United States v. Everett Nelson

CourtCourt of Appeals for the Fourth Circuit
DecidedMay 26, 2026
Docket25-4516
StatusUnpublished

This text of United States v. Everett Nelson (United States v. Everett Nelson) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Everett Nelson, (4th Cir. 2026).

Opinion

USCA4 Appeal: 25-4516 Doc: 27 Filed: 05/26/2026 Pg: 1 of 5

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-4516

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

EVERETT CHAD NELSON,

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of Virginia, at Alexandria. Leonie M. Brinkema, District Judge. (1:24-cr-00251-LMB-1)

Submitted: April 24, 2026 Decided: May 26, 2026

Before WILKINSON and NIEMEYER, Circuit Judges, and TRAXLER, Senior Circuit Judge.

Affirmed in part, vacated in part, and remanded by unpublished per curiam opinion.

ON BRIEF: Geremy C. Kamens, Federal Public Defender, Patrick L. Bryant, Assistant Federal Public Defender, Cadence A. Mertz, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Alexandria, Virginia, for Appellant. Todd W. Blanche, Deputy Attorney General, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; James Reed Sawyers, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Alexandria, Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-4516 Doc: 27 Filed: 05/26/2026 Pg: 2 of 5

PER CURIAM:

Everett Chad Nelson appeals his convictions and the 30-month sentence imposed

following a jury trial for assault resulting in serious bodily injury, in violation of 18 U.S.C.

§ 113(a)(6); 49 U.S.C. § 46506(1) (Count 1), and assault by striking, beating, or wounding,

in violation of 18 U.S.C. § 113(a)(4); 49 U.S.C. § 46506(1) (Count 2). On appeal, Nelson

argues that his conviction on Count 1 is not supported by sufficient evidence and that the

district court procedurally erred in imposing two special conditions of supervised release.

We review de novo the denial of a motion for judgment of acquittal. United States

v. Zelaya, 908 F.3d 920, 925 (4th Cir. 2018). We will uphold the jury’s verdict if, viewing

the evidence in the light most favorable to the Government, substantial evidence supports

the verdict. United States v. Burfoot, 899 F.3d 326, 334 (4th Cir. 2018). In reviewing the

evidence, we ask whether “any rational trier of fact could have found the essential elements

of the crime beyond a reasonable doubt.” United States v. Robinson, 855 F.3d 265, 268

(4th Cir. 2017) (emphasis and internal quotation marks omitted). During this inquiry, we

may not “assess witness credibility,” and we must “assume that the jury resolved any

conflicting evidence in the prosecution’s favor.” United States v. Savage, 885 F.3d 212,

219 (4th Cir. 2018) (internal quotation marks omitted). “A defendant bringing a

sufficiency challenge therefore bears a heavy burden, and reversal is warranted only where

the prosecution’s failure is clear.” United States v. Wysinger, 64 F.4th 207, 211 (4th Cir.

2023) (internal quotation marks omitted).

To establish a violation of § 113(a)(6), the Government must prove (1) “that the

defendant assaulted another person by intentionally striking him; [(2)] that, as a result, the

2 USCA4 Appeal: 25-4516 Doc: 27 Filed: 05/26/2026 Pg: 3 of 5

other person suffered serious bodily injury; and [(3)] that the assault took place within the

special maritime and territorial jurisdiction of the United States.” United States v. Davis,

726 F.3d 357, 360 (2d Cir. 2013). “Serious bodily injury” is bodily injury involving “(A) a

substantial risk of death; (B) extreme physical pain; (C) protracted and obvious

disfigurement; or (D) protracted loss or impairment of the function of a bodily member,

organ, or mental faculty.” 18 U.S.C. § 1365(h)(3); see 18 U.S.C. § 113(b)(2)

(incorporating definition from § 1365).

At trial, the victim testified that Nelson punching him was “excruciatingly painful”

and felt “almost like [being hit] with a brick.” (J.A. 104). 1 He rated his pain during the

assault as “[10] or more” out of 10. (J.A. 105). He suffered a broken nose and experienced

symptoms consistent with a concussion, including nausea, spots in his vision, and loss of

consciousness. And another passenger testified that the assault led the victim to emit “a

very loud piercing blood-curdling scream.” (J.A. 69; see also J.A. 64 (describing victim’s

“ear-shattering screams”)). On these facts, a rational trier of fact could have found beyond

a reasonable doubt that the victim suffered extreme physical pain because of the assault.

We therefore affirm Nelson’s conviction on Count 1.

Regarding the conditions of Nelson’s supervised release, the parties agree that the

district court did not adequately explain the challenged conditions. A “confession of error

by the government respecting a criminal conviction” does not “relieve this court of the

performance of the judicial function to examine independently the errors confessed.”

1 Citations to “J.A.” refer to the joint appendix filed in this appeal.

3 USCA4 Appeal: 25-4516 Doc: 27 Filed: 05/26/2026 Pg: 4 of 5

United States v. Brainer, 691 F.2d 691, 693 (4th Cir. 1982) (citation modified).

Accordingly, even when the Government “concedes the correctness of [the] defendant’s

view of the law” on appeal, we must still carry out that duty. Id.; see also United States v.

Pena, 952 F.3d 503, 512 (4th Cir. 2020) (recognizing that “we are not bound by the

government’s concession of error”).

Because Nelson objected to the conditions that he challenges on appeal, our review

is for abuse of discretion. See United States v. Boyd, 5 F.4th 550, 554 (4th Cir. 2021). “[A]

sentencing court’s duty to provide an explanation for the sentence imposed also requires

that the court explain any special conditions of supervised release.” United States v.

McMiller, 954 F.3d 670, 676 (4th Cir. 2020). Specifically, “when a defendant presents

non-frivolous reasons for imposing a different sentence, the district court must address or

consider them and explain why it has rejected them.” Boyd, 5 F.4th at 557 (citation

modified). “A district court that fails to provide an explanation for the sentence imposed

commits reversible procedural error.” United States v.

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Related

United States v. Corey Davis
726 F.3d 357 (Second Circuit, 2013)
United States v. Cornell Robinson
855 F.3d 265 (Fourth Circuit, 2017)
United States v. Junaidu Savage
885 F.3d 212 (Fourth Circuit, 2018)
United States v. Anthony Burfoot
899 F.3d 326 (Fourth Circuit, 2018)
United States v. Miguel Zelaya
908 F.3d 920 (Fourth Circuit, 2018)
United States v. Roberto Moreno Pena
952 F.3d 503 (Fourth Circuit, 2020)
United States v. Benjamin McMiller
954 F.3d 670 (Fourth Circuit, 2020)
United States v. Alan Williams
5 F.4th 500 (Fourth Circuit, 2021)
United States v. Santario Boyd
5 F.4th 550 (Fourth Circuit, 2021)
United States v. Kendall Wysinger
64 F.4th 207 (Fourth Circuit, 2023)

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