The U.S. Court of Appeals for the Eleventh Circuit affirmed the conviction of a former federal postal worker who argued that the trial court violated her constitutional rights by commenting on her decision not to testify. In *United States v. Myelicia T. Rodgers* (11th Cir. 2026), the court held that the district court did not improperly draw adverse inferences from the defendant's silence during her bench trial.

Myelicia Rodgers, a former clerk at the United States Post Office in Crestview, Florida, was convicted of tampering with and stealing mail while employed by the U.S. Postal Service. The case reached the Eleventh Circuit on appeal after Rodgers challenged her conviction on constitutional grounds, specifically arguing that the district court violated her Fifth Amendment right against self-incrimination.

The constitutional issue arose during Rodgers's bench trial in the U.S. District Court for the Northern District of Florida. Chief Judge William Pryor, writing for the three-judge panel, explained that the district court properly informed Rodgers of her right not to testify at trial. Following standard procedure, the court advised her that she could choose whether or not to take the witness stand in her own defense.

Rodgers exercised her constitutional right to remain silent, deciding against testifying and offering no witnesses in her defense. However, the controversy emerged when the district court, while explaining its verdict, mentioned that the prosecution's evidence went "uncontradicted" and specifically noted that Rodgers had not testified.

This language formed the basis of Rodgers's appeal to the Eleventh Circuit. Her defense team argued that the district court's comments about her silence effectively punished her for exercising her Fifth Amendment rights. The Fifth Amendment to the U.S. Constitution protects individuals from being compelled to testify against themselves in criminal proceedings, and courts are generally prohibited from drawing negative inferences from a defendant's decision to remain silent.

The Eleventh Circuit panel, which included Chief Judge William Pryor, Circuit Judge Abudu, and District Judge Anne C. Conway of the Middle District of Florida sitting by designation, carefully analyzed whether the trial court's comments crossed constitutional boundaries. The court's review focused on determining whether the district judge actually drew an adverse inference from Rodgers's silence or merely made a factual observation about the state of the evidence.

In its published opinion filed Jan. 30, 2026, the Eleventh Circuit concluded that the district court did not violate Rodgers's constitutional rights. Chief Judge Pryor wrote that "the district court did not consider Rodgers's silence against her," distinguishing between impermissible adverse inferences and permissible observations about uncontradicted evidence.

The distinction is crucial in Fifth Amendment jurisprudence. While courts cannot use a defendant's silence as evidence of guilt or draw negative inferences from their refusal to testify, they may observe when evidence presented by the prosecution goes uncontested. The Eleventh Circuit determined that the trial court's comments fell into the latter category rather than constituting an improper inference.

This case highlights the delicate balance courts must maintain when addressing a defendant's decision not to testify. The Fifth Amendment protection is fundamental to the American criminal justice system, ensuring that defendants cannot be forced to incriminate themselves. However, courts also must be able to evaluate the evidence presented and explain their reasoning for verdicts.

The Rodgers case involved charges related to mail tampering and theft, federal offenses that fall under postal service regulations. As a postal employee, Rodgers held a position of trust with access to mail and postal facilities. The prosecution apparently presented evidence of her misconduct that went unchallenged during the bench trial, though specific details of the evidence were not included in the appellate opinion excerpt.

The Eleventh Circuit's decision reinforces established precedent regarding Fifth Amendment protections while clarifying the boundaries of permissible judicial commentary. The court's analysis demonstrates how appellate courts carefully scrutinize trial court statements that reference a defendant's silence to ensure constitutional rights are protected.

For defense attorneys, this ruling serves as a reminder that challenges to alleged Fifth Amendment violations require clear evidence that a court drew improper inferences rather than simply acknowledged uncontradicted evidence. The decision also provides guidance for trial judges on how to frame their reasoning when defendants choose not to testify.

The case was designated for publication by the Eleventh Circuit, meaning it will serve as binding precedent within the circuit, which covers Alabama, Florida, and Georgia. Published opinions carry greater weight than unpublished decisions and provide guidance for future cases involving similar constitutional issues.

Rodgers's conviction now stands affirmed, and the Eleventh Circuit's ruling strengthens the body of law governing Fifth Amendment protections in federal criminal cases. The decision balances defendants' constitutional rights with courts' need to evaluate evidence and explain their verdicts in criminal proceedings.