The U.S. Court of Appeals for the Eleventh Circuit has affirmed a 192-month prison sentence for Keith Pharms, rejecting his constitutional challenges to the conviction and sentencing in a case involving the shooting of a federal officer during a car theft operation.
Pharms was convicted on five criminal charges arising from his involvement in shooting at a federal officer in the aftermath of a car theft and his subsequent conduct while in custody. The defendant, also known as "B-Boy," appealed his sentence to the Eleventh Circuit, arguing that it violated the Fifth and Sixth Amendments and was procedurally unreasonable because it was based on clearly erroneous facts.
According to testimony presented at trial, the events leading to Pharms' conviction began on Feb. 24, 2022, when Pharms and two co-defendants, Jokava Harris and Blake Beard, drove a black Chevrolet SS to an apartment complex parking garage. The trio positioned their vehicle next to an orange Dodge Charger Hellcat, which Harris then broke into and stole. Pharms and Beard followed Harris in the Chevrolet as he drove away with the stolen vehicle.
The criminal activity was observed by Atlanta Police Department Sergeant and FBI Task Force Officer Will Johnson, who was conducting patrol operations in the area. Johnson's presence as a federal officer conducting law enforcement duties became central to the federal charges ultimately filed against Pharms and his co-defendants.
The case was originally filed in the U.S. District Court for the Northern District of Georgia under docket number 1:23-cr-00004-JPB-JSA-2. Following his conviction at trial, Pharms was sentenced to 192 months in federal prison, prompting his appeal to the Eleventh Circuit.
In his appeal brief, Pharms raised several constitutional arguments challenging both his conviction and sentence. He specifically claimed that his Fifth Amendment due process rights and Sixth Amendment rights to counsel and a fair trial were violated during the proceedings. Additionally, Pharms argued that his sentence was procedurally unreasonable because the district court relied on clearly erroneous factual findings in determining the appropriate punishment.
The Eleventh Circuit panel, consisting of Circuit Judges Jordan, Abudu, and Anderson, issued a per curiam opinion rejecting all of Pharms' arguments. The court found that the constitutional challenges lacked merit and that the district court properly applied federal sentencing guidelines in determining the 192-month term.
The appeals court's decision was designated "not for publication," indicating that while it resolves the specific case before the court, it does not establish new legal precedent for future cases. This designation is common for routine appeals where the legal principles are well-established and the case turns primarily on factual determinations rather than novel legal questions.
Pharms' case highlights the serious federal penalties that can result from crimes involving federal law enforcement officers. Federal statutes provide enhanced penalties for crimes committed against federal agents acting in their official capacity, reflecting Congress' intent to protect federal law enforcement personnel and deter attacks against them.
The 192-month sentence, equivalent to 16 years in federal prison, reflects the severity with which federal courts treat crimes involving violence or threats against law enforcement officers. Federal sentencing guidelines typically recommend substantial prison terms for such offenses, particularly when they involve the use of firearms or result in injury to officers.
The case was heard on the Non-Argument Calendar, meaning the panel decided the appeal based solely on written briefs without oral argument. This procedural approach is often used for appeals where the legal issues are straightforward and do not require additional clarification through oral advocacy.
Pharms' conviction and the affirmance of his sentence serve as a reminder of the federal government's commitment to prosecuting crimes against federal law enforcement officers to the fullest extent of the law. The case also demonstrates the limited success rate of constitutional challenges to federal criminal convictions, particularly in cases where the evidence of guilt is substantial and proper procedures were followed during trial.
With the Eleventh Circuit's affirmance, Pharms will serve his full 192-month sentence unless he pursues further appeals or seeks other post-conviction relief. The decision effectively closes the direct appeal process for his case, though defendants retain certain limited rights to challenge their convictions through other procedural mechanisms in appropriate circumstances.
The case reflects broader federal law enforcement efforts to combat car theft operations and protect officers conducting investigations into such crimes. Federal involvement in car theft cases often occurs when the crimes cross state lines, involve interstate commerce, or target federal personnel, bringing enhanced penalties and resources to bear against defendants.