Kissinger St. Fleur v. United States
JusticiabilityDoctri
Did the district court and the Eleventh Circuit deny Mr. St. Fleur a fair trial when it failed to give buyer-seller instructions to the jury?
QUESTION PRESENTED The government charged Kissinger St. Fleur with conspiracy to distribute and possess with intent to distribute cocaine and crack cocaine. Supported by evidence presented at trial, Mr. St. Fleur asked the district court to instruct the jury on buy-sell transactions. He submitted a proposed instruction to the court which set forth an accurate statement of the law. The district court declined to give the instruction and Mr. St. Fleur objected. Mr. St. Fleur was ultimately convicted of conspiracy to distribute and possession with intent to distribute cocaine and crack cocaine. On appeal, the Eleventh Circuit agreed with Mr. St. Fleur that the buy-sell instruction should have been given, finding that it was legally correct and the evidence could have been interpreted as only a buyer-seller relationship. App. 1920. Nonetheless, the Eleventh Circuit said it was bound by precedent and therefore could not “hold that the district court abused its discretion in refusing to give the buyer-seller instruction.” Did the district court and the Eleventh Circuit deny Mr. St. Fleur a fair trial when it failed to give buyer-seller instructions to the jury?