United States v. James Mathurin
868 F.3d 921
| 11th Cir. | 2017Background
- In 2007, James Mathurin (just shy of 18) committed a months-long spree of armed robberies and two carjackings; he was arrested on Dec. 12 after a 7-Eleven robbery and carjacking.
- After initial post-arrest statements and plea negotiations, the Government indicted and tried Mathurin; his first conviction was vacated on Speedy Trial Act grounds and the indictment was dismissed without prejudice.
- The Government re-indicted him within 10 days; at a second trial Mathurin was convicted on nearly all counts and later sentenced to 685 months (57 years, 1 month).
- Mathurin challenged (a) suppression rulings (probable cause, voluntariness, plea negotiation protections, eyewitness IDs), (b) dismissal-without-prejudice and timeliness of the second indictment, (c) certain evidentiary rulings at retrial, and (d) the sentence under Graham (juvenile non-homicide life-without-parole rule) and Pearce (vindictive sentencing).
- The Eleventh Circuit affirmed both conviction and sentence, rejecting suppression and evidentiary claims, upholding dismissal without prejudice under the Speedy Trial Act and 18 U.S.C. §3288, and finding the sentence compatible with Graham once good-time credits and time-served were considered; it also held no presumption of vindictiveness applied because a different judge imposed the second sentence.
Issues
| Issue | Mathurin's Argument | Government's Argument | Held |
|---|---|---|---|
| Probable cause for arrest / admissibility of post-arrest statements | Arrest lacked probable cause; statements should be suppressed | Officer had victim ID and possession of victim property; probable cause existed | Probable cause existed; statements admissible |
| Statements during plea negotiations (Rule 410) | Statements were made in plea negotiation context and inadmissible | Defendant was advised no promises would be made; expectation unreasonable | No error — statements not protected under Rule 410 |
| Voluntariness / Miranda and juvenile-notice issues | Waiver form inadequate; mother not promptly notified; questioned despite counsel | Waivers were signed and Miranda given; statutory notice delay does not render statements involuntary | Statements voluntary and admissible |
| Eyewitness identifications | IDs unreliable (delay, uncertainty) and should be suppressed | Identification procedures were not unduly suggestive; reliability adequate | No undue suggestiveness shown; IDs admissible |
| Dismissal of original indictment without prejudice (Speedy Trial Act) | Dismissal should be with prejudice | Court weighed seriousness of offenses, good-faith prosecutorial delay, minimal prejudice to defendant | Dismissal without prejudice was proper |
| Statute of limitations / re‑indictment timeliness | Some robbery counts time-barred after dismissal | 18 U.S.C. §3288 permits re‑indictment within 6 months; new indictment filed promptly | Re‑indictment timely (filed within 10 days) |
| Admission of evidence relating to conduct acquitted at first trial | Collateral estoppel forbids presenting evidence of firearm use tied to acquitted firearm counts | Dowling controls — probative admissible evidence need not be sanitized because of prior acquittal | Admission proper; no double jeopardy bar |
| Prosecutorial misconduct (closing, uncorrected testimony) | Misstatements and failure to correct prejudiced jury | Any remarks were not improper or not prejudicial given weight of evidence | No reversible prosecutorial misconduct |
| Eighth Amendment / Graham challenge to long term-of-years sentence for juvenile offender | 685-month term is functionally life without parole given life expectancy (esp. for black males); violates Graham | Good‑time credits and time‑served create a meaningful opportunity for release within defendant’s life; Graham not violated | Sentence complies with Graham — defendant has realistic opportunity for release (good‑time credits reduce actual time below life expectancy) |
| Vindictive sentencing (Pearce) | Longer sentence after successful appeal was punitive/vindictive | Different judge imposed sentence; judge gave explicit non‑vindictive reasons for longer sentence | No presumption of vindictiveness (different sentencer); no actual vindictiveness found |
Key Cases Cited
- Feliciano v. City of Miami Beach, 707 F.3d 1244 (11th Cir. 2013) (probable cause standard for arrests)
- Merrill v. United States, 685 F.3d 1002 (11th Cir. 2012) (test for subjective and objective expectation of plea negotiation protection)
- Montejo v. Louisiana, 556 U.S. 778 (2009) (Miranda waiver and waiver of counsel during interrogation)
- Dowling v. United States, 493 U.S. 342 (1990) (double jeopardy collateral-estoppel does not bar otherwise admissible probative evidence of conduct underlying acquitted charges)
- Zedner v. United States, 547 U.S. 489 (2006) (effect of dismissal without prejudice on reindictment and statute of limitations)
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment prohibits life without parole for juvenile non-homicide offenders; requires meaningful opportunity for release)
- North Carolina v. Pearce, 395 U.S. 711 (1969) (presumption of vindictiveness when harsher sentence follows successful appeal; reasons must affirmatively appear)
- United States v. Williams, 314 F.3d 552 (11th Cir. 2002) (standard of review and Speedy Trial Act remedy review)
- United States v. Frank, 599 F.3d 1221 (11th Cir. 2010) (standard for prosecutorial misconduct review)