United States v. Jamal Knox

CourtCourt of Appeals for the Third Circuit
DecidedNovember 25, 2025
Docket24-1341
StatusUnpublished

This text of United States v. Jamal Knox (United States v. Jamal Knox) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. Jamal Knox, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ________________

No. 24-1341 ________________

UNITED STATES OF AMERICA

v.

JAMAL KNOX, Appellant ________________

Appeal from the United States District Court for the Western District of Pennsylvania (D.C. No. 2:19-cr-00190-009) District Judge: Honorable Marilyn J. Horan ________________

Submitted under Third Circuit L.A.R. 34.1(a) on March 4, 2025

Before: MATEY, FREEMAN and ROTH, Circuit Judges

(Opinion filed: November 25, 2025)

________________

OPINION* ________________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. ROTH, Circuit Judge

Jamal Knox appeals his conviction for conspiracy to distribute fentanyl and the

District Court’s calculation of his sentence. Because both of his challenges fail, we will

affirm.

I. 1

Knox was indicted with twelve other individuals for criminal activities connected

to the drug trafficking organization “Hustlas Don’t Sleep” or “HDS.” Knox was charged

individually with conspiring with his codefendants and unnamed individuals to possess

with intent to distribute heroin and fentanyl. Eleven of his codefendants pleaded guilty,

and Knox was tried separately in late 2022. At trial, the government presented testimony

from a variety of witnesses, including five of Knox’s codefendants, seven law

enforcement witnesses, and confidential informant Anthony Gatto, to establish that Knox

supplied HDS with fentanyl and heroin and had a close relationship with Robert Howell

Jr., the leader of the group. As relevant to this appeal, Gatto testified about his

relationship to HDS, including sampling their product and providing construction work

on HDS houses, how Howell introduced him to Knox, and how Knox supplied HDS with

fentanyl and heroin. In addition, Gatto testified about referring other customers to Knox,

his two controlled purchases from Knox in 2019, and other information about Knox’s

products and distribution practices. The government also presented evidence of Knox’s

1 Because we write for the parties, we recite only those facts necessary to our disposition. 2 sales to non-HDS purchasers, including text messages between Knox and “Dej Cuddy” to

corroborate the quantity, packaging, and pricing of his products.

The jury found Knox guilty of conspiracy to distribute at least 40 grams, but not

more than 400 grams, of fentanyl. The District Court found the amount of fentanyl

attributable to Knox was at least 280 grams, but less than 400 grams, and sentenced Knox

to 293 months in prison.

II. 2

Knox raises two points on appeal: (1) there was a prejudicial variance between the

indictment and the proof at trial, as the government adduced evidence of multiple,

separate conspiracies, rather than the single conspiracy charged in the indictment; and (2)

the District Court erred in calculating the base offense level for his sentence.

As Knox raises his prejudicial variance challenge for the first time on appeal, we

review for plain error. 3 To succeed on this challenge, Knox must demonstrate both that

the evidence at trial proved the existence of multiple conspiracies, rather than the charged

2 The District Court had jurisdiction under 18 U.S.C. § 3231. We have appellate jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C. § 3742. 3 See United States v. Vosburgh, 602 F.3d 512, 531 (3d Cir. 2010). When reviewing for plain error, we will “grant relief only if we conclude that (1) there was an error, (2) the error was ‘clear or obvious,’ and (3) the error ‘affected the appellant’s substantial rights.’ If those three prongs are satisfied, we have ‘the discretion to remedy the error — discretion which ought to be exercised only if the error seriously affect[s] the fairness, integrity, or public reputation of judicial proceedings.’” United States v. Stinson, 734 F.3d 180, 184 (3d Cir. 2013) (cleaned up) (quoting Puckett v. United States, 556 U.S. 129, 135 (2009)). 3 conspiracy, and that one of his substantial rights was prejudiced by the variance. 4 Knox

argues that the government proved three separate conspiracies—between Knox and HDS,

Knox and Gatto, and Knox and Dej Cuddy—rather than the single conspiracy charged in

the Indictment. 5 We do not address whether Knox has demonstrated a variance, because

even if one exists, he has not shown prejudice.

Knox claims that the purported variance caused him prejudice through “spillover

of evidence,” leading the jury to confuse evidence of Knox’s individual dealings with the

conspiracy with HDS. We are concerned with spillover where “incriminating evidence

against co-defendants who were involved in separate conspiracies affected the jury’s

consideration of the evidence against the defendant.” 6 We have no such concerns here.

Viewed in the light most favorable to the government, 7 the “spillover evidence” that

Knox identifies directly implicated his own activities, and that evidence, at the very least,

was relevant to proving a conspiracy with HDS by establishing Knox’s products and

distribution practices. 8 Knox does not advance any other theory of prejudice, nor does he

4 See United States v. Perez, 280 F.3d 318, 345 (3d Cir. 2002). 5 See id. (“A defendant alleging a variance between a single conspiracy charged in an indictment and the proof presented at trial must demonstrate, first, that there was such a variance and, second, that the variance prejudiced one of his substantial rights.” (citation omitted)). 6 United States v. Kemp, 500 F.3d 257, 291 (3d Cir. 2007) (quoting United States v. Trainor, 477 F.3d 24, 36 n.21 (1st Cir. 2007)). 7 See Kemp, 500 F.3d at 287. 8 See Perez, 280 F.3d at 347 (finding that two defendants suffered no prejudice where the purported spillover evidence concerning other coconspirators also “directly implicated both [of those defendants] in the conspiracy”); Kemp, 500 F.3d at 291–92 (finding no prejudice from spillover where evidence concerning an uncharged conspiracy between 4 provide evidence that he was insufficiently informed of the charges against him or that

the variance placed him in danger of a subsequent prosecution. 9 As we will vacate a

conviction “only where the discrepancy between the indictment and the proof at trial

prejudiced the defendant’s substantial rights,” Knox’s variance challenge fails. 10

Knox’s challenge to the District Court’s base offense drug quantity calculations is

barred by the invited error doctrine and waiver. 11 A party may not “complain on appeal

of errors that he himself invited or provoked or caused the court or the opposite party to

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Related

United States v. Vosburgh
602 F.3d 512 (Third Circuit, 2010)
Puckett v. United States
556 U.S. 129 (Supreme Court, 2009)
United States v. Trainor
477 F.3d 24 (First Circuit, 2007)
United States v. William F. Schoenhut, Jr
576 F.2d 1010 (Third Circuit, 1978)
United States v. Dorothea Daraio
445 F.3d 253 (Third Circuit, 2006)
United States v. Robert Stinson, Jr.
734 F.3d 180 (Third Circuit, 2013)
United States v. Kemp
500 F.3d 257 (Third Circuit, 2007)
Sara Lesende v. Arnold Borrero
752 F.3d 324 (Third Circuit, 2014)
United States v. Evans Santos Diaz
951 F.3d 148 (Third Circuit, 2020)
United States v. Scott Allinson
27 F.4th 913 (Third Circuit, 2022)
United States v. Tiesha Henderson
64 F.4th 111 (Third Circuit, 2023)

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United States v. Jamal Knox, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-jamal-knox-ca3-2025.