United States v. Otis Furman Crabbe

CourtCourt of Appeals for the Eleventh Circuit
DecidedApril 29, 2026
Docket25-11568
StatusUnpublished

This text of United States v. Otis Furman Crabbe (United States v. Otis Furman Crabbe) 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. Otis Furman Crabbe, (11th Cir. 2026).

Opinion

USCA11 Case: 25-11568 Document: 37-1 Date Filed: 04/29/2026 Page: 1 of 16

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11568 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

OTIS FURMAN CRABBE, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 2:24-cr-14037-DMM-1 ____________________

Before LUCK, LAGOA, and MARCUS, Circuit Judges. PER CURIAM: Otis Crabbe appeals his conviction for possession with intent to distribute 50 grams or more of methamphetamine. On appeal, he argues that: (1) the district court erred in denying his motion to USCA11 Case: 25-11568 Document: 37-1 Date Filed: 04/29/2026 Page: 2 of 16

2 Opinion of the Court 25-11568

suppress his stationhouse interrogation; (2) the district court abused its discretion by allowing the government to present expert testimony; (3) the district court clearly erred in denying his chal- lenge to the government’s peremptory strike of a Black venireman; and (4) the district court abused its discretion in declining to pro- vide a jury instruction on the lesser-included offense of simple pos- session. After thorough review, we affirm. I. We review the denial of a motion to suppress as a mixed question of law and fact, with conclusions of law reviewed de novo and findings of fact reviewed for clear error. United States v. Thomas, 160 F.4th 1177, 1181 (11th Cir. 2025). Facts are construed in the light most favorable to the party that prevailed in the district court. Id. “When reviewing the denial of a motion to suppress, [we are] not restricted to the evidence presented at the suppression hearing and instead consider[] the whole record.” United States v. Epps, 613 F.3d 1093, 1097 (11th Cir. 2010). We review de novo whether a statement was voluntary, giving deference to the district court’s factual findings. United States v. Lall, 607 F.3d 1277, 1285 (11th Cir. 2010). The government must establish voluntariness of a chal- lenged confession by a preponderance of the evidence. Id. We generally review discovery violations under Fed. R. Crim. P. 16 for abuse of discretion. United States v. Hastamorir, 881 F.2d 1551, 1559 (11th Cir. 1989). A district court’s decision on whether to give a lesser-included offense instruction also is re- viewed for abuse of discretion. United States v. Gutierrez, 745 F.3d USCA11 Case: 25-11568 Document: 37-1 Date Filed: 04/29/2026 Page: 3 of 16

25-11568 Opinion of the Court 3

463, 470 (11th Cir. 2014). The court abuses its discretion in declin- ing to give an instruction on a lesser-included offense when “the evidence would permit a rational jury to find the defendant guilty of the lesser offense and not the greater.” Id. (citation modified). When we review the district court’s ruling on a challenge made pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), the district court’s determination “is entitled to great deference, and must be sustained unless it is clearly erroneous.” United States v. Robertson, 736 F.3d 1317, 1324 (11th Cir. 2013) (citation modified). Where there are two permissible views of the evidence, the factfinder’s choice between them cannot be clearly erroneous. United States v. McPhee, 336 F.3d 1269, 1275 (11th Cir. 2003). II. First, we are unpersuaded by Crabbe’s claim that the district court erred in denying his motion to suppress his stationhouse in- terrogation. The Supreme Court’s decision in Miranda v. Arizona, 384 U.S. 436 (1966), protects a defendant’s Fifth Amendment right against self-incrimination by requiring that law enforcement offic- ers advise the person subject to custodial interrogation of certain rights and to respect the person’s invocation of those rights. United States v. Woods, 684 F.3d 1045, 1055 (11th Cir. 2012). A defendant may waive his Miranda rights if the government proves by a preponderance of the evidence that the waiver was made voluntarily, knowingly, and intelligently. United States v. Ber- nal-Benitez, 594 F.3d 1303, 1318 (11th Cir. 2010). Voluntariness re- quires that the waiver was the result of “a free and deliberate USCA11 Case: 25-11568 Document: 37-1 Date Filed: 04/29/2026 Page: 4 of 16

4 Opinion of the Court 25-11568

choice rather than intimidation, coercion, or deception.” Id. (cita- tion modified). The waiver must be made with full awareness of the nature of the rights being waived and the consequences of that decision. Id. A court may conclude that Miranda rights were waived only if the totality of the circumstances demonstrates both free choice and the requisite level of comprehension. Id. A defend- ant is deemed to have impliedly waived his Miranda rights if the prosecution shows he both understood his rights and made an un- coerced statement. Berghuis v. Thompkins, 560 U.S. 370, 384 (2010). “While the failure to comply with Miranda creates a pre- sumption that a confession was not voluntary, an examination of the totality of the circumstances is necessary to determine whether the confession was actually voluntarily given.” Lall, 607 F.3d at 1285. Threats of violence or promises of leniency can render a statement involuntary. Id. The use of deception to obtain a con- fession is another important factor. Id. In Lall, we held that where an officer promised a defendant that nothing he said would be used to prosecute him, his subsequent confession was rendered involun- tary because it completely undermined the previously-adminis- tered Miranda warning’s prophylactic effect. Id. at 1287. By con- trast, in United States v. Nash, we held that an officer had not illegally induced the defendant’s ensuing confession where an officer prom- ised to make it known to the prosecutor that the defendant had cooperated, encouraged him to tell the truth, and said that defend- ants who cooperate generally received better sentences. 910 F.2d 749, 752–53 (11th Cir. 1990). We explained that because the officer had not promised the defendant a reduced sentence, the officer USCA11 Case: 25-11568 Document: 37-1 Date Filed: 04/29/2026 Page: 5 of 16

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only had afforded him the opportunity to make an informed deci- sion about the advantages of cooperating with the government. Id. Here, the government met its burden of showing that Crabbe’s statements during his custodial interrogation were volun- tary. For starters, Crabbe concedes in his reply brief that Martin County Sheriff’s Office (“MCSO”) Detective Gitlin provided him adequate Miranda warnings prior to his arrest and custodial inter- rogation. Further, the record reflects that Crabbe implicitly waived his Miranda rights -- after being read his rights, Detective Gitlin told Crabbe that he could exercise his rights at any time, and Crabbe affirmed that he understood his rights, said he had no questions about his rights, and then voluntarily continued speaking with of- ficers. Berghuis, 560 U.S. at 384.

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United States v. Otis Furman Crabbe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-otis-furman-crabbe-ca11-2026.