United States v. Ahkil Crumpton
24-10925
11th Cir.Mar 21, 2025Background
- Ahkil Crumpton was convicted of attempted Hobbs Act robbery and aiding and abetting a false statement to a firearms dealer.
- Crumpton sought to introduce evidence suggesting that his roommate, Juwan Taylor, was the actual perpetrator of the robbery.
- The district court excluded evidence relating to Taylor as a potential suspect, citing concerns over prejudice, jury confusion, and lack of nexus between Taylor and the crime.
- At trial, Crumpton was still permitted to argue that the police conducted an incomplete investigation and failed to consider other suspects.
- On appeal, Crumpton claimed his constitutional right to present a complete defense was violated by excluding the third-party guilt evidence.
- The Eleventh Circuit reviewed both evidentiary and constitutional error arguments, ultimately affirming the district court’s ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of third-party guilt evidence | Crumpton: Excluding evidence about Taylor violated his right to present a complete defense | Government: No sufficient connection between Taylor and the crime; evidence is prejudicial / confusing | Court found no constitutional violation; exclusion was reasonable |
| Whether error was harmless | Crumpton: Error was not harmless, prejudiced his defense | Government: Any error did not affect substantial rights | Any error was harmless beyond a reasonable doubt |
| Sufficient nexus between third party and crime | Crumpton: Taylor’s similarities and access to gun supported nexus | Government: Evidence was speculative and disconnected | No sufficient, non-speculative nexus to warrant admission |
| Right to present essence of defense to jury | Crumpton: Was unable to present complete theory | Government: Essence of alternative theory was presented | Court found Crumpton presented his theory to the jury |
Key Cases Cited
- United States v. Frazier, 387 F.3d 1244 (11th Cir. 2004) (discussing constitutional right to present a complete defense and evidentiary rulings)
- United States v. King, 713 F.2d 627 (11th Cir. 1983) (Rule 403 balancing between probative value and unfair prejudice)
- Cikora v. Dugger, 840 F.2d 893 (11th Cir. 1988) (nexus requirement for third-party guilt evidence)
- United States v. Nunez, 1 F.4th 976 (11th Cir. 2021) (standard for harmless error review in constitutional claims)
- United States v. Harris, 916 F.3d 948 (11th Cir. 2019) (right is not prejudiced if essence of defense argument is presented to jury)