United States v. Harris, No. 19-13692 (11th Cir. 2021)
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To root out police corruption in Miami, the FBI created a reverse sting operation, having agents pose as would-be drug dealers. Officer Anderson became the subject of the investigation and eventually agreed to act as a cooperating witness, wearing a recording device. Anderson identified Officer Harris as having corruptly engaged in misconduct. At the FBI’s direction, Anderson set up the “protection” operation, during which officers Harris and Archibald protected “drug couriers” as they delivered containers purportedly filled with cocaine to hotels. Both were convicted of conspiracy to possess with intent to distribute cocaine, attempted possession with intent to distribute cocaine, and possession of a firearm in furtherance of a drug trafficking crime.
The Eleventh Circuit affirmed, finding the evidence sufficient to support their convictions. With respect to an entrapment defense, the evidence was sufficient for a reasonable jury to find beyond a reasonable doubt that the defendant was predisposed to take part in the charged crimes. Archibald was not entitled to a duress instruction. The court rejected claims of perjury and government misconduct with respect to grand jury proceedings. The defendants failed to establish that the prosecutor struck an African American juror because of race, in violation of “Batson.” The district court did not err by not providing the jury with a read-back of Archibald’s testimony.
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