United States v. William Franklin

Court of Appeals for the Eleventh Circuit·Decided August 17, 2026·No. 25-13004·Unpublished

Opinion

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 25-13004

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus

WILLIAM CHARLES FRANKLIN, Defendant-Appellant.

Appeal from the United States District Court for the Middle District of Georgia D.C. Docket No. 5:24-cr-00067-MTT-CHW-1

Before NEWSOM, BRASHER, and WILSON, Circuit Judges. PER CURIAM:

In June 2024, Defendant-Appellant William Franklin, a white man, was driving his tractor down a rural road in Washington County, Georgia, when he came upon Devon Wilson, a United

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2 Opinion of the Court 25-13004

States Postal Service (USPS) rural mail carrier and a Black man. The road itself was too narrow to allow the two vehicles to pass. Both vehicles stopped, and a conflict ensued. When Wilson refused to back his vehicle down, citing official USPS policy, Franklin became enraged and yelled racially offensive and profane threats, including threats of bodily injury. Wilson’s report of the incident resulted in a federal investigation (June Incident).

Then, in December 2024, Wilson and Franklin met again on another rural road. Wilson was driving a tractor with an attachment on the side known as a harrow.1 This time, neither vehicle stopped and as Franklin passed Wilson, the harrow hit the back side of the USPS vehicle, causing damage. Another report and federal investigation followed (December Incident). After a three-day trial, a jury convicted Franklin of obstructing the mails, assault upon a federal officer, aggravated assault upon a federal officer, and retaliating against a witness.

On appeal, Franklin challenges his conviction and sentence.

He argues that the evidence was insufficient to convict him of the assault, aggravated assault, and retaliation counts, and to support the jury’s finding that he committed those offenses against the victim because of his race. He also argues that his 66-month sentence was procedurally and substantively unreasonable. He maintains that the district court improperly applied an eight-level enhancement under U.S.S.G. § 2J1.2(b)(1)(B) in calculating his advisory

1 The harrow is an implement attached to the back of the tractor used as a

smoothing plow.

25-13004 Opinion of the Court 3

range. He also argues that the district court overlooked key mitigating evidence, including his character reference letters and a report from a forensic psychiatrist. After careful review, we affirm.

I.

First, Franklin argues that the government produced insufficient evidence for a reasonable jury to find him guilty of forcible assault of a federal officer for the June Incident. We review the sufficiency of the evidence to support a conviction de novo, “considering the evidence in the light most favorable to the government and resolving any conflicts in the evidence in favor of the government .” United States v. Bryan, 159 F.4th 1274, 1287 (11th Cir. 2025) (citation modified). “A jury’s verdict cannot be overturned for insufficient evidence unless there is no reasonable construction of the evidence that could support a guilty verdict.” United States v. Smith, 22 F.4th 1236, 1242 (11th Cir. 2022). The factfinder “is free to choose among alternative reasonable interpretations of the evidence , and the government’s proof need not exclude every reasonable hypothesis of innocence.” United States v. Tampas, 493 F.3d 1291, 1298 (11th Cir. 2007) (citation modified). When the government relies on circumstantial evidence, the jury’s verdict must be supported by reasonable inferences and not “mere speculation.” Bryan, 159 F.4th at 1287.

Federal law prohibits forcibly assaulting, resisting, or impeding certain types of federal officers or employees. 18 U.S.C. § 111(a)–(b). The governing statute establishes three separate crimes in an ascending order of punishment and required elements:

4 Opinion of the Court 25-13004

(1) simple assault, (2) forcible assault, and (3) aggravated assault. See United States v. Siler, 734 F.3d 1290, 1296 (11th Cir. 2013). Relevant to this appeal, we have defined offenses in the second category to require something more than simple assault, “such as a willful attempt or threat to inflict serious bodily injury,” coupled with the apparent present ability, which causes the intended victim a reasonable apprehension of “immediate serious bodily harm or death.” United States v. Fallen, 256 F.3d 1082, 1088 (11th Cir. 2001). We have held that none of the three categories require a showing of physical contact. Siler, 734 F.3d at 1297.

Here, there was sufficient evidence for the jury to convict Franklin of forcible assault for his conduct during the June Incident. The jury heard ample testimony about Franklin’s aggressive comments , including direct threats that he would “punch [Wilson] in [his] face.” Photographic evidence showed that Franklin’s tractor was mere inches away from Wilson’s vehicle when Franklin threatened to “drive over” it. Thus, the jury was in a position to reasonably infer both that Franklin had the present ability to carry out his threats and that these threats created a reasonable apprehension of serious bodily injury or death.

II.

Next, Franklin argues that the government produced insuf-

ficient evidence for a reasonable jury to find him guilty of aggravated assault of a federal officer for the December Incident. Franklin disputes that the government ever proved that he used a “farming tractor” as a dangerous weapon towards Wilson.

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25-13004 Opinion of the Court 5

The third category of forcible assault under 18 U.S.C. § 111 is aggravated assault, which requires a showing of all the elements of a regular forcible assault under the second category, plus the element of the usage of a “deadly or dangerous” weapon in the commission of the assault. See Siler, 734 F.3d at 1297; 18 U.S.C. § 111(b). Motor vehicles can constitute deadly or dangerous weapons under § 111. See United States v. Gumbs, 964 F.3d 1340, 1348 (11th Cir. 2020).

Although Franklin argues that evidence supports a reasonable , alternative hypothesis of what occurred on that rural road, 2 we are asked only to determine whether the evidence is sufficient to support the jury verdict. Here, there was sufficient evidence for the jury to convict Franklin of aggravated assault for his conduct during the December Incident. The government produced evidence showing Franklin knew what Wilson looked like and what vehicle he drove from the June Incident and intentionally maneuvered his tractor in a way that only hit the back side of Wilson’s vehicle.3 Franklin immediately left the scene, left his tractor in an

2 Franklin argues that the tractor does not qualify as a “dangerous weapon”

because of its low top speed; that numerous witnesses, including Wilson, considered the incident an accident; that the brief scraping on the rear end of Wilson ’s vehicle was due to Wilson’s failure to yield; and that he did not know Wilson would be on the road that day. Unlike the June Incident, there was no evidence presented of jeers, slurs, or threats. 3 At trial, the government presented evidence that the collision in December

could not have been accidental because of the narrow scope of damage on the back side of Wilson’s car, indicating that Franklin intentionally maneuvered his harrow to scrape the back side of the vehicle and nothing else.

6 Opinion of the Court 25-13004

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