United States v. Lance Hardiman

CourtCourt of Appeals for the Fourth Circuit
DecidedSeptember 7, 2022
Docket19-4407
StatusUnpublished

This text of United States v. Lance Hardiman (United States v. Lance Hardiman) 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. Lance Hardiman, (4th Cir. 2022).

Opinion

USCA4 Appeal: 19-4407 Doc: 57 Filed: 09/07/2022 Pg: 1 of 8

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 19-4407

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

LANCE HARDIMAN,

Defendant - Appellant.

Appeal from the United States District Court for the District of South Carolina, at Florence. R. Bryan Harwell, Chief District Judge. (4:17-cr-00469-RBH-1)

Submitted: August 18, 2022 Decided: September 7, 2022

Before GREGORY, Chief Judge, and THACKER and RUSHING, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Elizabeth A. Franklin-Best, ELIZABETH FRANKLIN-BEST, P.C., Columbia, South Carolina, for Appellant. Corey F. Ellis, United States Attorney, Derek A. Shoemake, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Florence, South Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 19-4407 Doc: 57 Filed: 09/07/2022 Pg: 2 of 8

PER CURIAM:

Lance Hardiman appeals his jury conviction and 480-month prison sentence for

armed bank robbery, in violation of 18 U.S.C. §§ 2, 2113(a), (d) (count 1), discharging a

firearm during and in relation to the crime of violence of armed bank robbery charged in

count 1, in violation of 18 U.S.C. §§ 2, 924(c)(1)(A)(iii) (count 2), witness tampering, in

violation of 18 U.S.C. §§ 2, 1512(a)(2)(C) (count 3), discharging a firearm during and in

relation to and in furtherance of the crimes of violence of armed bank robbery charged in

count 1 and witness tampering charged in count 3, in violation of 18 U.S.C. §§ 2,

924(c)(1)(A)(iii) (count 4), and possession of firearms and ammunition by a convicted

felon, in violation of 18 U.S.C. §§ 2, 922(g)(1), 924(a)(2) (count 5). On appeal, Hardiman

contends that he is entitled to relief under Rehaif v. United States, 139 S. Ct. 2191

(2019)-which was decided after he was convicted and sentenced-and challenges his prison

sentence based on his mental health history. We affirm.

Hardiman contends he is entitled to relief under Rehaif and that this court should

vacate his conviction on count 5 because the superseding indictment did not allege, and the

Government did not prove, he was aware on the date of his possession that he was a

convicted felon and therefore not eligible to possess a firearm. Because Hardiman did not

raise these issues in the district court, we review them for plain error. See Greer v. United

States, 141 S. Ct. 2090, 2096 (2021); United States v. Caldwell, 7 F.4th 191, 213 (4th Cir.

2021) (“[P]lain-error review applies to unpreserved Rehaif errors.”). “To succeed in

obtaining plain-error relief, a defendant must show (1) an error, (2) that is plain, (3) and

that affects substantial rights.” Caldwell, 7 F.4th at 211. When a defendant has been

2 USCA4 Appeal: 19-4407 Doc: 57 Filed: 09/07/2022 Pg: 3 of 8

convicted following a jury trial, he must show that without the error, “there is a reasonable

probability that he would have been acquitted.” Greer, 141 S. Ct. at 2097 (internal

quotation marks omitted). “If those three requirements are met, [we] may grant relief if

[we] conclude[] that the error had a serious effect on the fairness, integrity or public

reputation of judicial proceedings.” Id. at 2096-97 (internal quotation marks omitted).

In Rehaif, “the Supreme Court concluded that to obtain a § 922(g) conviction, the

[G]overnment ‘must show that the defendant knew he possessed a firearm [or ammunition]

and also that he knew he had the relevant [felon] status when he possessed [them].”

Caldwell, 7 F.4th at 213 (quoting Rehaif, 139 S. Ct. at 2194). “As the Supreme Court has

noted, ‘[i]n a felon-in-possession case where the defendant was in fact a felon when he

possessed firearms, the defendant faces an uphill climb in trying to satisfy the

substantial-rights prong of the plain-error test based on an argument that he did not know

he was a felon. The reason is simple: If a person is a felon, he ordinarily knows he is a

felon.’” Id. (quoting Greer, 141 S. Ct. at 2097). However, “the mere undisputed fact that

[the defendant] was a felon at the time of the [offense] is not dispositive.” Id.

“[T]here may be cases in which a defendant who is a felon can make an adequate

showing on appeal that he would have presented evidence in the district court that he did

not in fact know he was a felon when he possessed firearms.” Greer, 141 S. Ct. at 2097.

“But if a defendant does not make such an argument or representation on appeal, [this]

court will have no reason to believe that the defendant would have presented such evidence

to a jury, and thus no basis to conclude that there is a ‘reasonable probability’ that the

outcome would have been different absent the Rehaif error.” Id.; see United States v.

3 USCA4 Appeal: 19-4407 Doc: 57 Filed: 09/07/2022 Pg: 4 of 8

Hobbs, 24 F.4th 965, 973 (4th Cir.) (concluding that defendant failed to make required

showing where he testified he was not allowed to possess firearms and had “not proffered

‘a sufficient argument or representation’ that he would have presented a factual basis at

trial for contradicting this evidence that he knew he was a felon” (quoting Greer, 141 S. Ct.

at 2100)), cert. denied, 142 S. Ct. 2825 (2022); Caldwell, 7 F.4th at 213 (concluding that

defendant could not make required showing where he never disputed validity of his felony

convictions and had served sentences longer than a year, “making it virtually impossible

to believe he did not know he had been convicted of crimes punishable by such sentences”).

Although there was plain error in this case under Rehaif, we conclude that Hardiman

has not shown that his substantial rights were affected, i.e., that absent the error, there is a

reasonable probability that he would have been acquitted. Count 5 of the superseding

indictment charged Hardiman with possession by a convicted felon of firearms and

ammunition on or about May 4, 2016, and, at trial, Hardiman stipulated that, on that date,

he had been convicted of a crime punishable by imprisonment for a term exceeding one

year under 18 U.S.C. § 922(g)(1) and thus could not lawfully possess a firearm or

ammunition. Hardiman’s criminal record makes plain that he was convicted of possession

with intent to distribute illegal drugs and threatening a public official or teacher and

sentenced under the South Carolina Youthful Offender Act (YOA) for those convictions

in 2014. On appeal, Hardiman has neither disputed the validity of these convictions nor

suggested they were not felonies. Although Hardiman proffers on appeal his mental illness

and the nature of his YOA sentence as reasons why knowledge of his prohibited status

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Agustin Rivera-Santana
668 F.3d 95 (Fourth Circuit, 2012)
United States v. Lynn
592 F.3d 572 (Fourth Circuit, 2010)
United States v. Erasto Gomez-Jimenez
750 F.3d 370 (Fourth Circuit, 2014)
United States v. William White
810 F.3d 212 (Fourth Circuit, 2016)
Rehaif v. United States
588 U.S. 225 (Supreme Court, 2019)
United States v. John Fowler
948 F.3d 663 (Fourth Circuit, 2020)
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)
Greer v. United States
593 U.S. 503 (Supreme Court, 2021)
United States v. Anthony Caldwell
7 F.4th 191 (Fourth Circuit, 2021)
United States v. Erick Hobbs
24 F.4th 965 (Fourth Circuit, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Lance Hardiman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-lance-hardiman-ca4-2022.