Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. JAMARUS DEONTAE HOSKINS

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-23 Docket: 7:24-cr-00154-AMM-GMB-1 The eleventh-circuit vacated Jamarus Hoskins’s sentence and remanded the case for resentencing, reversing the district court’s application of a two-level sentencing enhancement under U.S.S.G. § 2B1.1(b)(4) for receiving stolen property while affirming the four-level leadership-role enhancement under U.S.S.G. § 3B1.1(a). The court held that the receipt-of-stolen-property enhancement was improper because Hoskins acted as an “operative actor” and “thief” within the car theft ring rather than a “fence” who merely sells goods stolen by others. Citing *United States v. Bradley*, the court explained that § 2B1.1(b)(4) applies only to defendants who sell items stolen by others, not to those who direct the thefts themselves. The record showed Hoskins directed co-conspirators on which vehicles to steal, how to steal them, and managed the sales, establishing his role as a thief rather than a receiver of stolen property. Conversely, the court affirmed the leadership-role enhancement, finding no clear error in the district court’s determination that Hoskins was an organizer or leader of criminal activity involving five or more participants. The court relied on evidence that Hoskins exercised decision-making authority, recruited accomplices, controlled the scope of the illegal activity, and managed transactions by instructing runners and paying them, which exceeded mere orchestration of specific transactions. The practical consequence is that Hoskins’s sentence will be recalculated in the district court without the two-level increase for receiving stolen property, while the four-level leadership enhancement remains in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.