Background
Steven Todd Roseboro appealed his convictions for possession of a firearm and ammunition by a convicted felon and committing an offense while on release. He challenged the jury venire composition, the government’s use of peremptory strikes, the sufficiency of the evidence, and the constitutionality of the underlying statute.
The court’s reasoning
The court reviewed the jury selection challenge and found the absolute disparity between the population and the jury pool was less than ten percent, failing the fair cross-section requirement. Regarding peremptory strikes, the court noted the government did not strike all black jurors and a black juror remained on the panel, negating an inference of discrimination. On sufficiency, the court held that circumstantial evidence, including Roseboro’s admission of packing the backpack containing the firearm, supported the conviction. Finally, the court affirmed the statute’s constitutionality under the Second Amendment, citing binding precedent that the Supreme Court has not abrogated.
What it means going forward
The decision reinforces the Eleventh Circuit’s adherence to prior panel precedent regarding the constitutionality of federal felon-in-possession laws and sets a clear threshold for challenging jury composition based on statistical disparity.
Podcast (federal-narrative-summaries): Play in new window | Download