United States v. Phillip Howard

CourtCourt of Appeals for the Eleventh Circuit
DecidedJanuary 7, 2026
Docket24-10042
StatusUnpublished

This text of United States v. Phillip Howard (United States v. Phillip Howard) 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. Phillip Howard, (11th Cir. 2026).

Opinion

USCA11 Case: 23-13871 Document: 76-1 Date Filed: 01/07/2026 Page: 1 of 18

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 23-13871 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

PHILLIP TIMOTHY HOWARD, Defendant- Appellant. ____________________ Appeal from the United States District Court for the Northern District of Florida D.C. Docket No. 4:22-cr-00043-AW-MAL-1 ____________________ ____________________ No. 24-10042 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, USCA11 Case: 23-13871 Document: 76-1 Date Filed: 01/07/2026 Page: 2 of 18

2 Opinion of the Court 23-13871

versus

PHILLIP T. HOWARD, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Florida D.C. Docket No. 4:22-cr-00043-AW-MAL-1 ____________________

Before NEWSOM, ABUDU, and ANDERSON, Circuit Judges. PER CURIAM: Phillip Howard appeals both his conviction and sentence re- sulting from his guilty plea to racketeering in violation of 18 U.S.C. § 1962(c). He argues that his guilty plea was invalid because it was not supported by a sufficient factual basis and because it was not knowing and voluntary. He further argues that his 168-months’ imprisonment sentence is both procedurally and substantively un- reasonable. He asserts that the district court improperly calculated his sentence because it used relevant conduct to which he did not plead guilty and inaccurate calculations of actual loss to determine his offense level. Howard also argues that the district court erred in imposing restitution in an amount equal to actual loss, and that it erred in imposing a forfeiture money judgment in the amount of $10,651,941.40. For the reasons we’ll explain below, we AFFIRM the district court on all grounds. The facts of the case are known to the parties, and we repeat them here only as necessary to decide the case. USCA11 Case: 23-13871 Document: 76-1 Date Filed: 01/07/2026 Page: 3 of 18

23-13871 Opinion of the Court 3

I A When, as here, a defendant fails to challenge the validity of a guilty plea in the district court, we review for plain error. United States v. Puentes-Hurtado, 794 F.3d 1278, 1285 (11th Cir. 2015). The defendant bears the burden of showing “that (1) there is an error; (2) the error is clear or obvious, rather than subject to reasonable dispute; (3) the error affected [his] substantial rights; and (4) the er- ror seriously affects the fairness, integrity or public reputation of judicial proceedings.” United States v. Hill, 119 F.4th 862, 866 (11th Cir. 2024) (quotation omitted). A district court must determine that there is a factual basis for a guilty plea before accepting it. Fed. R. Crim. P. 11(b)(3). Whether the facts were sufficient to support the plea depends upon “whether the trial court was presented with evidence from which it could reasonably find that the defendant was guilty.” United States v. Frye, 402 F.3d 1123, 1128 (11th Cir. 2005) (quotation omit- ted). There need not be “uncontroverted evidence of guilt.” United States v. Owen, 858 F.2d 1514, 1516–17 (11th Cir. 1988). Generally, an error that affects substantial rights is one that is “prejudicial,” in that it “affected the outcome of the district court proceedings.” United States v. Olano, 507 U.S. 725, 734 (1993). A defendant who seeks to reverse “his conviction after a guilty plea, on the ground that the district court committed plain error under Rule 11 must show a reasonable probability that, but for the error, he would not have entered the plea.” United States v. Dominguez USCA11 Case: 23-13871 Document: 76-1 Date Filed: 01/07/2026 Page: 4 of 18

4 Opinion of the Court 23-13871

Benitez, 542 U.S. 74, 83 (2004). “A variance from the requirements of [Rule 11] is harmless error if it does not affect substantial rights.” Id. at 80 (quoting Fed. R. Crim. P. 11(h)). To establish that a defendant has committed a RICO viola- tion under 18 U.S.C. § 1962(c), the government must prove: “(1) the existence of an enterprise; (2) that the enterprise affected interstate commerce; (3) that the defendants were employed by or associated with the enterprise; (4) that the defendants participated, either directly or indirectly, in the conduct of the affairs of the en- terprise; and (5) that the defendants participated through a pattern of racketeering activity.” United States v. Starrett, 55 F.3d 1525, 1541 (11th Cir. 1995) (footnote omitted). A “pattern of racketeering ac- tivity” refers to at least two acts of racketeering activity within the span of ten years. Id. Wire fraud in violation of 18 U.S.C. § 1343 qualifies as a “racketeering activity.” 18 U.S.C. § 1961(1)(B). To convict a de- fendant for wire fraud, the government must prove that he (1) in- tentionally participated in a scheme to defraud and (2) utilized in- terstate mails or wires in furtherance of that scheme. United States v. Maxwell, 579 F.3d 1282, 1299 (11th Cir. 2009). “A scheme to de- fraud requires proof of a material misrepresentation, or the omis- sion or concealment of a material fact calculated to deceive another out of money or property.” Id. And “[a] misrepresentation is ma- terial if it has a natural tendency to influence, or [is] capable of in- fluencing, the decision maker to whom it is addressed.” Id. (quota- tion marks omitted). USCA11 Case: 23-13871 Document: 76-1 Date Filed: 01/07/2026 Page: 5 of 18

23-13871 Opinion of the Court 5

Here, the statement of facts attached to Howard’s plea agreement contains facts sufficient for the district court to “reason- ably find that the defendant was guilty.” Frye, 402 F.3d at 1128. He has admitted to the following: being the founder and president of Howard & Associates and The Cambridge Entities; hiring as invest- ment manager and then actively concealing the past of D.W.R., a convicted felon barred by the SEC from engaging in investment work; convincing former NFL players to invest over $4 million with The Cambridge Entities; and misrepresenting the nature of clients’ investments and returns. The district court, considering these facts, found that the plea had a sufficient factual basis. We hold that the district court did not commit plain error in accepting the plea. B The Due Process Clause requires that a guilty plea be know- ing and voluntary. McCarthy v. United States, 394 U.S. 459, 466 (1969). To determine whether the waiver is knowing and volun- tary, a district court accepting a plea of guilty must comply with the three “core objectives” of Rule 11 by ensuring that: (1) the guilty plea is free from coercion; (2) the defendant understands the nature of the charges; and (3) the defendant understands the con- sequences of his plea. United States v. Presendieu, 880 F.3d 1228, 1238 (11th Cir. 2018).

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

Related

United States v. Lewis
115 F.3d 1531 (Eleventh Circuit, 1997)
United States v. Cunningham
161 F.3d 1343 (Eleventh Circuit, 1998)
United States v. Dicter
198 F.3d 1284 (Eleventh Circuit, 1999)
United States v. Lisa Hunter, a.k.a. Lesa Hunter
323 F.3d 1314 (Eleventh Circuit, 2003)
United States v. Quan Chau
426 F.3d 1318 (Eleventh Circuit, 2005)
United States v. Jason M. Moriarty
429 F.3d 1012 (Eleventh Circuit, 2005)
United States v. Dewey M. Hamaker
455 F.3d 1316 (Eleventh Circuit, 2006)
United States v. Debra B. Woodard
459 F.3d 1078 (Eleventh Circuit, 2006)
United States v. Damon Amedeo
487 F.3d 823 (Eleventh Circuit, 2007)
United States v. Robertson
493 F.3d 1322 (Eleventh Circuit, 2007)
United States v. Pugh
515 F.3d 1179 (Eleventh Circuit, 2008)
United States v. Gonzalez
550 F.3d 1319 (Eleventh Circuit, 2008)
United States v. Dorsey
554 F.3d 958 (Eleventh Circuit, 2009)
United States v. Beckles
565 F.3d 832 (Eleventh Circuit, 2009)
United States v. Maxwell
579 F.3d 1282 (Eleventh Circuit, 2009)
McCarthy v. United States
394 U.S. 459 (Supreme Court, 1969)
United States v. Olano
507 U.S. 725 (Supreme Court, 1993)
United States v. Dominguez Benitez
542 U.S. 74 (Supreme Court, 2004)
United States v. Booker
543 U.S. 220 (Supreme Court, 2004)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Phillip Howard, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-phillip-howard-ca11-2026.