United States v. Jelani Jones

Opinion

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 26-4012

UNITED STATES OF AMERICA, Plaintiff - Appellee,

v.

JELANI A. JONES, Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of Virginia, at Richmond. John A. Gibney, Jr., Senior District Judge. (3:19-cr-00122-JAG-1)

Submitted: July 30, 2026 Decided: August 19, 2026

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

Affirmed by unpublished per curiam opinion.

ON BRIEF: Geremy C. Kamens, Federal Public Defender, Patrick L. Bryant, Assistant Federal Public Defender, Carolyn V. Grady, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Alexandria, Virginia, for Appellant. Todd W. Blanche, Acting Attorney General, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; Janet Jin Ah Lee, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Alexandria, Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:

Jelani A. Jones appeals the 10-month sentence, followed by 26 months’ supervised release, imposed by the district court following the revocation of his supervised release. Jones contends that the district court did not adequately explain its reasons for imposing his revocation sentence, rendering the sentence plainly unreasonable. We affirm.

“A district court . . . has broad discretion to impose a particular sentence upon revocation of a defendant’s term of supervised release.” United States v. Celedon, 165 F.4th 873, 879 (4th Cir. 2026) (citation modified). We will affirm a revocation sentence “unless it is above the statutory maximum or plainly unreasonable.” Id. Where, as here, the sentence does not exceed the statutory maximum, “we first examine whether the sentence was unreasonable at all.” United States v. Amin, 85 F.4th 727, 739 (4th Cir. 2023) (internal quotation marks omitted). “Only if we find the sentence unreasonable must we decide whether it is plainly so.” Id. (internal quotation marks omitted).

“A revocation sentence is procedurally reasonable if the district court adequately explains the chosen sentence after considering the Sentencing Guidelines’ nonbinding Chapter Seven policy statements and the applicable 18 U.S.C. § 3553(a) factors.” United States v. Coston, 964 F.3d 289, 297 (4th Cir. 2020) (internal quotation marks omitted); see 18 U.S.C. § 3583(e) (listing applicable factors). “Although the court need not be as detailed or specific when imposing a revocation sentence as it must be when imposing a post-conviction sentence, it still must provide a statement of reasons for the sentence imposed.” United States v. Slappy, 872 F.3d 202, 208 (4th Cir. 2017) (citation modified). At a minimum, the district court must explain the sentence sufficiently to permit

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meaningful appellate review with the “assurance that [it] considered the applicable sentencing factors with regard to the particular defendant before it.” United States v. Gibbs, 897 F.3d 199, 204 (4th Cir. 2018) (citation modified).

We have reviewed the record and conclude that the district court adequately explained its imposition of the sentence, including the additional term of supervised release. Although Jones faults the district court for allegedly failing to conduct an individualized assessment of his case, he identifies no nonfrivolous arguments for a lower sentence that the court failed to address. Indeed, the court actively engaged with the parties throughout the revocation hearing, and it directly addressed each of Jones’s arguments for a lower sentence, including his drug addiction and mental health struggles. The court also outlined the relevant § 3553(a) factors and discussed how each one had, or had not, factored into its decision. The court also clearly expressed its belief that Jones’s behavior warranted additional guidance, in the form of supervised release, at the end of his custodial sentence. We discern no procedural error in the imposition of Jones’s revocation sentence. Accordingly, we conclude that Jones’s sentence is not unreasonable, let alone plainly so.

We therefore affirm the district court’s revocation judgment. 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