United States v. Jarrett Lawson

• Court: Court of Appeals for the Fourth Circuit
• Decided: April 10, 2025
• Docket: 24-4259
• Status: Unpublished

Opinion

USCA4 Appeal: 24-4259 Doc: 26 Filed: 04/10/2025 Pg: 1 of 4

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-4259

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

JARRETT OMAR LAWSON,

Defendant - Appellant.

Appeal from the United States District Court for the District of South Carolina, at Columbia. Sherri A. Lydon, District Judge. (3:23-cr-00224-SAL-1)

Submitted: February 27, 2025 Decided: April 10, 2025

Before HARRIS and RICHARDSON, Circuit Judges, and FLOYD, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Jeremy A. Thompson, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Columbia, South Carolina, for Appellant. Elle E. Klein, Assistant United States Attorney, Kathleen Michelle Stoughton, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Columbia, South Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-4259 Doc: 26 Filed: 04/10/2025 Pg: 2 of 4

PER CURIAM:

Jarrett Omar Lawson pleaded guilty, without a plea agreement, to possession with

intent to distribute and distribution of five grams or more of methamphetamine and

possession with intent to distribute and distribution of 50 grams or more of

methamphetamine and 40 grams or more of fentanyl, in violation of 21 U.S.C.

§§ 841(a)(1), (b)(1)(A), (b)(1)(B). The district court sentenced Lawson to a downward-

variant sentence of 220 months’ imprisonment. On appeal, counsel has filed a brief

pursuant to Anders v. California, 386 U.S. 738 (1967), finding no meritorious grounds for

appeal, but questioning whether Lawson’s sentence is substantively unreasonable.

Although advised of his right to do so, Lawson has not filed a supplemental pro se brief.

The Government declined to file a response brief.

We review a defendant’s sentence “under a deferential abuse-of-discretion

standard.” Gall v. United States, 552 U.S. 38, 41 (2007). Under this standard, we review

the sentence for both procedural and substantive reasonableness. Id. at 51. In determining

procedural reasonableness, this Court considers whether the district court properly

calculated the defendant’s advisory Sentencing Guidelines range, gave the parties an

opportunity to argue for an appropriate sentence, considered the 18 U.S.C. § 3553(a)

factors, and sufficiently explained the selected sentence. Id. at 49-51. If a sentence is free

from “significant procedural error,” then we review it for substantive reasonableness,

“tak[ing] into account the totality of the circumstances.” Id. at 51. “Any sentence that is

within or below a properly calculated Guidelines range is presumptively reasonable.”

United States v. Louthian, 756 F.3d 295, 306 (4th Cir. 2014). “Such a presumption can

2 USCA4 Appeal: 24-4259 Doc: 26 Filed: 04/10/2025 Pg: 3 of 4

only be rebutted by showing that the sentence is unreasonable when measured against the

18 U.S.C. § 3553(a) factors.” Id.

We conclude that Lawson’s sentence is both procedurally and substantively

reasonable. Lawson argues that his sentence is substantively unreasonable because the

district court should have rejected on policy grounds the application of the Sentencing

Guidelines’ career offender provisions and “arbitrary” treatment of “ice”

methamphetamine. However, “[a]lthough a sentencing court may be entitled to consider

policy decisions underlying the Guidelines, including the presence or absence of empirical

data[,] it is under no obligation to do so.” See United States v. Williams, 19 F.4th 374, 378

(4th Cir. 2021) (cleaned up). Here, the district court heard and rejected Lawson’s

arguments that his career offender status overstated his criminal history and that the

Guidelines’ treatment of “ice” methamphetamine was unjust, finding that these arguments,

even if mitigating, were outweighed by the court’s balancing of the § 3553(a) factors. We

discern no abuse of discretion in the district court’s decision not to reject the application of

the Guidelines on policy grounds.

In accordance with Anders, we have reviewed the entire record in this case and have

found no meritorious grounds for appeal. We therefore affirm the district court’s judgment.

This court requires that counsel inform Lawson, in writing, of the right to petition the

Supreme Court of the United States for further review. If Lawson requests that a petition

be filed, but counsel believes that such a petition would be frivolous, then counsel may

move in this court for leave to withdraw from representation. Counsel’s motion must state

that a copy thereof was served on Lawson.

3 USCA4 Appeal: 24-4259 Doc: 26 Filed: 04/10/2025 Pg: 4 of 4

We dispense with oral argument because the facts and legal contentions are

adequately presented in the materials before this court and argument would not aid the

decisional process.

AFFIRMED