The U.S. Court of Appeals for the Eleventh Circuit affirmed Alfonso Leon Wilson's convictions for drug conspiracy and unlawful monetary transactions in a per curiam opinion filed Jan. 12, 2026. Wilson had appealed his convictions from the U.S. District Court for the Middle District of Florida, arguing that procedural errors and insufficient evidence warranted reversing his convictions.
Wilson was originally indicted by a federal grand jury on multiple charges stemming from a drug conspiracy case. The indictment included one count of conspiracy to distribute and possess with intent to distribute 400 grams or more of fentanyl under 21 U.S.C. §§ 846 and 841(b)(1)(A). He also faced one count of possession of 40 grams or more of fentanyl with intent to distribute under 21 U.S.C. § 841(a)(1) and (b)(1)(B), as well as 18 U.S.C. § 2. Additionally, Wilson was charged with two counts of unlawful monetary transactions related to the purchase of a Dodge Durango.
The case presented complex issues regarding drug quantity evidence and the appropriate remedy when courts find insufficient evidence to support the specific quantities alleged in an indictment. Wilson's primary argument on appeal centered on the district court's handling of the drug conspiracy charge when evidence proved insufficient to support the 400-gram fentanyl quantity originally charged.
When the trial court determined that the evidence was insufficient to support the specific drug quantity alleged in the indictment, Wilson argued that this finding should have resulted in a new trial rather than allowing the court to enter judgment on a lesser-included offense. This argument raises important questions about criminal procedure and the appropriate remedies when evidence fails to support the precise charges brought by prosecutors.
The distinction between granting a new trial versus entering judgment on a lesser-included offense is significant in federal criminal law. When evidence is insufficient to support the greater charge but sufficient to support a lesser offense, courts must determine the appropriate procedural response. Wilson's position was that the evidentiary insufficiency required starting over with a new trial, rather than simply reducing the severity of the conviction.
Regarding the unlawful monetary transactions charges, Wilson also challenged the sufficiency of the evidence supporting these convictions. These charges related to his alleged purchase of a Dodge Durango using proceeds from drug trafficking activities. Federal law prohibits monetary transactions involving proceeds from specified unlawful activities, and prosecutors must prove both the underlying criminal activity and that the defendant knew the money came from illegal sources.
The Eleventh Circuit panel, consisting of Chief Judge William Pryor and Circuit Judges Jordan and Kidd, issued a per curiam opinion affirming Wilson's convictions. Per curiam opinions, which represent the unanimous view of the panel without attribution to a specific author, are commonly used for cases that do not require extensive legal analysis or do not establish new precedential rules.
The court's affirmance indicates that Wilson's arguments regarding both the drug conspiracy conviction and the unlawful monetary transactions charges failed to demonstrate reversible error. In federal appeals, defendants must show that any errors that occurred at the trial level were not harmless and actually affected the outcome of the proceedings.
The opinion states that "no reversible error occurred," suggesting that while the court may have identified some issues with the trial proceedings, none rose to the level requiring reversal of the convictions. This language is typical in criminal appeals where courts find that any errors were either harmless or did not substantially affect the defendant's rights.
The case reflects ongoing challenges in federal drug prosecutions, particularly regarding the proof of specific drug quantities that trigger enhanced penalties under federal sentencing guidelines. The Controlled Substances Act establishes different penalty ranges based on the type and quantity of drugs involved in offenses, making the precise determination of drug amounts crucial for both prosecution and defense strategies.
Wilson's case also highlights issues surrounding money laundering and asset forfeiture in drug cases. Federal prosecutors routinely charge defendants with unlawful monetary transactions when they can demonstrate that assets were purchased with drug proceeds. These charges can result in significant additional penalties and allow for asset forfeiture proceedings.
The Middle District of Florida, where Wilson's case originated, handles numerous drug trafficking cases due to Florida's position as a major entry point for illegal drugs entering the United States. The district court's docket number 8:22-cr-00389-TPB-TGW-2 indicates this was a criminal case filed in 2022.
The Eleventh Circuit's jurisdiction covers Alabama, Florida, and Georgia, and the court frequently addresses drug conspiracy and money laundering cases. The circuit's precedents in these areas significantly influence federal criminal practice throughout the Southeast.
Wilson's appeal was handled on the non-argument calendar, meaning the court decided the case based on written briefs without oral argument. This procedural approach is common for cases where the legal issues are well-established or where the appeals court determines that oral argument would not significantly assist in reaching a decision.