime of violence, in violation of 18 U.S.C. §§ 924(c)(1)(A)(ii) & (iii); one count of possession of a firearm by a convicted felon, in violation of 18 U.S.C. § 922(g)(1); one count of possession of cell phones and other electronic devices while in prison, in violation of 18 U.S.C. §§ 1791(a)(2) & (d)(1)(F); and one count of possessing, while in prison, a prohibited object designed to facilitate escape, in violation of 18 U.S.C. §§ 1791(a)(2) & (d)(1)(B).

Mr. Pharms proceeded to trial. At his trial, Mr. Beard testified for the government, as did Avery Hardy, a cellmate of Mr. Pharms’ while he was in custody. Mr. Beard testified that after Mr. Harris took the Charger, he was driving the Chevy, and, when they noticed a vehicle trailing them, Mr. Pharms fired shots at the vehicle following them. Corroborating that testimony, Mr. Hardy testified that Mr. Pharms told him he had shot at the vehicle following them after the theft and that he had later given the gun he used to Mr. Harris, the third person involved in the car theft.

The government also presented social media evidence depicting Mr. Pharms with a gun resembling the one matching the shell casings recovered from the scene. And it presented video evidence of the Chevy leaving the parking garage, in which the

4 Opinion of the Court 24-14191

passenger was wearing clothes consistent with what Mr. Pharms was wearing on that day. On appeal, Mr. Pharms denies that the evidence showed he discharged a firearm during the offense.

Mr. Pharms was convicted on all five counts. However, by a special interrogatory, the jury was asked, “As to Count 2, was the firearm discharged?” The jury checked the “no” box.

After the trial, a probation officer prepared Mr. Pharms’

presentence investigation report (“PSR”), which calculated the recommended sentencing range under the United States Sentencing Guidelines. The PSR grouped Counts 1 and 3 pursuant to U.S.S.G. § 3D1.2(c) into Group A, and Counts 4 and 5 pursuant to § 3D1.2(b) into Group B.

For Group A, the PSR calculated an offense level of 22, consisting of the greater of the adjusted offense levels of Counts 1 and 3, which reflected: (1) a base offense level of 20 for Count 3; (2) no enhancement pursuant to § 2K2.1(b)(6)(b), which permits an increase in the offense level by four if a firearm was used in connection with another felony offense unless, according to the probation officer’s reading of § 2K2.4 Note 4, a sentence on that underlying offense is also being imposed; and (3) a two-level upward adjustment for obstruction of justice. The government objected to the probation officer’s denial of the enhancement under § 2K2.1(b)(6)(b), which the district court overruled. Mr. Pharms’ counsel objected to any factual finding in the PSR that Mr. Pharms discharged the firearm during the offense.

24-14191 Opinion of the Court 5

For Group B, the PSR calculated an offense level of 13, consisting of the greater of the adjusted offense levels of Counts 4 and 5, which reflected: (1) a base offense level of 13 Counts 4 and 5 and (2) no enhancements or adjustments. Based on the adjusted offense levels for Groups A and B, the PSR calculated a total offense level of 22, reflecting the greater adjusted offense levels of the two groups and no adjustments for acceptance of responsibility or any other reason.

As to Count 2, pursuant to § 2K2.4(b), the PSR calculated the applicable guideline sentence as the minimum term of imprisonment required by statute: five years, running consecutively with any other term of imprisonment. See 18 U.S.C. § 924(c)(1)(A)(i). The defense and the government both agreed with this calculation.

Based on these calculations, the PSR calculated a recommended guideline range of 63 to 78 months, plus 60 months consecutive to all other counts.

After the PSR was filed, the government moved for an upward variance, in light of the fact that Mr. Pharms shot at the vehicle following him, nearly striking Officer Johnson, and pressed its contention that a four-level enhancement should have applied to Count 3. The government therefore submitted that a 204-month total sentence was appropriate. Mr. Pharms filed a memorandum in response, arguing that the four-level enhancement did not apply, that his sentence should reflect credit for his time in state custody, and that the 18 U.S.C. § 3553 factors did not favor a longer sentence for several reasons. Mr. Pharms requested a 114-month sentence.

6 Opinion of the Court 24-14191

At the sentencing hearing, the district court denied the four-

level enhancement, but concluded that the evidence supported a finding by the preponderance of the evidence that Mr. Pharms had been the shooter. The court reasoned that, “even if we were, as the defense would argue, going to throw out Mr. Hardy’s testimony entirely, we still have . . . Mr. Beard’s testimony,” and reasoned further that “it makes a lot more sense that it be [sic] the passenger who is firing the shots, and especially here, someone who was able to fire a shot accurately enough from one car to another to come within inches of hitting the person.” D.E. 172 at 38– 39. Thus, the court found that it was more likely than not that Mr. Pharms had shot at Officer Johnson. The court also noted that the social media evidence and Mr. Hardy’s testimony—even if not entirely credited—added weight to its conclusion.

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