United States v. Michael Boyer

CourtCourt of Appeals for the Third Circuit
DecidedOctober 1, 2024
Docket23-3253
StatusUnpublished

This text of United States v. Michael Boyer (United States v. Michael Boyer) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. Michael Boyer, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

__________

No. 23-3253 ___________

UNITED STATES OF AMERICA

v.

MICHAEL BOYER,

Appellant

________________ Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Criminal Action No. 2-22-cr-00429-001) District Judge: Honorable Timothy J. Savage ________________ Submitted Under Third Circuit L.A.R. 34.1(a) September 26, 2024

Before: KRAUSE, BIBAS and AMBRO, Circuit Judges

(Opinion filed: October 1, 2024)

___________ OPINION* ___________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. AMBRO, Circuit Judge

Michael Boyer was convicted of carjacking after stealing a vehicle with an

accomplice in Philadelphia. He argues, as he did in a post-trial motion before the District

Court, that the Government failed to establish that he acted with the requisite intent to

commit that offense. Like the District Court, which denied his motion and later

sentenced him, we determine that a rational juror could have found Boyer possessed the

requisite intent beyond a reasonable doubt. We thus affirm.

Boyer and an accomplice, Asad Brown, stole a vehicle from Elliott Anderson in

the early hours of May 22, 2022, as Anderson and his friend Corey sat in the car near

Love Park in Philadelphia. Before the carjacking, Anderson had spoken with Boyer for

about 30 minutes in the park before he returned to his car with Corey.1 When Anderson

and Corey left the park to walk toward Anderson’s car, Boyer told Brown that he wanted

to rob them. Brown agreed, and as the two started to pursue Anderson, Brown handed

Boyer a fanny pack containing a BB gun. There was no evidence presented at trial

bearing on whether the BB gun was loaded or unloaded.

Boyer and Brown then approached Anderson’s car, and Boyer pulled the gun

partially out of the bag so that Anderson could see it. Anderson, believing a robbery was

taking place, asked Boyer, “[A]re we really doing this?” App. 43. Boyer affirmed and

told Anderson to get out of the car. Corey, who had previously intimated he had a

firearm, tried to grab his bag before leaving the vehicle. According to Anderson’s

1 Another acquaintance of Anderson named Destiny had also talked with Boyer but was not involved in the subsequent carjacking. 2 testimony, Boyer threatened Corey as he was doing so by asking, “[A]re you trying to get

shot?” App. 43. After Anderson and Corey got out of the car, Boyer and Brown let

Anderson fetch his backpack from the vehicle. Boyer then sat in the driver’s seat, Brown

got in the backseat, and the two fled in the car.

Later that afternoon, a Philadelphia police officer spotted the stolen vehicle. The

officer attempted to pull Boyer and Brown over and instructed Brown, who was now

driving the car, to park it and throw the keys out of the window. Boyer told Brown

instead to drive away, and he sped off. Brown drove at a high rate of speed through stop

signs, struck a child on a bicycle, and finally crashed into several parked cars. Boyer and

Brown then fled on foot. The two were soon apprehended by officers. Officers also

recovered Brown’s fanny pack, containing the BB gun used in the carjacking.

Boyer was indicted and charged with carjacking and aiding and abetting in

violation of 18 U.S.C. §§ 2119 and 2. He proceeded to trial in July 2023, where the jury

found him guilty. Boyer filed a post-trial motion for judgment of acquittal per Federal

Rule of Criminal Procedure 29(c), arguing that the Government had failed to establish

that he had acted with the specific intent to cause death or serious bodily harm—an

element of carjacking, as set out below. Fed. R. Crim. P. 29(c). The District Court

denied the motion, concluding that a rational juror could have found the intent element

beyond a reasonable doubt. The Court then sentenced Boyer to 120 months’

imprisonment and a term of supervised release of three years.

3 On appeal, Boyer makes the same argument as in his Rule 29 motion, i.e., that the

Government’s evidence at trial failed to establish he acted with the requisite intent to

support his carjacking conviction.2

We review the sufficiency of the evidence under a “highly deferential” standard,

and we will overturn a jury verdict only “if no reasonable juror could accept the evidence

as sufficient to support the conclusion of the defendant’s guilt beyond a reasonable

doubt.” United States v. Caraballo-Rodriguez, 726 F.3d 418, 430–31 (3d Cir. 2013)

(quoting United States v. Coleman, 811 F.2d 804, 807 (3d Cir. 1987)). “[T]he jury’s

verdict must be assessed from the perspective of a reasonable juror, and the verdict must

be upheld as long as it does not ‘fall below the threshold of bare rationality.’” Caraballo-

Rodriguez, 726 F.3d at 431 (quoting Coleman v. Johnson, 566 U.S. 650, 656 (2012)). In

this context, we review the evidence in the light most favorable to the prosecution. Id. at

430.

The criminal carjacking statute provides that a person is guilty of the offense

when, “with the intent to cause death or serious bodily harm[, he] takes a motor vehicle

that has been transported, shipped, or received in interstate or foreign commerce from the

person or presence of another by force and violence or by intimidation, or attempts to do

so[.]” 18 U.S.C. § 2119. In other words, to establish the offense, the Government must

prove beyond a reasonable doubt that the defendant “(1) with intent to cause death or

serious bodily harm (2) took a motor vehicle (3) that had been transported, shipped or

2 The District Court had jurisdiction under 18 U.S.C. § 3231. We have jurisdiction under 28 U.S.C. § 1291. 4 received in interstate or foreign commerce (4) from the person or presence of another (5)

by force and violence or intimidation.” United States v. Applewhaite, 195 F.3d 679, 685

(3d Cir. 1999) (quoting United States v. Lake, 150 F.3d 269, 272 (3d Cir. 1998)). The

District Court instructed the jury on these elements, and Boyer raises no dispute

concerning the instruction.

Boyer challenges the sufficiency of the evidence only for the first element: intent

to cause death or serious bodily harm. He argues that the Government failed to establish

the requisite intent because the BB gun was not an actual firearm; Boyer never “removed

the BB gun completely from the bag”; the carjackers allowed Anderson to retrieve his

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Related

Holloway v. United States
526 U.S. 1 (Supreme Court, 1999)
United States v. Hilton A. Lake, Hilton A. Lake
150 F.3d 269 (Third Circuit, 1998)
Coleman v. Johnson
132 S. Ct. 2060 (Supreme Court, 2012)
United States v. Richard Caraballo-Rodriguez
726 F.3d 418 (Third Circuit, 2013)
United States v. Fekete
535 F.3d 471 (Sixth Circuit, 2008)
United States v. Applewhaite
195 F.3d 679 (Third Circuit, 1999)
United States v. Dontae Small
944 F.3d 490 (Fourth Circuit, 2019)
United States v. Guerrero-Narvaez
29 F.4th 1 (First Circuit, 2022)

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United States v. Michael Boyer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-michael-boyer-ca3-2024.