United States v. Scott Evan Jones
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
§ 3A1.1. United States v. Tate later declined to extend Jones's sentencing objection-elicitation procedure to Batson objections. The remaining citing opinions applied Jones's unaffected rules, reported Morrill's act in history parentheticals, rejected claims that later decisions implicitly overruled Jones, or concerned unrelated authority.
310 later cases cite United States v. Scott Evan Jones; 164 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
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This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Eleventh Circuit sitting en banc overruled Jones to the extent it treated bank tellers as categorically vulnerable victims under U.S.S.G. § 3A1.1.
United States v. Morrill · Eleventh Circuit · filed
Because a panel cannot overturn circuit precedent, we voted the case en banc. We now hold that bank tellers, as a class, are not vulnerable victims within the meaning of section 3A1.1. To the extent that Jones holds to the contrary, that case is overruled.
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Limited
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The Eleventh Circuit declined to extend Jones's sentencing objection-elicitation procedure to Batson objections during jury selection.
United States v. Tate · Eleventh Circuit · filed
Tate requests that this court create a new rule mandating that district courts provide counsel with an opportunity to raise Batson objections, similar to the rule announced in United States v. Jones, 899 F.2d 1097, 1102 (11th Cir. 1990), overruled in part on other grounds by United States v. Morrill, 984 F.2d 1136 (11th Cir. 1993). However, we decline the invitation. The reasoning in Jones does not apply to Batson objections because the Jones inquiry is intended to provide the district court with an opportunity “to correct on the spot any error it may have made” at a sentencing hearing.
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