United States v. Anthony Lawrence - Criminal Conviction Appeal
Summary
The Eleventh Circuit Court of Appeals affirmed the conviction of Anthony Ray Lawrence for attempting to entice a minor. The court held that the jury was not required to unanimously agree on the specific underlying state offense supporting the conviction, citing existing precedent.
What changed
The Eleventh Circuit Court of Appeals affirmed the conviction of Anthony Ray Lawrence under 18 U.S.C. § 2422(b) for attempting to entice a minor. Lawrence appealed, arguing that the jury should have been required to specify which state offense supported his conviction. The court denied this argument, citing its own precedent in United States v. Jockisch, which holds that jury unanimity on the specific predicate state offense is not required for a § 2422(b) conviction.
This ruling reinforces existing precedent within the Eleventh Circuit regarding the application of 18 U.S.C. § 2422(b). For regulated entities and legal professionals, this decision means that appeals challenging convictions on the grounds of non-unanimous jury findings regarding predicate offenses under this statute are unlikely to succeed in this circuit. The court's adherence to the prior-panel precedent rule means that such arguments are foreclosed unless overturned by the Supreme Court or an en banc panel.
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March 23, 2026 Get Citation Alerts Download PDF Add Note
United States v. Anthony Lawrence
Court of Appeals for the Eleventh Circuit
- Citations: None known
- Docket Number: 25-10405
- Precedential Status: Non-Precedential
Nature of Suit: NEW
Combined Opinion
USCA11 Case: 25-10405 Document: 25-1 Date Filed: 03/23/2026 Page: 1 of 2
NOT FOR PUBLICATION
In the
United States Court of Appeals
For the Eleventh Circuit
No. 25-10405
Non-Argument Calendar
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
versus
ANTHONY RAY LAWRENCE,
Defendant-Appellant.
Appeal from the United States District Court
for the Northern District of Alabama
D.C. Docket No. 2:23-cr-00439-MHH-NAD-1
Before GRANT, LUCK, and LAGOA, Circuit Judges.
PER CURIAM:
Anthony Ray Lawrence appeals his conviction for
attempting to entice a minor to engage in sexual activity in
violation of 18 U.S.C. § 2422 (b). He argues that the district court
USCA11 Case: 25-10405 Document: 25-1 Date Filed: 03/23/2026 Page: 2 of 2
2 Opinion of the Court 25-10405
should have required the jury to specify in a special-verdict form
which underlying state offense supported his § 2422(b) conviction.
The problem, which Lawrence recognizes, is that our precedent
forecloses that argument. In United States v. Jockisch, we held that
when the government relies on multiple potential state predicate
offenses to convict a defendant under § 2422(b), the jury need not
unanimously agree about which sex offense the defendant’s
intended conduct would have violated. 857 F.3d 1122, 1131 (11th
Cir. 2017). So the district court here did not abuse its discretion
when it failed to require the jury to specify which sex offense
Lawrence would have violated had his attempt ripened into
completed conduct.
Lawrence responds that Jockisch was wrongly decided. But
our prior-panel precedent rule shuts that argument down, too. See
United States v. Archer, 531 F.3d 1347, 1352 (11th Cir. 2008).
Accordingly, Lawrence’s challenge to his conviction fails.
We AFFIRM the district court’s judgment.
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