Case Explained: UNITED STATES OF AMERICA v. ROLEX BRYAN BRUNO

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-10

Docket: 1:21-cr-20418-JLK-1

The eleventh-circuit vacated the defendant’s conviction for carjacking and remanded the case for a new trial on that count. The court held that the district court committed plain error by delivering an Allen charge that deviated substantially from the circuit’s pattern jury instructions. Specifically, the district court failed to inform the jurors that they need not give up their honest beliefs regarding the weight and effect of the evidence. While the standard of review for a challenge to the coercive nature of an Allen charge is plain error when no objection was made to the content at trial, the court found the omission of this specific language constituted an obvious error under controlling precedent, including *United States v. Scruggs*. The court determined that this error affected the defendant’s substantial rights, evidenced by the jury’s split verdict—convicting the defendant on the carjacking count while acquitting him on the related firearms charges immediately after receiving the improper instruction. Consequently, the conviction is vacated, and the case is remanded for a new trial on the carjacking charge; the court declined to address the defendant’s challenge to his sentence as it was unnecessary given the reversal of the conviction.

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