United States v. Tamara Denisaha Coleman
23-13337
| 11th Cir. | Jun 27, 2025Background
- Tamara Coleman was convicted for her role in a major, multi-state cocaine operation led by Darrin Southall.
- She was found guilty of conspiracy to possess with intent to distribute over 5 kilograms of cocaine, conspiracy to launder drug proceeds, and 26 counts of money laundering.
- At trial, the government presented both law enforcement and coconspirator testimony directly implicating Coleman in the drug and money laundering schemes.
- Coleman was sentenced to 240 months (20 years) in prison and fined a total of $1 million.
- On appeal, Coleman challenged the admission of certain lay witness testimony, as well as the procedural and substantive reasonableness of her sentence and fines.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Admission of agent's lay testimony | Fondren, as a lay witness, improperly summarized and interpreted key evidence | Any error was harmless due to overwhelming independent evidence | Affirmed (harmless error) |
| Reasonableness of 240-month sentence | Sentence based on erroneous Guidelines calculation; should be lower | District court would impose same sentence regardless; sentence reasonable | Affirmed |
| $1M fine despite inability to pay | Unreasonable due to inability to pay | Substantial evidence supported Coleman handled large sums; fine appropriate | Affirmed |
Key Cases Cited
- United States v. Graham, 981 F.3d 1254 (11th Cir. 2020) (outlines abuse of discretion standard for evidentiary rulings)
- United States v. Trailer, 827 F.3d 933 (11th Cir. 2016) (review standard for reasonableness of sentence)
- United States v. Pon, 963 F.3d 1207 (11th Cir. 2020) (defines harmless error standard for nonconstitutional errors)
- United States v. Emmanuel, 565 F.3d 1324 (11th Cir. 2009) (cumulative evidence does not warrant reversal of conviction)
- United States v. Goldman, 953 F.3d 1213 (11th Cir. 2020) (district courts may impose same sentence regardless of guidelines errors if substantively reasonable)
- United States v. Rodriguez, 75 F.4th 1231 (11th Cir. 2023) (within-Guidelines sentences are presumptively reasonable)