USA v. Alfonzo Lewis, No. 20-12997 (11th Cir. 2022)
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On appeal, Defendant challenged his convictions for conspiracy to possess with intent to distribute, and possessing with intent to distribute. Defendant’s four claims on appeal focused on three discrete portions of his criminal proceeding: the initial arrest, the jury selection, and the trial itself. The Eleventh Circuit affirmed Defendant’s conviction and sentence.
Defendant contended that the collateral estoppel doctrine precluded the federal government from relitigating the legality of the traffic stop and the subsequent search of the Suburban as that identical issue was already decided in state court. The court held that because the federal and state governments were not in privity in this case, the federal government was not estopped from relitigating the legality of the traffic stop, the search, and Defendant’s arrest.
Next, Defendant argued that the district court (1) abused its discretion by striking Juror 13 for cause; and (2) erred in sustaining the government’s Batson challenge and seating Juror 11 over Defendant’s peremptory strike. The court concluded that the district court did not abuse its discretion in striking Juror 13 for cause during the voir dire stage of Defendant’s case. Juror 13 never confirmed that she felt capable of following the law and the court’s instructions, thus the district court acted within its wide discretion in striking Juror 13 for cause. Moreover, the court concluded that the district court’s finding of discriminatory intent in the peremptory strike of Juror 11 was not clearly erroneous. Further, any error in excluding evidence relating to why the state court prosecution ended did not affect Defendant’s substantial rights.
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