United States v. Taibian Harris

124 F.4th 1088
CourtCourt of Appeals for the Seventh Circuit
DecidedJanuary 8, 2025
Docket24-1163
StatusPublished
Cited by2 cases

This text of 124 F.4th 1088 (United States v. Taibian Harris) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh 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. Taibian Harris, 124 F.4th 1088 (7th Cir. 2025).

Opinion

In the

United States Court of Appeals For the Seventh Circuit ____________________ No. 24-1163 UNITED STATES OF AMERICA, Plaintiff-Appellee, v.

TAIBIAN HARRIS, Defendant-Appellant. ____________________

Appeal from the United States District Court for the Northern District of Indiana, South Bend Division. No. 3:23-cr-29-DRL — Damon R. Leichty, Judge. ____________________

ARGUED SEPTEMBER 25, 2024 — DECIDED JANUARY 8, 2025 ____________________

Before SCUDDER, KIRSCH, and MALDONADO, Circuit Judges. KIRSCH, Circuit Judge. Taibian Harris and his cousin Tre- veon Smith robbed a store during a blizzard. Despite hazard- ous road conditions, Harris drove at excessive speeds and ran through stop signs and red lights after he encountered the po- lice. He ultimately collided with an oncoming police car that had its emergency lights activated when he tried to pass by it on a narrow, snow-covered road. The district court did not clearly err in finding that Harris recklessly created a 2 No. 24-1163

substantial risk of death or serious bodily injury to another person in the course of fleeing from a law enforcement officer under U.S.S.G. § 3C1.2. I Taibian Harris and Treveon Smith robbed a South Bend cell phone store during a blizzard. Smith entered the store while Harris remained in the car and acted as the getaway driver. Unbeknownst to Harris and Smith, one of the phones Smith took from the store was a bait phone which sent GPS pings of their location to the police. The GPS pings led the po- lice to a gas station, where an officer identified them as possi- ble suspects in the robbery. Harris and Smith left the gas sta- tion a short time later and drove for approximately nine minutes before colliding with an oncoming police car. They were apprehended as they attempted to flee from the collision on foot. Harris and Smith were indicted for robbery under 18 U.S.C. § 1951 and both pled guilty. This appeal only concerns Harris’s sentence. Harris’s Presentence Investigation Report recommended a two-level enhancement for recklessly creat- ing a substantial risk of death or serious bodily injury to an- other person while fleeing law enforcement. See U.S.S.G. § 3C1.2. Harris objected to the enhancement, arguing that there was no reliable evidence he was driving recklessly and that no police officer was ever in actual pursuit of him. To re- but Harris’s objection, the government called Smith as a wit- ness at the sentencing hearing. Smith had not been sentenced yet and hoped he would receive a lighter sentence for cooper- ating against Harris. No. 24-1163 3

Smith described in vivid detail the “high-speed chase” that Harris led the police on after they encountered a police car at the gas station. He testified that Harris was driving fifty or sixty miles per hour through snowy, icy streets, weaving in and out of lanes, and ignoring stop signs and red lights de- spite the hazardous driving conditions. In fact, Smith ex- plained that they decided to commit the robbery because there was a blizzard. They reasoned that the police would have a difficult time catching them given the poor road conditions and lack of visibility. They were right. Although the police car they encountered at the gas station pulled out right after them, Smith said that it was not able to get directly behind them and eventually stopped its pursuit. Later, a second marked police car got within one car’s length of them with its emergency lights activated but also stopped its pursuit after Harris drove through a red light. It was not until a third police car approached from the opposite direction and collided with them that their vehicle came to a stop. The district court credited Smith’s testimony that Harris was driving at excessive speeds and ignoring stop signs and red lights, which was partly corroborated by police dashcam footage. Although the district court expressed skepticism that Harris was actually going fifty or sixty miles an hour, the court recognized that it was natural for a passenger to overes- timate the speed of the vehicle when he is watching someone drive at unsafe speeds, particularly when there are poor driv- ing conditions. Based largely on Smith’s testimony and the dashcam foot- age, the district court overruled Harris’s objection to the sen- tencing enhancement. It found that Harris had recklessly fled from police both in the moments immediately preceding the 4 No. 24-1163

collision and during the nine minutes he eluded police after leaving the gas station. This appeal followed. II The Sentencing Guidelines authorize a two-level enhance- ment if “the defendant recklessly created a substantial risk of death or serious bodily injury to another person in the course of fleeing from a law enforcement officer.” U.S.S.G. § 3C1.2. Harris contends that the district court incorrectly calculated his sentencing range by imposing this two-level enhance- ment. We interpret the Sentencing Guidelines de novo and re- view the district court’s factual findings for clear error. United States v. Dean, 574 F.3d 836, 844 (7th Cir. 2009). We reverse un- der clear error review only when we are “left with the definite and firm conviction that a mistake has been made, such as a situation in which a district court credited exceedingly im- probable testimony.” United States v. Wendt, 465 F.3d 814, 816 (7th Cir. 2006) (cleaned up). A Harris first challenges the district court’s finding that he was driving recklessly. But in doing so he minimizes the ma- neuvers he engaged in for nine minutes after leaving the gas station. Specifically, the district court found that Harris drove at excessive speeds and ran through red lights and stop signs despite hazardous road conditions created by a blizzard. This conduct is more than sufficient to satisfy the recklessness standard in U.S.S.G. § 3C1.2. Further, the district court found that Harris was also act- ing recklessly in the moments leading up to the collision. Har- ris argues that the district court improperly ascribed to him No. 24-1163 5

the recklessness of the police officer who collided with him. But that is not what the district court did. Instead, it faulted Harris for continuing to drive toward a marked police car that had its lights activated despite the narrowness of the road and hazardous road conditions. The district court did not clearly err in finding that such conduct was reckless. See United States v. Brooks, 100 F.4th 825, 833 (7th Cir. 2024) (applying clear er- ror review to recklessness determination). Finally, Harris suggests that the district court erred in ap- plying a negligence standard rather than a recklessness stand- ard when it evaluated his conduct. Although the district court mentioned that a reasonable person would not do what Har- ris did, the court also found that Harris was aware of the risks that were created by his conduct yet recklessly invited a sub- stantial risk of serious injury anyway. That is an appropriate application of the recklessness standard. See U.S.S.G. § 3C1.2, cmt. n.2; U.S.S.G. § 2A1.4, cmt. n.1 (defining reckless as “a sit- uation in which the defendant was aware of the risk created by his conduct and the risk was of such a nature and degree that to disregard that risk constituted a gross deviation from the standard of care that a reasonable person would exercise in such a situation”). B Harris also challenges the district court’s finding that he was fleeing from law enforcement. He argues that a police car was never actually pursuing him—that is, a police car was never directly behind his vehicle with its lights or sirens acti- vated.

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Bluebook (online)
124 F.4th 1088, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-taibian-harris-ca7-2025.