United States v. James Hall, Jr.

CourtCourt of Appeals for the Fourth Circuit
DecidedJune 13, 2023
Docket22-4323
StatusUnpublished

This text of United States v. James Hall, Jr. (United States v. James Hall, Jr.) 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. James Hall, Jr., (4th Cir. 2023).

Opinion

USCA4 Appeal: 22-4323 Doc: 26 Filed: 06/13/2023 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-4323

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

JAMES WINFRED HALL, JR., a/k/a Silk,

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of North Carolina, at Raleigh. Terrence W. Boyle, District Judge. (5:19-cr-00489-BO-1)

Submitted: March 10, 2023 Decided: June 13, 2023

Before RICHARDSON, QUATTLEBAUM, and HEYTENS, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Brian Michael Aus, BRIAN AUS, ATTORNEY AT LAW, Durham, North Carolina, for Appellant. Michael F. Easley, Jr., United States Attorney, Kristine L. Fritz, Assistant United States Attorney, Lucy P. Brown, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 22-4323 Doc: 26 Filed: 06/13/2023 Pg: 2 of 6

PER CURIAM:

James Winfred Hall, Jr., appeals from his convictions and 285-month sentence

entered following the jury’s verdict. Hall was found guilty of two counts of aiding and

abetting interference with commerce by robbery, in violation of 18 U.S.C. §§ 1951 and 2,

as well as two counts of aiding and abetting possession of a firearm and brandishing in

furtherance of a crime of violence, in violation of 18 U.S.C. § 924(c)(l)(A)(ii). On appeal,

Hall challenges the court’s statement regarding the need for a witness and the procedural

reasonableness of his sentence. We affirm.

Hall first asserts that the district court plainly erred by stating, in front of the jury,

that the Government did not need to present the testimony of an expert witness regarding

the location of Hall’s cell phone during the robberies. A law enforcement officer testified

that he had mapped Hall’s cell phone records and determined that the phone was in the area

of one robbery. However, the officer informed the jury that he was not an expert in cell

phone data and read for the jury a disclaimer associated with using the records to identify

customer location, noting varying accuracy. The Government stated that its expert witness

would not be available until a later time, and the district court responded, “You don’t need

him.” Hall contends that the judge’s statement conveyed to the jury that the Government

had established beyond a reasonable doubt that Hall and his cell phone were at the site of

a particular robbery, regardless of the lack of certification of the accuracy of the records.

Because Hall did not object below, he correctly notes that his claim is reviewed for

plain error. United States v. Young, 470 U.S. 1, 15-16 (1985). “Especially when addressing

plain error, a reviewing court cannot properly evaluate a case except by viewing such a

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claim against the entire record.” Id. at 16. Thus, even inappropriate and erroneous remarks

are not plain error unless the remarks “undermine the fundamental fairness of the trial and

contribute to a miscarriage of justice.” Id.

Even assuming that the court’s statement was an improper comment on the

Government’s evidence, we find that Hall cannot show a miscarriage of justice. The

evidence at trial was overwhelming, consisting of testimony by eyewitnesses and

codefendants, which was further corroborated by video and physical evidence. As such, a

statement by the district court that could be viewed as bolstering the cell phone evidence

is unlikely to have had any material effect on the jury’s view of the case. Further, the

remark in question was isolated, and the court gave curative instructions both pre- and

post-trial reminding the jury that any comment made by the court, aside from its

instructions of law, should be disregarded when reaching a verdict. In sum, the court’s

remark, when viewed in the full context of the evidence presented at trial, does not rise to

the level of plain error. See United States v. Roof, 10 F.4th 314, 376 (4th Cir. 2021)

(reviewing unsolicited and prejudicial witness statements for plain error).

Hall next contends that his sentence was procedurally unreasonable because the

district court did not address his arguments for a lower sentence. “A district court is

required to provide an individualized assessment based on the facts before the court, and

to explain adequately the sentence imposed to allow for meaningful appellate review and

to promote the perception of fair sentencing.” United States v. Lewis, 958 F.3d 240, 243

(4th Cir. 2020) (internal quotation marks omitted). In explaining its sentence, the “court

must address or consider all non-frivolous reasons presented for imposing a different

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sentence and explain why it has rejected those arguments.” United States v. Webb, 965 F.3d

262, 270 (4th Cir. July 13, 2020) (brackets and internal quotation marks omitted).

“The adequacy of the sentencing court’s explanation depends on the complexity of

each case and the facts and arguments presented.” United States v. Torres-Reyes, 952 F.3d

147, 151 (4th Cir. 2020) (internal quotation marks omitted). Generally, an “explanation is

sufficient if it, although somewhat briefly, outlines the defendant’s particular history and

characteristics not merely in passing or after the fact, but as part of its analysis of the

statutory factors and in response to defense counsel’s arguments” in mitigation. United

States v. Blue, 877 F.3d 513, 519 (4th Cir. 2017) (brackets and internal quotation marks

omitted). “The court’s explanation should set forth enough to satisfy the appellate court

that it has considered the parties’ arguments and has a reasoned basis for exercising its own

legal decisionmkaing authority.” United States v. Lozano, 962 F.3d 773, 782 (4th Cir.

2020) (brackets and internal quotation marks omitted).

While “it is sometimes possible to discern a sentencing court’s rationale from the

context surrounding its decision,” we “may not guess at the district court’s rationale,

searching the record for statements by the Government or defense counsel or for any other

clues that might explain a sentence.” United States v. Ross, 912 F.3d 740, 745 (4th Cir.

2019) (internal quotation marks omitted). Nor may we “assume that the court has silently

adopted arguments presented by a party.” United States v. Nance, 957 F.3d 204, 214 (4th

Cir. 2020) (internal quotation marks omitted). Where the court fully addresses the

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Related

United States v. Young
470 U.S. 1 (Supreme Court, 1985)
United States v. Boulware
604 F.3d 832 (Fourth Circuit, 2010)
United States v. Benjamin Blue
877 F.3d 513 (Fourth Circuit, 2017)
United States v. Carl Ross
912 F.3d 740 (Fourth Circuit, 2019)
United States v. Apolonio Torres-Reyes
952 F.3d 147 (Fourth Circuit, 2020)
United States v. Larry Nance
957 F.3d 204 (Fourth Circuit, 2020)
United States v. Jamil Lewis
958 F.3d 240 (Fourth Circuit, 2020)
United States v. Jose Macias Lozano
962 F.3d 773 (Fourth Circuit, 2020)
United States v. Lemont Webb
965 F.3d 262 (Fourth Circuit, 2020)
United States v. Dylann Roof
10 F.4th 314 (Fourth Circuit, 2021)

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