United States v. Sandy Ledbetter

CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 9, 2019
Docket18-4000
StatusUnpublished

This text of United States v. Sandy Ledbetter (United States v. Sandy Ledbetter) 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. Sandy Ledbetter, (4th Cir. 2019).

Opinion

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 18-4000

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

SANDY DARNELL LEDBETTER, a/k/a B Stacks,

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of North Carolina, at Raleigh. James C. Dever III, District Judge. (5:16-cr-00111-D-8)

Submitted: June 27, 2019 Decided: July 9, 2019

Before KING, AGEE, and THACKER, Circuit Judges.

Affirmed by unpublished per curiam opinion.

Anne M. Hayes, Cary, North Carolina, for Appellant. G. Norman Acker III, First Assistant United States Attorney, Jennifer P. May-Parker, Assistant United States Attorney, Phillip A. Rubin, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. PER CURIAM:

Sandy Darnell Ledbetter appeals the denial of his Fed. R. Crim. P. 29 motion for a

judgment of acquittal and his convictions for conspiracy to distribute and possess with

intent to distribute a quantity of cocaine (Count 1), in violation of 21 U.S.C. §§ 841(a)(1),

(b)(1)(C), 846 (2012), and possession of a firearm in furtherance of a drug trafficking

crime (Count 5), in violation of 18 U.S.C. § 924(c)(1)(A) (2012). On appeal, Ledbetter

challenges the sufficiency of the evidence supporting his firearm conviction. He also

contends that the district court erred by permitting the jury to hear inadmissible hearsay

testimony. Finding no reversible error, we affirm.

“We review de novo a district court’s denial of a Rule 29 motion.” United States

v. Burfoot, 899 F.3d 326, 334 (4th Cir. 2018). “We must sustain a guilty verdict if,

viewing the evidence in the light most favorable to the prosecution, the verdict is

supported by substantial evidence.” Id. “Substantial evidence is that which a reasonable

finder of fact could accept as adequate and sufficient to support a conclusion of a

defendant’s guilt beyond a reasonable doubt.” Id. (internal quotation marks omitted).

“Reversal for insufficient evidence is reserved for the rare case where the prosecution’s

failure is clear.” United States v. Wolf, 860 F.3d 175, 194 (4th Cir. 2017) (internal

quotation marks omitted).

To convict Ledbetter of the § 924(c) charge, the Government was required to

prove that he “(1) used, carried, or possessed a firearm (2) in furtherance of a drug

trafficking crime.” United States v. Howard, 773 F.3d 519, 527 (4th Cir. 2014) (internal

quotation marks omitted). For a jury “to conclude that possession of [a] firearm[] was in

2 furtherance of drug trafficking,” it must find that “there exists a sufficiently close nexus

between the firearm[] and the drugs.” United States v. Moore, 769 F.3d 264, 270 (4th

Cir. 2014) (internal quotation marks omitted). Among the factors relevant to this inquiry

are “the type of drug activity that is being conducted, accessibility of the firearm, the type

of weapon, . . . the status of the possession (legitimate or illegal), whether the gun is

loaded, proximity to drugs or drug profits, and the time and circumstances under which

the gun is found.” Howard, 773 F.3d at 527 (internal quotation marks omitted).

At trial, the Government proceeded on the theory that Ledbetter served as muscle

for a drug trafficking organization (“DTO”) run by his coconspirator, Maurio Mitchell.

To that effect, the Government elicited testimony from another coconspirator, DeMarcus

Medley, who claimed that Mitchell bragged that Ledbetter was one of his shooters. In

addition, the Government presented ample evidence indicating that, at the time of his

arrest, Ledbetter unlawfully possessed a loaded firearm that police recovered from a

residence containing several items associated with illicit drug trafficking. In view of this

substantial evidence, we conclude that the district court properly denied Ledbetter’s Rule

29 motion.

Turning to the district court’s evidentiary rulings, which we review for abuse of

discretion, Burfoot, 899 F.3d at 340, we agree with Ledbetter’s assertion that, over his

objections, the court impermissibly allowed hearsay testimony from two Government

witnesses—Jahid Diggs and Kentrail Carlton. Specifically, Diggs related an out-of-court

statement from one of Ledbetter’s coconspirators, who told Diggs that Ledbetter had

been dealing cocaine, and Carlton offered testimony, concededly not based on his

3 personal knowledge, that Ledbetter carried a firearm to protect Mitchell during drug

deals. Nevertheless, reversal is unnecessary because the district court’s evidentiary errors

are harmless. Id.

An error is harmless if we can say with fair assurance, after pondering all that happened without stripping the erroneous action from the whole, that the judgment was not substantially swayed by the error. Put another way, an error is harmless if it’s highly probable that it did not affect the judgment. The decisive factors to consider are the closeness of the case, the centrality of the issue affected by the error, and the steps taken to mitigate the effects of the error.

Id. at 340-41 (citations, brackets, and internal quotation marks omitted). Although the

district court neglected to cure these evidentiary errors, which went to the heart of the

charges, the abundant incriminating evidence adduced by the Government leads us to

conclude that the hearsay testimony did not substantially sway the jury’s decision.

As to the drug conspiracy charge, Diggs recounted a conversation with Ledbetter

that occurred while the two men were incarcerated together. According to Diggs,

Ledbetter asserted that he would never betray Mitchell, who gave Ledbetter his first brick

of cocaine. These jailhouse admissions from Ledbetter were far more harmful to his

defense than Diggs’ hearsay testimony. See United States v. Abdallah, 911 F.3d 201, 216

(4th Cir. 2018) (“[A] defendant’s own confession is probably the most probative and

damaging evidence that can be admitted against him.” (internal quotation marks

omitted)).

Moreover, Carlton also directly implicated Ledbetter in the conspiracy, testifying

that Ledbetter sold cocaine and cocaine base as part of Mitchell’s DTO. Carlton also

stated that he saw Ledbetter with Mitchell on five or six different occasions at an

4 apartment where drugs were cooked and sold. Next, a police officer testified about an

intercepted phone conversation in which Mitchell asked Ledbetter to switch from an

audio call to a video call. The officer explained that Mitchell often used video calls,

which wiretaps cannot intercept, to discuss criminal matters with his coconspirators.

Finally, the Government played for the jury two music videos in which Ledbetter

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

Related

United States v. David Runyon
707 F.3d 475 (Fourth Circuit, 2013)
United States v. Corey A. Moore
769 F.3d 264 (Fourth Circuit, 2014)
United States v. Dennis Howard
773 F.3d 519 (Fourth Circuit, 2014)
United States v. Nathan Wolf
860 F.3d 175 (Fourth Circuit, 2017)
United States v. Larry Recio
884 F.3d 230 (Fourth Circuit, 2018)
United States v. Anthony Burfoot
899 F.3d 326 (Fourth Circuit, 2018)
United States v. Nader Abdallah
911 F.3d 201 (Fourth Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Sandy Ledbetter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-sandy-ledbetter-ca4-2019.