was decided in 1984. United States Phelps, 733 '. 2d 1464 (11th Cir. 1984). Case No. 08-80736-CV-MARRA P-01 1935 EFTA00226723 LAW OII.CCS Or GERALD D. LEPOOlat Indeed, a nationwide search of reported prosecutions convictions er a ct reveals that the statute has primarily been limi to cases invo