U.S. Court of Appeals for the Eleventh Circuit

United States v. Rodney Leroy Brown

September 9, 2026

Summary

The Eleventh Circuit affirmed Brown’s convictions but vacated his sentence, holding that the district court did not commit plain error in admitting the DNA analyst’s testimony under the Confrontation Clause, but plainly erred by applying a later version of the Sentencing Guidelines that increased his career‑offender enhancement, and remanded for resentencing.