131 F.4th 1288
11th Cir.2025Background
- Johnathan Morris was pulled over in Miami after running a stop sign and leading police on a car chase.
- Upon arrest, police found two firearms and ammunition in his vehicle and controlled substances on his person.
- Morris, a convicted felon, was charged with possession of a firearm and ammunition by a felon, possession of a controlled substance with intent to distribute, and possession of a firearm in furtherance of a drug trafficking crime.
- At trial, Morris requested a special verdict form requiring jury unanimity as to which specific firearm he possessed, but the district court denied the request.
- The jury convicted Morris on all counts and he was sentenced to 138 months’ imprisonment; he appealed, raising several challenges, including the special verdict form issue.
Issues
| Issue | Morris's Argument | Government's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for conviction | Evidence was insufficient for all counts | Evidence was sufficient | Conviction affirmed; evidence sufficient |
| Denial of motion to suppress evidence from the traffic stop | Stop was unlawful, evidence should be suppressed | Stop was lawful | Conviction affirmed; no error in denial of suppression |
| Refusal to require jury to unanimously identify which firearm was possessed under § 922(g) | Jury must agree on each specific firearm possessed | Jury need only agree on possession of "any firearm" | No error; unanimity not required as to which firearm, only possession of a firearm |
| Jury instruction about flight from police | Instruction was prejudicial and improper | Instruction was valid | Conviction affirmed; instruction was not improper |
| Reasonableness of sentence | Sentence was unreasonable | Sentence was reasonable | Sentence affirmed |
Key Cases Cited
- Richardson v. United States, 526 U.S. 813 (1999) (distinguishes between elements and means for jury unanimity)
- United States v. Prather, 205 F.3d 1265 (11th Cir. 2000) (standards for verdict form errors and due process)
- United States v. McNely, 99 F.3d 1068 (11th Cir. 1996) (verdict form review parallels jury instruction review)