USA v, Legestin Richards

CourtCourt of Appeals for the Eleventh Circuit
DecidedJanuary 26, 2022
Docket21-10695
StatusUnpublished

This text of USA v, Legestin Richards (USA v, Legestin Richards) 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
USA v, Legestin Richards, (11th Cir. 2022).

Opinion

USCA11 Case: 21-10695 Date Filed: 01/26/2022 Page: 1 of 8

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 21-10695 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus LEGESTIN RICHARDS,

Defendant-Appellant.

Appeal from the United States District Court for the Middle District of Alabama D.C. Docket No. 2:19-cr-00353-RAH-JTA-1 ____________________ USCA11 Case: 21-10695 Date Filed: 01/26/2022 Page: 2 of 8

2 Opinion of the Court 21-10695

Before WILSON, NEWSOM, and ANDERSON, Circuit Judges. PER CURIAM: Police executed a search warrant at the residence where Legestin Richards lived with his aunt. During the search, police officers found multiple firearms throughout the home. Conse- quently, Richards was indicted for possession of a firearm by a felon, in violation of 18 U.S.C. § 922(g)(1), and possession of an un- registered firearm, in violation of 26 U.S.C. §§ 5841, 5861(d), and 5871. After trial, a jury convicted Richards of those counts. Now, Richards appeals his convictions, as well as his 136- month total sentence imposed. First, Richards argues that he had no control over the firearms in the residence where he was located at the time of his arrest and that no witnesses could place him in actual possession of the firearms. He asserts that no evidence was presented at trial to indicate that he was aware of the presence of the firearms at the time of the search, or that he had a firearm on his person or attempted to arm himself when he was discovered by law enforcement. Second, Richards asserts that his 136-month to- tal sentence is substantively unreasonable. He argues that the dis- trict court failed to adequately consider that he was under an on- going threat at the residence and that the government presented insufficient evidence for his convictions. He also contends that the district court failed to consider the “simultaneous nature” of the criminal counts in its decision to impose his sentences consecu- tively. Furthermore, he asserts that the district court gave undue USCA11 Case: 21-10695 Date Filed: 01/26/2022 Page: 3 of 8

21-10695 Opinion of the Court 3

weight to the Sentencing Guidelines and to the allegation that he was a member of the alleged gang, the Black Disciples. I. We start by reviewing the sufficiency of the evidence as to the 922(g) count. 1 To sustain a conviction under § 922(g)(1), the government must prove that (1) the defendant was a convicted felon, (2) the defendant knowingly possessed a firearm, and (3) the firearm affected or was in interstate commerce. United States v. Funches, 135 F.3d 1405, 1406–07 (11th Cir. 1998). The defendant also must know that he is a prohibited person—here, a felon. See Rehaif v. United States, 139 S. Ct. 2191, 2194 (2019); United States v. Coats, 8 F.4th 1228, 1234–35 (11th Cir. 2021). Possession may be either actual or constructive. United States v. Perez, 661 F.3d 568, 576 (11th Cir. 2011). Constructive possession exists when the government “proves, through either di- rect or circumstantial evidence that the defendant (1) was aware or knew of the firearm’s presence and (2) had the ability and intent to later exercise dominion and control over that firearm.” Id. “A de- fendant’s presence in the vicinity of a firearm or mere association

1 We review the sufficiency of the evidence in support of a conviction de novo,

“viewing the evidence in the light most favorable to the government and drawing all reasonable inferences and credibility choices in favor of the jury’s verdict.” United States v. Rodriguez, 218 F.3d 1243, 1244 (11th Cir. 2000) (per curiam). USCA11 Case: 21-10695 Date Filed: 01/26/2022 Page: 4 of 8

4 Opinion of the Court 21-10695

with another who possesses [it] is insufficient” to show possession. Id. In Ochoa, we held that the government presented the jury with sufficient circumstantial evidence from which it reasonably could have concluded that the defendant had constructive posses- sion of ammunition because he exercised dominion and control over the bedroom in which it was located. United States v. Ochoa, 941 F.3d 1074, 1105 (11th Cir. 2019) cert. denied, 140 S. Ct. 2553 (2020). Specifically, the government connected the defendant to the bedroom through “his phones (one of which had on it a photo of Ochoa laying on the bed in the bedroom), personal identification cards, and travel papers bearing his name—all of which were found in the same bedroom as the ammunition.” Id. “The fact that other people had access to or may have also occupied the residence [did] not make [this] evidence insufficient.” Id.; see also United States v. Molina, 443 F.3d 824, 830 (11th Cir. 2006) (concluding sufficient ev- idence supported a defendant’s conviction for possession of a fire- arm in furtherance of a drug trafficking crime because the firearm was found in the defendant's bedroom and the dresser drawer con- tained her passport). Here, the government presented sufficient evidence at trial that Richards was in constructive possession of the firearms. Rich- ards’s statements to law enforcement indicated that he had knowledge of the firearms in the residence and intended to use them when needed, firearms were discovered in almost every room of the house, and Richards was discovered within reaching USCA11 Case: 21-10695 Date Filed: 01/26/2022 Page: 5 of 8

21-10695 Opinion of the Court 5

distance of an unregistered firearm. Further, a reasonable jury could conclude that Richards exercised dominion and control over the entire residence and particularly the master bedroom where a handgun was found. The government presented evidence that Richards’s vehicle was observed at the residence on a daily basis, Richards stated to law enforcement that he lived there with his aunt, and his ID, work badge, prescription pills, and homework were located in the master bedroom. Accordingly, because there was ample evidence to support the jury’s verdict, we affirm Rich- ards’s conviction on the 922(g) count. As to his conviction for possession of an unregistered fire- arm, Richards only fleetingly challenged the denial of his motion for a judgment of acquittal. Because he only raised that issue in passing, with no supporting law or argument, he has abandoned it. See United States v. Jernigan, 341 F.3d 1273, 1283 n.8 (11th Cir. 2003) (“[A] party seeking to raise a claim or issue . . . must plainly and prominently so indicate . . . At the very least, he must devote a discrete, substantial portion of his argumentation to that issue. Otherwise, the issue—even if properly preserved at trial—will be considered abandoned.”). But, even if we were to review the district court’s § 5861(d) decision, it would only be for plain error, see United States v. Baston, 818 F.3d 651, 664 (11th Cir.

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Related

United States v. Rodriguez
218 F.3d 1243 (Eleventh Circuit, 2000)
United States v. Jernigan
341 F.3d 1273 (Eleventh Circuit, 2003)
United States v. Eliany Molina
443 F.3d 824 (Eleventh Circuit, 2006)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Wayerski
624 F.3d 1342 (Eleventh Circuit, 2010)
United States v. Perez
661 F.3d 568 (Eleventh Circuit, 2011)
United States v. Dylan Stanley
754 F.3d 1353 (Eleventh Circuit, 2014)
United States v. Jesus Rosales-Bruno
789 F.3d 1249 (Eleventh Circuit, 2015)
Rehaif v. United States
588 U.S. 225 (Supreme Court, 2019)
United States v. Roosevelt Coats, III
8 F.4th 1228 (Eleventh Circuit, 2021)
United States v. Baston
818 F.3d 651 (Eleventh Circuit, 2016)

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Bluebook (online)
USA v, Legestin Richards, Counsel Stack Legal Research, https://law.counselstack.com/opinion/usa-v-legestin-richards-ca11-2022.