United States v. Jody Hairston

CourtCourt of Appeals for the Fourth Circuit
DecidedJune 14, 2022
Docket20-4591
StatusUnpublished

This text of United States v. Jody Hairston (United States v. Jody Hairston) 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. Jody Hairston, (4th Cir. 2022).

Opinion

USCA4 Appeal: 20-4591 Doc: 22 Filed: 06/14/2022 Pg: 1 of 5

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 20-4591

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

JODY DELANO HAIRSTON,

Defendant - Appellant.

Appeal from the United States District Court for the Middle District of North Carolina, at Greensboro. Thomas D. Schroeder, Chief District Judge. (1:13-cr-00054-TDS-1)

Submitted: May 31, 2022 Decided: June 14, 2022

Before THACKER, QUATTLEBAUM, and HEYTENS, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Mark A. Jones, BELL, DAVIS & PITT, PA, Winston-Salem, North Carolina, for Appellant. Randall Stuart Galyon, OFFICE OF THE UNITED STATES ATTORNEY, Greensboro, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 20-4591 Doc: 22 Filed: 06/14/2022 Pg: 2 of 5

PER CURIAM:

Jody Delano Hairston appeals the district court’s judgment revoking his supervised

release and sentencing him to 37 months’ imprisonment followed by 23 months’

supervised release. Counsel has filed a brief pursuant to Anders v. California, 386 U.S.

738 (1967), stating that there are no meritorious grounds for appeal but questioning

whether the district court properly admitted a Drug Enforcement Administration (DEA)

lab report without requiring confrontation of the technician who prepared it, whether the

court properly concluded that Hairston committed a Grade A violation, and whether

Hairston’s sentence is procedurally and substantively reasonable. The Government has

declined to file a brief. Although notified of his right to file a pro se supplemental brief,

Hairston has not done so. We affirm.

First, counsel questions whether the district court erred in admitting a DEA lab

report without requiring confrontation of the technician who prepared it. Because Hairston

did not object to the admission of the report, we review his arguments on appeal for plain

error. United States v. Walker, 934 F.3d 375, 377-78 (4th Cir. 2019). To succeed on plain

error review, Hairston must “show that: (1) an error occurred; (2) the error was plain; and

(3) the error affected [his] substantial rights.” United States v. Bennett, 986 F.3d 389, 397

(4th Cir.), cert. denied, 142 S. Ct. 595 (2021). If Hairston makes this showing, we have

discretion to correct the error and should do so “if the error seriously affects the fairness,

integrity, or public reputation of judicial proceedings.” Rosales-Mireles v. United States,

138 S. Ct. 1897, 1905 (2018) (internal quotation marks omitted).

2 USCA4 Appeal: 20-4591 Doc: 22 Filed: 06/14/2022 Pg: 3 of 5

A defendant in a revocation hearing is “entitled to ‘an opportunity to . . . question

any adverse witness unless the court determines that the interest of justice does not require

the witness to appear.’” United States v. Ferguson, 752 F.3d 613, 616 (4th Cir. 2014)

(quoting Fed. R. Crim. P. 32.1(b)(2)(C)). “Rule 32.1(b)(2)(C) specifically requires that,

prior to admitting hearsay evidence in a revocation hearing, the district court must balance

the releasee’s interest in confronting an adverse witness against any proffered good cause

for denying such confrontation.” United States v. Doswell, 670 F.3d 526, 530 (4th Cir.

2012); see Ferguson, 752 F.3d at 616-17 (discussing Doswell). While reliability is no

longer the test for admissibility, Doswell, 670 F.3d at 530, it remains “a critical factor in

the balancing test under Rule 32.1,” id. at 531. “If hearsay evidence is reliable and the

[g]overnment has offered a satisfactory explanation for not producing the adverse witness,

the hearsay evidence will likely be admissible under Rule 32.1.” Id. We have thoroughly

reviewed the record and conclude that the district court did not plainly err in admitting the

DEA lab report.

Next, Hairston’s counsel questions whether the district court properly concluded

that Hairston committed a Grade A violation of supervised release. We review the district

court’s revocation of supervised release for abuse of discretion and its factual

determinations underlying the conclusion that a violation occurred for clear error. United

States v. Dennison, 925 F.3d 185, 190 (4th Cir. 2019). A district court need only find a

supervised release violation by a preponderance of the evidence. 18 U.S.C. § 3583(e)(3)

(cited in Dennison, 925 F.3d at 191). Based on our review of the record, we conclude that

there was ample evidence adduced at the revocation hearing from which the district court

3 USCA4 Appeal: 20-4591 Doc: 22 Filed: 06/14/2022 Pg: 4 of 5

could conclude that Hairston committed new criminal conduct by trafficking

methamphetamine.

Finally, Hairston’s counsel questions whether Hairston’s sentence is procedurally

and substantively reasonable. “We will affirm a revocation sentence if it is within the

statutory maximum and is not plainly unreasonable.” United States v. Webb, 738 F.3d 638,

640 (4th Cir. 2013) (internal quotation marks omitted). “When reviewing whether a

revocation sentence is plainly unreasonable, we must first determine whether it is

unreasonable at all.” United States v. Thompson, 595 F.3d 544, 546 (4th Cir. 2010). “In

making this determination, we follow generally the procedural and substantive

considerations that we employ in our review of original sentences, with some necessary

modifications to take into account the unique nature of supervised release revocation

sentences.” United States v. Slappy, 872 F.3d 202, 207 (4th Cir. 2017) (cleaned up). Only

if a sentence is either procedurally or substantively unreasonable is a determination then

made as to whether the sentence is plainly unreasonable. United States v. Moulden, 478

F.3d 652, 656-57 (4th Cir. 2007).

“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.” Slappy,

872 F.3d at 207 (footnote omitted); see 18 U.S.C. § 3583(e). A revocation sentence is

substantively reasonable if the court states a proper basis for concluding that the defendant

should receive the sentence imposed, up to the statutory maximum. United States v.

Crudup, 461 F.3d 433

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
United States v. Doswell
670 F.3d 526 (Fourth Circuit, 2012)
United States v. Christopher Devon Crudup
461 F.3d 433 (Fourth Circuit, 2006)
United States v. Damien Troy Moulden
478 F.3d 652 (Fourth Circuit, 2007)
United States v. Thompson
595 F.3d 544 (Fourth Circuit, 2010)
United States v. Austin Webb, Jr.
738 F.3d 638 (Fourth Circuit, 2013)
United States v. Jori Ferguson
752 F.3d 613 (Fourth Circuit, 2014)
United States v. Lacresha Slappy
872 F.3d 202 (Fourth Circuit, 2017)
Rosales-Mireles v. United States
585 U.S. 129 (Supreme Court, 2018)
United States v. Ezekiel Dennison
925 F.3d 185 (Fourth Circuit, 2019)
United States v. Donald Walker
934 F.3d 375 (Fourth Circuit, 2019)
United States v. Dawn Bennett
986 F.3d 389 (Fourth Circuit, 2021)

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