United States v. Patrick Minor, 698 F. App'x 765

Patrick Minor was tried before a magistrate judge (with consent) for misdemeanor assault under 18 U.S.C. § 113(a)(4) for an incident on an Air Force base; a jury convicted him.
Victim John Toney testified Minor struck him from behind and continued to hit him several times, causing cuts and bruises; Toney denied using any force. Police testimony included an admission by Minor that he hit Toney. Minor did not testify.
During voir dire, prospective juror Ernest Woods (the only black panelist) said his nephew had been treated unfairly by the criminal system and that he had strong feelings but could be impartial; the government used a peremptory strike on Woods.
Minor objected under Batson; the government proffered a race-neutral reason (Woods’ stated bias from his nephew’s case); the magistrate judge upheld the strike.
At sentencing the magistrate imposed 8 months custody and one year supervised release (within the Guidelines range), commenting on Minor’s lack of remorse and criminal record; Minor appealed sentence and other issues to district court, which affirmed; Minor then appealed to the Fifth Circuit.

Issue	Minor's Argument	Government's Argument	Held
Sufficiency of evidence to support assault conviction	Conviction rested on uncorroborated, speculative testimony; Minor denied being aggressor	Victim’s testimony and other evidence permitted a rational jury to find guilt	Affirmed — evidence sufficient; credibility for jury to resolve
Batson challenge to peremptory strike of Woods	Strike was racially motivated; Woods was sole black panelist and said he could be impartial	Strike was race-neutral: Woods expressed strong negative feelings about his nephew’s prosecution that could impair impartiality	Affirmed — prosecutor’s reason was race-neutral and Woods differed materially from selected jurors
Procedural sentencing concerns (e.g., judge’s comments, possible Guidelines misstatement)	Judge may have mis-stated Guidelines and chilled defense counsel; allocution/consideration rights implicated	Written record and PSR reflected correct Guidelines; comments insufficient to show reversible error	Affirmed — no clear procedural error; ambiguous oral remark not shown to reflect misunderstanding
Substantive reasonableness of within-Guidelines 8-month sentence	Sentence greater than necessary given minor injuries and compliance on bond	Sentence accounted for offense seriousness and defendant’s criminal history; within Guidelines presumed reasonable	Affirmed — within-Guidelines sentence presumed reasonable and not an abuse of discretion

Batson v. Kentucky, 476 U.S. 79 (established Batson three-step framework for race-based juror strikes)
Hernandez v. New York, 500 U.S. 352 (describes burdens at Batson steps and credibility determination)
Miller-El v. Dretke, 545 U.S. 231 (permits side-by-side comparative juror analysis in Batson disputes)
United States v. Vargas-Ocampo, 747 F.3d 299 (standard for reviewing sufficiency of evidence)
United States v. Moreno, 185 F.3d 465 (credibility deference to jury on sufficiency review)
United States v. Williams, 264 F.3d 561 (prosecutor’s race-neutral explanation need not be persuasive, only honest)
United States v. Williamson, 533 F.3d 269 (Batson review standard in Fifth Circuit)
Gall v. United States, 552 U.S. 38 (abuse-of-discretion standard for sentence reasonableness review)
United States v. Mondragon-Santiago, 564 F.3d 357 (presumption of reasonableness for within-Guidelines sentences)
United States v. Cooks, 589 F.3d 173 (how to rebut presumption of reasonableness)
United States v. Torres-Aguilar, 352 F.3d 934 (rule that oral pronouncement controls written judgment)
United States v. Pillault, 783 F.3d 282 (limits on applying oral-trumps-written rule to statement of reasons)