United States v. Melvin Maxwell

CourtCourt of Appeals for the Fourth Circuit
DecidedJune 9, 2026
Docket24-4640
StatusUnpublished

This text of United States v. Melvin Maxwell (United States v. Melvin Maxwell) 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. Melvin Maxwell, (4th Cir. 2026).

Opinion

USCA4 Appeal: 24-4640 Doc: 37 Filed: 06/09/2026 Pg: 1 of 8

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-4640

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

MELVIN ANTONIO EUGENE MAXWELL,

Defendant - Appellant.

Appeal from the United States District Court for the District of South Carolina, at Spartanburg. Henry M. Herlong, Jr., Senior District Judge. (7:24-cr-00281-HMH-1)

Submitted: April 13, 2026 Decided: June 9, 2026

Before AGEE and WYNN, Circuit Judges, and FLOYD, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Kimberly H. Albro, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Columbia, South Carolina, for Appellant. Matthew R. Galeotti, Thomas E. Booth, Appellate Section, Criminal Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; Bryan P. Stirling, United States Attorney, Charleston, South Carolina, Kathleen Stoughton, Assistant United States Attorney, Columbia, South Carolina, Maxwell B. Cauthen, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Greenville, South Carolina, for Appellee. USCA4 Appeal: 24-4640 Doc: 37 Filed: 06/09/2026 Pg: 2 of 8

Unpublished opinions are not binding precedent in this circuit.

2 USCA4 Appeal: 24-4640 Doc: 37 Filed: 06/09/2026 Pg: 3 of 8

PER CURIAM:

In November 2023, Officer Brandon Dorsett of the Cherokee County Sheriff’s

Office in South Carolina noticed a Nissan in the left-most lane (the passing lane) driving

slowly enough that vehicles were needing to pass it on its right. He followed the Nissan in

the passing lane for “about a half a mile” before turning on his blue lights to pull the Nissan

over. J.A. 33. 1

Upon approach of the vehicle, Dorsett smelled “an overwhelming odor of

marijuana” and called for backup. J.A. 34. Dorsett told the driver, Melvin Maxwell, that

he had been driving too slowly in the passing lane, in violation of South Carolina law. After

running Maxwell’s license, Dorsett returned to the Nissan and asked Maxwell about the

smell of the marijuana emanating from the vehicle. Maxwell denied having any marijuana.

Dorsett then reached into the vehicle and unlocked the passenger door, at which point

Maxwell hit the accelerator and sped off. Dorsett pursued Maxwell by car, but Maxwell

eventually crashed his vehicle and took off on foot. With the assistance of other officers,

Dorsett detained Maxwell.

With Maxwell detained, Dorsett and other officers proceeded to search Maxwell’s

vehicle. Dorsett began his search in the trunk of the car, where he found a firearm,

marijuana, and cocaine.

Maxwell was charged by grand jury with possession of a firearm as a felon, in

violation of 18 U.S.C. § 922(g)(1), and possession of cocaine and crack cocaine, in

1 Citations to the “J.A.” refer to the Joint Appendix filed by the parties in this appeal. 3 USCA4 Appeal: 24-4640 Doc: 37 Filed: 06/09/2026 Pg: 4 of 8

violation of 21 U.S.C. § 844(a). Maxwell filed a motion to suppress the evidence obtained

from the search of his vehicle, arguing both that the initial stop was impermissible and that

police lacked probable cause to search the trunk of his car.

After a suppression hearing, in which the Government played Dorsett’s body-worn-

camera footage from the incident and Dorsett testified in person, the district court denied

the motion to suppress. Noting that “this is a credibility issue,” it found that Maxwell “was

committing a traffic violation by going slower than the traveling vehicles in the right lane,”

and therefore “it was proper for [Dorsett] to stop the defendant’s vehicle because of a traffic

violation.” J.A. 56.

Maxwell then entered a conditional plea, reserving the right to appeal the denial of

the motion to suppress.

In June 2024, the district court held a combined hearing for sentencing and

revocation of Maxwell’s supervised release for a prior crime. The court calculated a

Guidelines range of 87 to 108 months for the firearm- and drug-possession charges.

Maxwell asked that the court not impose a term of supervised release as part of either

sentence. He specifically feared that while on supervised release some probation officers

might not let him travel with his children, noting “it depends who you get.” J.A. 104.

After considering “the statutory factors applicable to revocation under 3553(a) and

3583(e),” the district court sentenced Maxwell to 18 months’ imprisonment for violating

the terms of his supervised release. J.A. 104. And after considering “the relevant statutory

sentencing factors contained in 18 U.S.C. § 3553(a),” it sentenced him to a term of 87

4 USCA4 Appeal: 24-4640 Doc: 37 Filed: 06/09/2026 Pg: 5 of 8

months for the firearm-possession charge and 12 months for the narcotics charges. 2

J.A. 105. The district court also imposed a total of three years of supervised release

following Maxwell’s release from prison.

Maxwell timely appealed, arguing that the district court erred in denying his motion

to suppress and that the sentence was procedurally unreasonable. We affirm.

“In reviewing the denial of a motion to suppress, we review legal conclusions de

novo and factual findings for clear error. In doing so, we consider the evidence in the light

most favorable to the Government.” United States v. Pulley, 987 F.3d 370, 376 (4th Cir.

2021) (cleaned up).

Here, Dorsett’s in-person testimony and body-worn-camera footage support the

district court’s factual finding that Maxwell committed a left-lane violation under South

Carolina law. See United States v. Palmer, 820 F.3d 640, 653 (4th Cir. 2016) (noting that

“we particularly defer to [the] district court’s credibility determinations, for it is the role of

the district court to observe witnesses and weigh their credibility during a pre-trial motion

to suppress” (cleaned up)); S.C. Code § 56-5-1885(A) (2021) (providing that, unless an

exception applies, a “vehicle may not be driven in the farthest left-hand lane of a controlled

access highway except when overtaking and passing another vehicle”). And “[o]bserving

a traffic violation provides sufficient justification for a police officer to detain the offending

vehicle for as long as it takes to perform the traditional incidents of a routine traffic stop.”

United States v. Branch, 537 F.3d 328, 335 (4th Cir. 2008).

2 The district court specified that all three sentences were to be served concurrently. 5 USCA4 Appeal: 24-4640 Doc: 37 Filed: 06/09/2026 Pg: 6 of 8

As to the search of the trunk, it is uncontested that Officer Dorsett smelled marijuana

upon approach of Maxwell’s car, and “the odor of marijuana alone can satisfy the probable

cause requirement to search a vehicle or baggage.” United States v. Scheetz, 293 F.3d 175,

184 (4th Cir. 2002) (quotation omitted).

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Related

Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. Branch
537 F.3d 328 (Fourth Circuit, 2008)
United States v. Scheetz
293 F.3d 175 (Fourth Circuit, 2002)
United States v. Michael Palmer
820 F.3d 640 (Fourth Circuit, 2016)
United States v. Craig Pulley
987 F.3d 370 (Fourth Circuit, 2021)
United States v. Philip Friend
2 F.4th 369 (Fourth Circuit, 2021)
United States v. Patterson
25 F.4th 123 (Second Circuit, 2022)
United States v. Tarik Freitekh
114 F.4th 292 (Fourth Circuit, 2024)

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