This appeal arises from the federal convictions of William Bryan, Gregory McMichael, and Travis McMichael for their roles in the fatal shooting of Ahmaud Arbery in Satilla Shores, Georgia. Following state court convictions for murder, the defendants were tried in federal court on charges of interference with rights under 18 U.S.C. § 245 and attempted kidnapping under 18 U.S.C. § 1201. The government presented evidence that the defendants, motivated by racial animus and a desire for vigilante justice, chased Arbery through the neighborhood using their trucks to block his escape. The defendants moved for judgment of acquittal, arguing insufficient evidence that they acted because of race, that the streets were public, and that the truck used was an instrumentality of interstate commerce. The district court denied these motions, and the jury convicted all three defendants.
The Eleventh Circuit reviewed the sufficiency of the evidence de novo, viewing the record in the light most favorable to the government. First, regarding interference with rights, the court found ample evidence that the defendants acted because of Arbery's race. This included testimony regarding racially charged comments made by the defendants on social media and in private conversations, as well as evidence that they reacted less severely to a white suspect. The court also affirmed that the streets of Satilla Shores were 'provided or administered' by Glynn County, noting that the county maintained the roads and budgeted public funds for them, even without formal title. Second, regarding attempted kidnapping, the court addressed whether the defendants used an instrumentality of interstate commerce. The majority held that automobiles are per se instrumentalities of interstate commerce under the Commerce Clause. Consequently, the intrastate use of Travis McMichael's truck to pursue and block Arbery satisfied the statutory requirement, regardless of whether the vehicle crossed state lines. The court rejected the dissent's call for a case-by-case analysis, aligning with other circuits that recognize cars as instrumentalities of commerce.
The decision affirms the federal convictions and sentences of the defendants, leaving them to serve their federal terms concurrently with their state sentences. It establishes a binding precedent in the Eleventh Circuit that automobiles are per se instrumentalities of interstate commerce for the purposes of the federal kidnapping statute, simplifying jurisdictional analysis in future cases involving vehicles. The ruling clarifies that county maintenance of roads, even without formal title, satisfies the 'provided or administered' requirement for interference with rights charges.