USCA11 Case: 18-13113 Date Filed: 08/12/2021 Page: 1 of 75 [PUBLISH] IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT ________________________ No. 18-13113 ________________________ D.C. Docket No. 5:17-cr-00062-MTT-CHW-1 UNITED STATES OF AMERICA, Plaintiff-Appellee, versus ROOSEVELT COATS, III, Defendant-Appellant. ________________________ Appeal from the United States District Court for the Middle District of Georgia ________________________ (August 12, 2021) Before MARTIN, NEWSOM, and JULIE CARNES, Circuit Judges. JULIE CARNES, Circuit Judge: USCA11 Case: 18-13113 Date Filed: 08/12/2021 Page: 2 of 75 Defendant Roosevelt Coats pled guilty to and was convicted of being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g). The district court sentenced Defendant to serve 235 months in prison pursuant to the Armed Career Criminal Act (“ACCA”), which applies when a defendant who is convicted of violating § 922(g) has three prior convictions for a “serious drug offense” or a “violent felony.” The court applied the ACCA based in part on Defendant’s 2003 Georgia burglary conviction, which the court determined was a violent felony for purposes of the ACCA. Defendant’s sentence also reflected the district court’s denial of an acceptance-of-responsibility reduction to his recommended sentencing guidelines range based on his obstructive conduct preceding his guilty plea. On appeal, Defendant argues that his burglary conviction does not satisfy the ACCA’s definition of a violent felony and that, due to extraordinary circumstances, he was entitled to an acceptance-of-responsibility reduction despite his obstructive conduct. He also argues for the first time on appeal that his conviction should be vacated because his guilty plea was constitutionally invalid pursuant to the Supreme Court’s decision in Rehaif v. United States, 139 S. Ct. 2191 (2019). We affirm Defendant’s conviction because any Rehaif error was nonprejudicial; we affirm Defendant’s sentence because we agree with the district court that his 2003 Georgia burglary conviction qualifies as a violent felony under 2 USCA11 Case: 18-13113 Date Filed: 08/12/2021 Page: 3 of 75 the ACCA, and we conclude that the district court did not clearly err in refusing to award an acceptance-of-responsibility reduction. BACKGROUND Defendant was arrested in 2017 on state drug and weapons charges after making several controlled drug sales to a confidential informant (“CI”). The transactions between Defendant and the CI were monitored through a recording device the CI was wearing. In one of the recorded transactions, Defendant sold the CI a rifle for $100. During their subsequent investigation, police discovered that Defendant had provided the CI with, and was in possession of, additional guns. Defendant was a convicted felon at the time of the transactions with the CI and the investigation. Following his arrest, Defendant was housed at the Wilkinson County, Georgia jail while he awaited trial on the state charges. The CI who assisted in the investigation of Defendant was in custody at the same facility. At some point during his incarceration, Defendant gained access to the CI and assaulted him by punching him in the face. That incident resulted in additional state charges against Defendant for battery and …
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