The U.S. Court of Appeals for the Eleventh Circuit has affirmed the conviction and 192-month sentence of Nathaniel Hilliard for multiple federal drug and firearm charges, rejecting his claims that his constitutional rights were violated during trial proceedings.
Hilliard was convicted on five counts: three counts of heroin distribution, possession of a firearm by a convicted felon, and failure to appear at a pretrial conference. The convictions stemmed from a case in the U.S. District Court for the Middle District of Georgia.
In his appeal to the Eleventh Circuit, Hilliard raised five separate challenges to his conviction and sentence. The appeals court, in a per curiam opinion filed Jan. 9, 2026, rejected all of his arguments after careful review.
Hilliard's primary argument centered on his claim that the district court violated his Sixth Amendment right to self-representation. He argued the trial court improperly denied his request to proceed pro se and instead appointed him counsel against his wishes. The right to self-representation, established in Faretta v. California, allows defendants to waive their right to counsel and represent themselves in criminal proceedings, provided the waiver is knowing and voluntary.
The defendant also challenged his removal from the courtroom during portions of his trial, claiming this violated his Sixth and Fifth Amendment rights as well as the Federal Rules of Criminal Procedure. Criminal defendants generally have the right to be present during their trial, though courts may remove disruptive defendants under certain circumstances.
Regarding the firearm possession charge, Hilliard argued that the evidence was insufficient to overcome his entrapment defense. An entrapment defense requires defendants to show they were induced by government agents to commit crimes they were not predisposed to commit. Hilliard apparently claimed government agents improperly encouraged him to possess the firearm.
Hilliard further argued the district court violated the Confrontation Clause by preventing him from cross-examining government witness Glen Mitchell regarding Mitchell's criminal conviction. The Confrontation Clause guarantees defendants the right to confront witnesses against them, including the ability to cross-examine witnesses about their credibility and potential biases.
Finally, Hilliard challenged his sentence on two grounds. He argued the district court incorrectly applied a sentencing enhancement under U.S. Sentencing Guidelines Section 2K2.1(b)(6), which typically relates to firearm offenses. He also claimed his 192-month sentence was substantively unreasonable.
The Eleventh Circuit panel, consisting of Circuit Judges Newsom, Branch, and Brasher, reviewed each of Hilliard's arguments but provided no detailed reasoning in the brief per curiam opinion. The court simply stated that after careful review, it was affirming the lower court's decision on all counts.
The case highlights several important constitutional and procedural issues in federal criminal law. The right to self-representation remains a complex area where courts must balance defendants' autonomy with ensuring fair and orderly proceedings. Similarly, the scope of cross-examination rights and the application of sentencing enhancements continue to generate appellate litigation.
Drug distribution cases involving firearms often result in significant sentences due to the combination of drug penalties and firearm enhancements. Federal sentencing guidelines typically impose additional penalties when defendants possess firearms in connection with drug crimes, reflecting Congress's intent to deter the dangerous combination of drugs and weapons.
The failure to appear charge adds another layer to Hilliard's case, as defendants who flee or fail to appear at required court proceedings face additional penalties. This charge suggests Hilliard may have attempted to avoid the criminal process at some point during his case.
The opinion was designated 'Not for Publication,' meaning it will not be included in the official court reporters and has limited precedential value. Such designations are common for routine appeals that do not establish new legal principles or resolve novel legal questions.
Hilliard's case was handled on the non-argument calendar, indicating the court determined oral argument was unnecessary to resolve the issues presented. This is typical for appeals where the legal questions are straightforward or where the court's precedent clearly controls the outcome.
The 192-month sentence represents a substantial prison term of 16 years, reflecting the serious nature of the charges and potentially Hilliard's criminal history. Federal drug distribution charges, particularly involving heroin, carry significant penalties under federal sentencing guidelines, and the addition of firearm charges typically results in enhanced sentences.
With the Eleventh Circuit's affirmation, Hilliard's conviction and sentence are now final unless he seeks review from the Supreme Court. However, the Supreme Court accepts very few criminal appeals, particularly those involving routine application of established legal principles rather than novel constitutional questions.