The U.S. Court of Appeals for the Eleventh Circuit affirmed Antoine Johnson's federal conviction for possession of a firearm by a convicted felon, rejecting his arguments that the district court erred in denying his motion to suppress evidence and that insufficient evidence supported a sentencing enhancement.
Johnson was convicted under 18 U.S.C. §§ 922(g)(1) and 924(e) following a bifurcated jury trial in the U.S. District Court for the Middle District of Florida. The case, *United States v. Antoine Johnson* (11th Cir. 2026), involved Johnson's appeal of both his conviction and the application of the Armed Career Criminal Act enhancement to his sentence.
The case originated from a traffic stop on May 9, 2023, when Officer Brett Naymik of the Palm Bay Police Department responded to a shots heard call in a high-crime area of Palm Bay, Florida. After departing the area following sunset, Naymik observed Johnson riding his bicycle across a public roadway without visible lights, in violation of Florida Statute § 316.2065(7). The officer activated his vehicle's lights to conduct a traffic stop.
Johnson challenged the traffic stop and subsequent search that led to the discovery of the firearm, filing a motion to suppress the evidence. The district court denied this motion, finding that the traffic stop was justified under Florida law and that the subsequent search was lawful. Johnson argued on appeal that the district court erred in this determination.
The Eleventh Circuit panel, consisting of Circuit Judges Newsom, Brasher, and Hull, issued a per curiam opinion rejecting Johnson's arguments. The court conducted what it described as a "careful review" of the record and found no error in the district court's handling of the suppression motion.
In addition to challenging the denial of his motion to suppress, Johnson also contested the sufficiency of evidence supporting a critical finding that enhanced his sentence under the Armed Career Criminal Act. The ACCA provides for enhanced penalties for defendants who possess firearms after being convicted of three or more violent felonies or serious drug offenses committed on separate occasions.
The jury in Johnson's case made a specific finding that he had committed three prior felony offenses on separate occasions, which triggered the ACCA enhancement. Johnson argued on appeal that insufficient evidence supported this finding, contending that the government failed to prove the separate occasions requirement.
The case proceeded through a bifurcated trial structure, where different aspects of the case were tried separately. This approach is sometimes used in federal criminal cases to address different legal issues or when certain evidence might be prejudicial to one aspect of the case but relevant to another.
The Eleventh Circuit's affirmance of Johnson's conviction reflects the court's determination that both the traffic stop and search were conducted lawfully and that sufficient evidence supported the jury's findings regarding his prior criminal history. The court's decision validates the district court's analysis of the Fourth Amendment issues raised by the traffic stop and search.
Federal felon-in-possession charges under 18 U.S.C. § 922(g)(1) prohibit individuals with prior felony convictions from possessing firearms or ammunition. The statute is frequently prosecuted in federal courts and carries significant penalties, particularly when enhanced under the ACCA.
The Armed Career Criminal Act, codified at 18 U.S.C. § 924(e), mandates a minimum 15-year prison sentence for defendants who violate federal firearm laws and have three or more prior convictions for violent felonies or serious drug offenses committed on separate occasions. The "separate occasions" requirement has been the subject of extensive litigation and requires that the prior offenses were not part of a single criminal episode.
Johnson's case illustrates the challenges defendants face in challenging both the underlying seizure of evidence and the application of federal sentencing enhancements. The Eleventh Circuit's decision demonstrates the court's careful review of both constitutional and evidentiary issues in federal firearms prosecutions.
The opinion was designated "not for publication," meaning it will not be published in the Federal Reporter and has limited precedential value. However, the decision reflects the Eleventh Circuit's approach to analyzing Fourth Amendment challenges in traffic stop cases and evidentiary standards for ACCA enhancements.
The case originated from the Middle District of Florida under District Court docket number 6:23-cr-00139-CEM-LHP-1 and was heard by the Eleventh Circuit under case number 24-14083 on the non-argument calendar, indicating the court decided the case based on the briefs without oral argument.
Johnson's conviction and the circuit court's affirmance underscore the significant consequences individuals with prior felony convictions face under federal firearms laws, particularly when enhanced penalties under the ACCA apply. The decision also reflects the courts' careful scrutiny of both constitutional challenges to evidence gathering and the sufficiency of evidence supporting sentencing enhancements in federal criminal cases.