United States v. Olajuwon Raheem Williams

CourtCourt of Appeals for the Eleventh Circuit
DecidedJune 3, 2024
Docket23-12790
StatusUnpublished

This text of United States v. Olajuwon Raheem Williams (United States v. Olajuwon Raheem Williams) 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. Olajuwon Raheem Williams, (11th Cir. 2024).

Opinion

USCA11 Case: 23-12790 Document: 30-1 Date Filed: 06/03/2024 Page: 1 of 7

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 23-12790 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus OLAJUWON RAHEEM WILLIAMS,

Defendant-Appellant.

Appeal from the United States District Court for the Southern District of Georgia D.C. Docket No. 1:22-cr-00122-JRH-BKE-1 ____________________ USCA11 Case: 23-12790 Document: 30-1 Date Filed: 06/03/2024 Page: 2 of 7

2 Opinion of the Court 23-12790

Before ROSENBAUM, GRANT, and BLACK, Circuit Judges. PER CURIAM: Olajuwon Williams appeals his 120-month sentence for pos- session of a firearm by a convicted felon. He asserts the district court clearly erred in failing to apply a reduction for acceptance of responsibility, pursuant to U.S.S.G. § 3E1.1(a), because he had clearly demonstrated acceptance of responsibility by the time of sentencing. The Government has moved for summary affirmance, arguing that, under § 3E1.1, Williams’ obstruction of justice en- hancement precludes a reduction for acceptance of responsibility except in “extraordinary cases,” and submits that United States v. Coats, 8 F.4th 1228 (11th Cir. 2021), dictates that Williams’ case is not extraordinary. After review, 1 we grant the Government’s mo- tion for summary affirmance. Pursuant to U.S.S.G. § 3C1.1, a defendant’s offense level will be increased by two levels if: (1) the defendant willfully obstructed or impeded, or attempted to obstruct or impede, the administration of justice with respect to the investigation, prosecu- tion, or sentencing of the instant offense of convic- tion, and

1 We “review the district court’s determination of acceptance of responsibility

only for clear error.” United States v. Amedeo, 370 F.3d 1305, 1320 (11th Cir. 2004). USCA11 Case: 23-12790 Document: 30-1 Date Filed: 06/03/2024 Page: 3 of 7

23-12790 Opinion of the Court 3

(2) the obstructive conduct related to (A) the defend- ant’s offense of conviction and any relevant conduct; or (B) a closely related offense . . . . U.S.S.G. § 3C1.1. Pursuant to U.S.S.G. § 3E1.1, a defendant’s of- fense level may be decreased: (a) If the defendant clearly demonstrates acceptance of responsibility for his offense, decrease the offense level by 2 levels. (b) If the defendant qualifies for a decrease under sub- section (a), the offense level determined prior to the operation of subsection (a) is level 16 or greater, and upon motion of the government stating that the de- fendant has assisted authorities in the investigation or prosecution of his own misconduct by timely notify- ing authorities of his intention to enter a plea of guilty, thereby permitting the government to avoid preparing for trial and permitting the government and the court to allocate their resources efficiently, decrease the offense level by 1 additional level. Id. § 3E1.1. The defendant bears the burden of clearly demonstrat- ing he has accepted personal responsibility. United States v. Wright, 862 F.3d 1265, 1279 (11th Cir. 2017). A relevant factor for whether the reduction is appropriate is whether the defendant voluntarily terminated or withdrew from criminal conduct or associations. U.S.S.G. § 3E1.1, comment. (n.1(B)). In addition, we have held a court may consider USCA11 Case: 23-12790 Document: 30-1 Date Filed: 06/03/2024 Page: 4 of 7

4 Opinion of the Court 23-12790

“subsequent criminal conduct in deciding whether a decrease pur- suant to § 3E1.1 is appropriate,” even if that conduct is unrelated to the offense of the conviction. United States v. Pace, 17 F.3d 341, 343 (11th Cir. 1994); Wright, 862 F.3d at 1279. Commentary appli- cation note 4 of § 3E1.1 specifies that “[c]onduct resulting in an en- hancement under § 3C1.1 . . . ordinarily indicates that the defend- ant has not accepted responsibility for his criminal conduct. There may, however, be extraordinary cases in which adjustments under both §§ 3C1.1 and 3E1.1 may apply.” U.S.S.G. § 3E1.1, comment. (n.4). In Coats, we rejected Coats’ argument he was entitled to an acceptance of responsibility reduction despite his obstructive con- duct, which preceded his guilty plea. Coats, 8 F.4th at 1232-34. Dur- ing his incarceration in county jail, Coats assaulted a material wit- ness in his case by punching him in the face in an attempt to influ- ence his testimony. Id. at 1233, 1261. A federal grand jury later indicted Coats for the same underlying incident as his state charges, and he subsequently pleaded guilty. Id. at 1233, 1261. Coats re- ceived an enhancement for obstruction of justice based on his as- sault of the witness, and he was denied a reduction for acceptance of responsibility given the obstruction of justice and based on the court’s finding that there were no “extraordinary circumstances” warranting the reduction. Id. at 1233–34, 1262. On appeal, Coats argued he was entitled to the reduction because of the “extraordinary circumstance” that his obstructive conduct preceded his guilty plea. Id. at 1234. We rejected his USCA11 Case: 23-12790 Document: 30-1 Date Filed: 06/03/2024 Page: 5 of 7

23-12790 Opinion of the Court 5

argument and determined the speed of federal authorities is an ar- bitrary and inapt factor in determining whether a case is extraordi- nary. Id. at 1263. While Coats contended his guilty plea evidenced acceptance of responsibility despite his obstructive conduct, we re- jected his argument, because a defendant “must present more than just a guilty plea to establish acceptance of responsibility . . . even more so when . . . the obstructive act was a violent assault of a key witness.” Id. (quotation marks omitted). We noted Coats’ argu- ment failed to account for the violent nature of his obstructive con- duct and held the court did not clearly err. Id. We grant the Government’s motion for summary affir- mance because its position is clearly correct as a matter of law. Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969) 2 (explaining summary disposition is appropriate where “the posi- tion of one of the parties is clearly right as a matter of law so that there can be no substantial question as to the outcome of the case, or where, as is more frequently the case, the appeal is frivolous”). The court did not clearly err in declining to apply the reduction for acceptance of responsibility, pursuant to U.S.S.G. § 3E1.1. Alt- hough Coats did not define “extraordinary cases,” the facts in the instant case are similar such that a finding of clear error in Williams’ case is irreconcilable with this Court’s holding in Coats. First, while Williams suggests his guilty plea and apology sufficiently

2In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc), this

Court adopted as binding precedent all decisions of the former Fifth Circuit handed down prior to close of business on September 30, 1981. USCA11 Case: 23-12790 Document: 30-1 Date Filed: 06/03/2024 Page: 6 of 7

6 Opinion of the Court 23-12790

demonstrate that he accepted responsibility, this Court directly re- jected that argument in Coats. Coats, 8 F.4th at 1263; see also Wright, 862 F.3d at 1279. Accordingly, Williams’ contention that his guilty plea alone demonstrated acceptance of responsibility cannot suc- ceed.

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

Related

United States v. Damon Amedeo
370 F.3d 1305 (Eleventh Circuit, 2004)
Larry Bonner v. City of Prichard, Alabama
661 F.2d 1206 (Eleventh Circuit, 1981)
United States v. Stanley M. Pace
17 F.3d 341 (Eleventh Circuit, 1994)
United States v. Keyiona Marvete Wright
862 F.3d 1265 (Eleventh Circuit, 2017)
United States v. Roosevelt Coats, III
8 F.4th 1228 (Eleventh Circuit, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Olajuwon Raheem Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-olajuwon-raheem-williams-ca11-2024.