The U.S. Court of Appeals for the Eleventh Circuit affirmed the convictions of three defendants who were found guilty of conspiracy to commit Hobbs Act robbery, rejecting their appeals on multiple procedural and evidentiary grounds.
The defendants—Jamar Brandon Nattiel (also known as D-Boy and Debo), Palacio Valdes Farley (also known as Bobo and Bo), and Joassaint Josiah Aristil, Jr. (also known as JoJo)—were convicted after a jury trial on a single count of conspiracy to commit Hobbs Act robbery in violation of 18 U.S.C. § 1951(a). The case originated in the U.S. District Court for the Southern District of Florida.
The three-judge panel, consisting of Circuit Judges Jill Pryor, Luck, and Hull, issued a per curiam opinion dated Jan. 5, 2026, systematically addressing each of the defendants' challenges to their convictions.
The defendants mounted a comprehensive appeal, challenging five distinct aspects of their prosecution. First, they collectively challenged the district court's denial of their motions to dismiss the indictment. These motions typically argue that the charges are legally insufficient or that the prosecution lacks jurisdiction to bring the case.
Second, defendant Palacio Farley specifically challenged the denial of his motion to suppress photo lineup identifications. Suppression motions in photo lineup cases often center on whether the identification procedure was unduly suggestive or violated the defendant's constitutional rights. The appeals court found no error in the district court's decision to allow the identification evidence.
Third, the defendants challenged the admission of evidence regarding a robbery in Daytona Beach under Federal Rule of Evidence 404(b). Rule 404(b) allows courts to admit evidence of other crimes, wrongs, or acts if they are relevant to prove motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake. The inclusion of this evidence suggests prosecutors sought to establish a pattern of criminal behavior or demonstrate the defendants' modus operandi.
Fourth, the defendants contested the admission of evidence regarding Palacio Farley's threat against a witness named Lisa Flood, also under Rule 404(b). This evidence likely served to demonstrate consciousness of guilt, obstruction of justice, or a pattern of intimidating behavior designed to interfere with the judicial process.
Finally, all three defendants challenged the district court's denial of their Rule 29 motions for judgment of acquittal. These motions argue that the evidence presented at trial was insufficient to support a conviction and that no reasonable jury could have found the defendants guilty beyond a reasonable doubt.
The Hobbs Act, codified at 18 U.S.C. § 1951, criminalizes robbery and extortion that affects interstate commerce. The law has been a powerful tool for federal prosecutors in targeting organized crime and violent criminal enterprises. Conspiracy charges under the Hobbs Act require proof that defendants agreed to commit robbery and that at least one conspirator took an overt act in furtherance of the conspiracy.
The conspiracy charge indicates that prosecutors alleged the three defendants worked together to plan and execute robbery schemes. The use of multiple aliases for each defendant suggests they may have been involved in ongoing criminal activity where they used false identities to avoid detection.
The appeals court's per curiam opinion indicates that the panel unanimously agreed on the outcome, though the specific reasoning behind each ruling is not detailed in the available excerpt. The court noted that it conducted its review "with the benefit of oral argument," suggesting the defendants' attorneys presented their case in person before the three-judge panel.
The opinion was marked "NOT FOR PUBLICATION," which means it will not appear in the Federal Reporter and has limited precedential value. However, unpublished opinions can still be cited in some circuits and provide guidance on how courts apply legal standards in similar cases.
This case represents another example of successful federal prosecution under the Hobbs Act's conspiracy provisions. The comprehensive nature of the defendants' appeal—challenging both procedural decisions and evidentiary rulings—demonstrates the thoroughness of their legal challenge, making the Eleventh Circuit's affirmance particularly significant.
The case file number 24-10954 indicates this was among the appeals docketed in 2024, with the court issuing its decision early in 2026. The original district court case number 1:22-cr-20556-RKA-5 shows the prosecution began in 2022, indicating a multi-year legal process from indictment through appeal.
With their convictions now affirmed, the defendants face the prospect of serving their sentences unless they pursue further appellate options, such as a petition for rehearing en banc or a petition for writ of certiorari to the U.S. Supreme Court. However, such appeals face long odds, particularly in cases involving well-established legal principles like Hobbs Act prosecutions.