United States v. Steven Roseboro

CourtCourt of Appeals for the Eleventh Circuit
DecidedMay 5, 2026
Docket24-13264
StatusUnpublished

This text of United States v. Steven Roseboro (United States v. Steven Roseboro) 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. Steven Roseboro, (11th Cir. 2026).

Opinion

USCA11 Case: 24-13264 Document: 38-1 Date Filed: 05/05/2026 Page: 1 of 18

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-13264 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

STEVEN TODD ROSEBORO, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Middle District of Alabama D.C. Docket No. 1:23-cr-00182-RAH-SMD-1 ____________________

Before NEWSOM, BRASHER, and MARCUS, Circuit Judges. PER CURIAM: Courtney Roseboro appeals his convictions for possession of a firearm and ammunition by a convicted felon, in violation of 18 U.S.C. § 922(g)(1), and committing an offense while on release, in USCA11 Case: 24-13264 Document: 38-1 Date Filed: 05/05/2026 Page: 2 of 18

2 Opinion of the Court 24-13264

violation of 18 U.S.C. § 3147. On appeal, Roseboro argues that: (1) the district court erred in denying his motion challenging the com- position of the jury venire as violating either the fair cross-section requirement of the Sixth Amendment or the principles of the Jury Selection and Service Act (“JSSA”); (2) the court erred by conclud- ing that he failed to establish a prima facie case of discrimination from the government’s use of its peremptory strikes; (3) the evi- dence at his trial was insufficient to support his § 922(g)(1) convic- tion; and (4) § 922(g)(1) is unconstitutional in violation of the Sec- ond Amendment. After thorough review, we affirm. I. We review de novo constitutional challenges to the jury se- lection process. United States v. Grisham, 63 F.3d 1074, 1077 (11th Cir. 1995). We review the denial of a challenge under Batson v. Ken- tucky, 476 U.S. 79 (1986), for clear error. United States v. Robert- son, 736 F.3d 1317, 1324 (11th Cir. 2013). However, we review er- rors of law in the application of Batson de novo. United States v. Allen-Brown, 243 F.3d 1293, 1296 (11th Cir. 2001). We also review de novo whether the evidence was sufficient to sustain a convic- tion. United States v. Davis, 854 F.3d 1276, 1292 (11th Cir. 2017). Finally, we review de novo challenges to the constitutional- ity of a statute. United States v. Dubois (Dubois II), 139 F.4th 887, 890 (11th Cir. 2025), cert. denied, (U.S. Jan. 20, 2026) (No. 25-6281). But when a constitutional claim is raised for the first time on appeal, we review for plain error. United States v. Hughes, 840 F.3d 1368, 1385 (11th Cir. 2016). To establish plain error, the defendant must USCA11 Case: 24-13264 Document: 38-1 Date Filed: 05/05/2026 Page: 3 of 18

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show (1) an error, (2) that is plain, and (3) that affected his substan- tial rights. United States v. Turner, 474 F.3d 1265, 1276 (11th Cir. 2007). If the defendant satisfies these conditions, we may exercise our discretion to recognize the error only if it seriously affects the fairness, integrity, or public reputation of judicial proceedings. Id. Under the prior precedent rule, we are “bound to follow a prior panel’s holding unless and until it is overruled or under- mined to the point of abrogation by an opinion of the Supreme Court or of this Court sitting en banc.” United States v. Gillis, 938 F.3d 1181, 1198 (11th Cir. 2019). We’ve “categorically reject[ed] any exception to the prior panel precedent rule based upon a per- ceived defect in the prior panel’s reasoning or analysis as it relates to the law in existence at that time.” Smith v. GTE Corp., 236 F.3d 1292, 1303 (11th Cir. 2001). II. First, we are unpersuaded by Roseboro’s claim that the dis- trict court erred in denying his motion challenging the composition of the jury venire. The Sixth Amendment guarantees a criminal defendant the right to be tried by juries drawn from a fair cross- section of the community. Grisham, 63 F.3d at 1078. However, there is no requirement that the chosen jury mirror the community and reflect the various distinctive groups in the population. United States v. Green, 742 F.2d 609, 611 (11th Cir. 1984). To establish a prima facie case that a jury selection process does not produce a “fair cross-section” of the community, a defendant must show that: (1) the group alleged to be excluded is a distinctive group in the USCA11 Case: 24-13264 Document: 38-1 Date Filed: 05/05/2026 Page: 4 of 18

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community; (2) representation of the group in venires is not fair and reasonable in relation to the number of such persons in the community; and (3) the underrepresentation is due to systemic ex- clusion of the group in the jury-selection process. Duren v. Missouri, 439 U.S. 357, 364 (1978). Failure to establish any one of these ele- ments results in the failure of the entire Sixth Amendment claim. See United States v. Carmichael, 560 F.3d 1270, 1280 (11th Cir. 2009). To determine whether a distinctive group’s representation is fair and reasonable, we compare the difference between the per- centage of the distinctive group among the population eligible for jury service and the percentage of the distinctive group in the jury pool. Id. If the absolute disparity between these percentages is 10% or less, Duren’s second element is not met. Grisham, 63 F.3d at 1079. We compare the venire’s community to the federal judicial district or division from which jurors are drawn. Id. at 1079–80. The JSSA also protects the “right to grand and petit juries selected at random from a fair cross section of the community in the district or division wherein the court convenes.” 28 U.S.C. § 1861. Procedures for selecting names from these sources should “ensure the random selection of a fair cross section of the persons residing in the community.” Id. § 1863(b)(3). The JSSA provides remedies only for “substantial failure[s] to comply” with its provi- sions. Id. § 1867(d). JSSA violations are substantial if they thwart one of the Act’s foundational principles: “(1) random selection of juror names; (2) from a fair cross-section of the community; and (3) USCA11 Case: 24-13264 Document: 38-1 Date Filed: 05/05/2026 Page: 5 of 18

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use of objective criteria for determination of disqualifications, ex- cuses, exemptions, and exclusions.” Carmichael, 560 F.3d at 1277. Notably, the same analysis used for Sixth Amendment fair cross-section violations applies to JSSA fair cross-section violations. Id. at 1278. The randomness requirement “does not require statis- tical randomness but rather requires a system of selection that af- fords no room for impermissible discrimination against individuals or groups.” Id. at 1277 (citation modified).

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United States v. Steven Roseboro, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-steven-roseboro-ca11-2026.