United States v. Smith, No. 18-13969 (11th Cir. 2020)
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The Eleventh Circuit affirmed defendant's convictions and sentences for three counts of Hobbs Act robbery, one count of carjacking, and four counts of brandishing a firearm in furtherance of those crimes of violence. The court rejected defendant's evidentiary claims of error, holding that the admission of eyewitness identification did not violate due process and there was no abuse of discretion in admitting a music video of defendant's rap song.
In regard to defendant's conviction for Hobbs Act robbery, the court held that the district court did not abuse its discretion in refusing to give defendant's substantively incorrect jury instruction and the evidence was sufficient for the jury to conclude that defendant's robbery affected interstate commerce. The court also held that Section 403 of the First Step Act does not apply to defendant's offenses, and thus 18 U.S.C. 924(c)(1)(C) required the district court to impose consecutive 25-year minimum sentences for defendant's convictions on Counts Four, Six, and Eight. Finally, the court held that defendant's 1,105-month sentence does not violate the Eighth Amendment for being grossly disproportionate in light of his crime and was substantively reasonable where the district court considered the 18 U.S.C. 3553(a) sentencing factors and did not abuse its discretion.
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