United States v. Brantley
United States Court of Appeals for the Eleventh Circuit
803 F.3d 1265 (2015)
After Courtnee Brantley's (defendant) boyfriend Dontae Morris, a felon prohibited from possessing firearms, shot and killed two police officers during a traffic stop of her car and fled, Brantley drove away and, after exchanging texts in which Morris urged her to conceal the car, told him she had already parked it away from the scene and planned to move it further; police later found her car parked amid bushes obscuring its empty license plate holder. Brantley was convicted of misprision of felony for knowingly concealing evidence of Morris's illegal gun possession, and the trial judge denied her motion for acquittal notwithstanding the verdict; she appealed.
Whether sufficient evidence supported a misprision of felony conviction based on inferences that the defendant affirmatively acted to conceal her car as evidence connecting her boyfriend to an illegally possessed firearm.