Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. JOJUAN LINDSEY

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-24 Docket: 8:23-cr-00071-KKM-SPF-1 The eleventh-circuit affirmed Jojuan Lindsey’s conviction and sentence for possession of a firearm by a convicted felon. The court held that the district court did not clearly err in denying Lindsey’s motion to suppress evidence found during a warrantless search of his rental vehicle, nor did it err in applying a four-level sentencing enhancement under U.S.S.G. § 2K2.1(b)(6)(B). Regarding the suppression motion, the court applied the automobile exception to the Fourth Amendment, which permits a warrantless search if the vehicle is readily mobile and police have probable cause. The court reviewed the district court’s factual findings for clear error and its legal application de novo, construing facts in the light most favorable to the prevailing party. The court found sufficient probable cause based on the totality of the circumstances, including Lindsey’s failure to stop immediately at a traffic stop, his evasive driving maneuvers (turning left, slowing down, then accelerating), furtive movements suggesting he was hiding objects, his refusal to roll down the window or exit the vehicle promptly, and his spontaneous disclaimer of ownership. The court determined that the officers’ testimony regarding these events was credible and not incredible as a matter of law, even where dashcam footage was inconclusive due to darkness. Regarding the sentencing enhancement, the court reviewed the district court’s application of the Sentencing Guidelines de novo and its factual finding for clear error. Lindsey argued the enhancement was improper because it relied on Application Note 14(B) regarding “close proximity” rather than the guideline text itself. The court noted that while it does not defer to commentary unless the guideline text is ambiguous, the record supported the enhancement under the plain meaning of § 2K2.1(b)(6)(B). The court found it more likely than not that Lindsey possessed the firearm in connection with another felony offense (possession with intent to distribute cocaine), as the loaded gun was found near cocaine and drug paraphernalia, including a digital scale, indicating the weapon had the potential to facilitate the drug trafficking. As a practical consequence, the judgment of the district court is affirmed, and Lindsey’s conviction and 150-month sentence remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.