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United States v. Brantley

United States Court of Appeals for the Eleventh Circuit
803 F.3d 1265 (2015)


Facts

The federal government (plaintiff) prosecuted Courtnee Nicole Brantley (defendant) for misprision of a felony, in violation of 18 U.S.C. § 4. The federal district court trial evidence established that Brantley knew that her boyfriend, Dontae Morris, was a convicted felon. As such, it was illegal for Morris to possess firearms. Police officers stopped Brantley's car because it was missing a license plate. Morris, who was sitting in the passenger seat, exited the car, shot and killed two officers, and then fled. Brantley sped off and drove to a friend's apartment, where she was later arrested. Minutes later, Brantley and Morris began exchanging text messages, in which Morris urged Brantley to conceal the car. Brantley told Morris that she had already parked away from the crime scene, but planned to move the car somewhere else. The police eventually arrested Brantley and found her car across the lake from the friend's apartment, parked amid bushes that obscured its empty license plate holder. The government argued that Brantley affirmatively acted to conceal the car, which linked Brantley to Morris, and Morris to the gun used to kill the officers. The jury convicted Brantley, and the judge denied Brantley's motion for a judgment of acquittal notwithstanding the verdict. Brantley appealed to the Eleventh Circuit Court of Appeals.

Rule of Law

Issue

Holding and Reasoning (Proctor, J.)

Concurrence (Martin, J.)

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