United States v. James Honesty

CourtCourt of Appeals for the D.C. Circuit
DecidedJune 16, 2026
Docket24-3032
StatusPublished

This text of United States v. James Honesty (United States v. James Honesty) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. 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 Honesty, (D.C. Cir. 2026).

Opinion

United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT

Argued February 10, 2026 Decided June 16, 2026

No. 24-3032

UNITED STATES OF AMERICA, APPELLEE

v.

JAMES FITZGERALD HONESTY, APPELLANT

Appeal from the United States District Court for the District of Columbia (No. 1:22-cr-00187-1)

Howard B. Katzoff, appointed by the court, argued the cause and filed the briefs for appellant.

David B. Goodhand, Assistant U.S. Attorney, argued the cause for appellee. With him on the brief were Jeanine Ferris Pirro, U.S. Attorney, and Chrisellen R. Kolb and Nicholas P. Coleman, Assistant U.S. Attorneys.

Before: PILLARD and WALKER, * Circuit Judges, and ROGERS, Senior Circuit Judge.

* Circuit Judge WALKER joins the court’s opinion as to all except for Part II.A.2 of the opinion. 2 Opinion for the Court by Senior Circuit Judge ROGERS.

ROGERS, Senior Circuit Judge: Appellant James Honesty challenges his convictions upon pleading guilty to firearms and drugs offenses on two interrelated grounds. First, he contends that the government breached the Plea Agreement to cap its allocution to a range under the Sentencing Guidelines by implicitly advocating for a sentence above that range. Second, he contends that the district court erred procedurally by relying on erroneous factfinding and failing to explain the basis for imposing a sentence above the Guidelines range. Appellant Br. at 17–18. The court affirms. Upon plain error review, Honesty has failed to show that his claimed breach of the Plea Agreement through implicit advocacy was reasonably likely to have affected his sentence. Further, he fails to show procedural error by the district court.

I.

Honesty and the government entered into a Plea Agreement that he would plead guilty to two counts of a six- count indictment on firearms and drug charges: Count 1, felon in possession of a firearm and ammunition, and Count 4, possession of Phencyclidine (“PCP”) with intent to distribute. 1

1 The superseding indictment charged in separate counts: (1) felon in possession of a firearm and ammunition, 18 U.S.C. § 922(g)(1); (2) possession of a controlled substance (N-Propylbutylone), 21 U.S.C. § 844(a); (3) possession of another controlled substance (N,N- Dimethylpentylone), 21 U.S.C. § 844(a); (4) possession of PCP with intent to distribute, 21 U.S.C. § 841(a)(1) and (b)(1)(C); (5) possession of a firearm in furtherance of a drug trafficking offense, 18 U.S.C. § 924(c)(1)(A); and (6) possession of PCP with intent to distribute within a thousand feet of a school zone, 21 U.S.C. § 860(a). Superseding Indictment at 2–3 (May 11, 2023). The maximum term of imprisonment for Count 1 was fifteen years, 18 U.S.C. 3 Honesty acknowledged that the Statement of Offense “fairly and accurately describes” his offenses, and the Plea Agreement stated that the estimated Sentencing Guidelines range was 92 to 115 months, based on Honesty’s criminal history. Plea Agreement (“PA”) at 2 (Aug. 15, 2023) (attaching Statement of Offense). 2 The government agreed to dismiss the remaining counts and not to prosecute Honesty for other conduct described in the Statement of Offense. The government also agreed “to cap its allocution to the top of the applicable [S]entencing [G]uidelines range, as ultimately determined by the Court.” PA at 2, 5. Both the defense and the government could “describe fully, both orally and in writing, to the sentencing judge, the nature and seriousness of [Honesty’s] misconduct, including any misconduct not described in the charges to which [he] is pleading guilty, to inform the

§§ 922(g)(1), 924(a)(2), and for Count 4, twenty years, 21 U.S.C. § 841(a)(1) and (b)(1)(C). 2 According to the Statement of Offense, police officers were on patrol in the Southeast quadrant of Washington, D.C., on the evening of May 23, 2022, when they received a lookout call for a Black male with a slim build and dreadlocks wearing a white shirt and blue jeans who “reportedly brandished a gun to the 9-1-1 caller’s significant other.” Statement at 3. The officers spotted Honesty, who matched the description. He fled when they approached to speak with him. In the ensuing chase, Honesty took a firearm from his satchel and dropped it in front of the officers as he turned a corner. He continued running and dropped the satchel shortly before the officers caught up to him. The firearm was a nine-millimeter semi-automatic handgun with one round in the chamber and twenty-one rounds in a magazine. The satchel contained three vials of PCP, thirty-two grams of N,N- Dimethylpentylone (Schedule I controlled substance), fifty-eight grams of N-Propylbutylone (Schedule I controlled substance), a small spoon with white powder residue, a large quantity of small Ziploc bags, a scale, and cash. “At the time [Honesty] possessed the [PCP], he intended to distribute it.” Id. at 4. 4 presentence report writer and the Court of any relevant facts, to dispute any factual inaccuracies in the presentence report, and to contest any matters not provided for in this Agreement.” Id. at 5. Further, if the district court considered “any Sentencing Guidelines adjustments, departures, or calculations different from those agreed to and/or estimated in this Agreement” or “a sentence outside the Guidelines range based upon the general sentencing factors listed in 18 U.S.C. § 3553(a),” then each party had “the right to answer any related inquiries from the Court” and to “allocute for a sentence within the Guidelines range, as ultimately determined by the Court, even if the Guidelines range ultimately determined by the Court is different from the Estimated Guidelines Range calculated herein.” Id.

A presentence report prepared by the Probation Office for the district court also identified Honesty’s Guidelines range as 92 to 115 months’ imprisonment and stated the Office had “not identified any factors that would warrant a variance from the applicable [G]uideline range based on the factors outlined in [18 U.S.C.] § 3553(a).” Presentence Report at 23, 28 (D.D.C. Nov. 14, 2023) (“PSR 1”). Honesty, through trial counsel, stated in a sentencing memorandum that his criminal history score had been incorrectly calculated in PSR 1, mistakenly including three points for a 2009 conviction that “times out” under Guidelines § 4A1.2(e) as well as an incorrect “status point,” and that the correct Guidelines sentencing range was 63 to 78 months. Honesty Sent. Mem. at 5 (Jan. 19, 2024). Trial counsel requested a sentence of 72 months’ imprisonment and five years’ supervised release in view of Honesty’s traumatic youth, his need for drug treatment, and his acceptance of responsibility, submitting two expert reports and character letters from family and friends. 5 The government’s sentencing memorandum requested that Honesty be sentenced at the top of the correctly calculated Guidelines range: 96 months’ imprisonment followed by three years of supervised release. Gov’t. Sent. Mem. at 1 (Jan. 19, 2024).

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