United States v. Grady, No. 20-14341 (11th Cir. 2021)
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Defendants, members of the Plowshares Movement, appealed their convictions and sentences for conspiracy, destruction of property on a naval installation, depredation of government property, and trespass. Defendants' convictions stemmed from their actions illegally entering the Naval Submarine Base Kings Bay in St. Marys, Georgia to engage in religious protest of nuclear weapons.
The Eleventh Circuit affirmed defendants' convictions and sentences, concluding that the district court did not err in denying defendants' motions to dismiss the indictment under the Religious Freedom and Restoration Act (RFRA); the district court did not abuse its discretion or otherwise err in holding defendants jointly and severally liable for the full amount of restitution; any alleged error in failing to award Defendants Hennessy and Trotta reductions for acceptance of responsibility was harmless; the district court did not err in holding Hennessy accountable for the entire loss amount when imposing the USSG 2B1.1 enhancement; the district court did not err in failing to address Defendant Grady's RFRA-related sentencing argument; and the district court did not abuse its discretion in failing to give Grady's requested mistake-of-fact jury instruction.
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