United States v. Tomonta Simmons

CourtCourt of Appeals for the Fourth Circuit
DecidedMarch 16, 2026
Docket24-4627
StatusUnpublished

This text of United States v. Tomonta Simmons (United States v. Tomonta Simmons) 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. Tomonta Simmons, (4th Cir. 2026).

Opinion

USCA4 Appeal: 24-4627 Doc: 27 Filed: 03/16/2026 Pg: 1 of 7

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-4627

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

TOMONTA SIMMONS,

Defendant - Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Charlotte. Max O. Cogburn, Jr., District Judge. (3:23-cr-00064-MOC-SCR-1)

Submitted: March 10, 2026 Decided: March 16, 2026

Before KING and WYNN, Circuit Judges, and KEENAN, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

ON BRIEF: James W. Kilbourne, Jr., ALLEN STAHL + KILBOURNE, Asheville, North Carolina, for Appellant. Amy Elizabeth Ray, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Asheville, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-4627 Doc: 27 Filed: 03/16/2026 Pg: 2 of 7

PER CURIAM:

Tomonta Simmons appeals his conviction and sentence after pleading guilty to

possession of one or more firearms in violation of 18 U.S.C. § 922(g)(1). On appeal,

Simmons’s attorney has filed a brief under Anders v. California, 386 U.S. 738, 744 (1967),

concluding there are no meritorious grounds for appeal but raising the issues of whether

Simmons’s statement at sentencing that the firearms were for self-protection resulted in an

unconstitutional application of § 922(g)(1) in violation of his Second Amendment rights

and whether his sentence was procedurally or substantively unreasonable. Simmons was

notified of his right to file a pro se supplemental brief but has not done so. We affirm.

We first consider Simmons’s challenge to his conviction based on the Second

Amendment. “[T]o be constitutionally valid, a plea of guilty must be knowingly and

voluntarily made.” United States v. Paylor, 88 F.4th 553, 560 (4th Cir. 2023) (citation

modified). Rule 11 of the Federal Rules of Criminal Procedure “outlines the requirements

for a district court plea colloquy, designed to ensure that a defendant ‘understands the law

of his crime in relation to the facts of his case, as well as his rights as a criminal defendant.’”

United States v. Kemp, 88 F.4th 539, 545 (4th Cir. 2023) (quoting United States v. Vonn,

535 U.S. 55, 62 (2002)). “The district court must also ‘determine that the plea is voluntary

and that there is a factual basis for the plea.’” United States v. Taylor-Saunders, 88 F.4th

516, 522 (4th Cir. 2023). When a defendant contests the validity of a guilty plea that he

did not challenge or seek to withdraw in the district court, we review the challenge only

for plain error. United States v. King, 91 F.4th 756, 760 (4th Cir. 2024).

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Plain error can be reviewed where the defendant establishes: (1) there is error; (2)

the error is plain; and (3) the error affects his substantial rights. Id. “To satisfy this third

condition, the defendant must show a reasonable probability that, but for the error, the

outcome of the proceeding would have been different.” United States v. Perdue, 110 F.4th

662, 668 (4th Cir. 2024) (citation modified). Even if the defendant satisfies this three-

prong test, we will exercise our discretion to remedy the error “only if it ‘seriously affects

the fairness, integrity or public reputation of judicial proceedings.’” King, 91 F.4th at 760

(quoting United States v. Olano, 507 U.S. 725, 732 (1993)). “The defendant bears the

burden of satisfying each element of the plain error standard.” Id.

“When properly preserved, this Court generally reviews constitutional claims de

novo.” United States v. Hunt, 123 F.4th 697, 701 (4th Cir. 2024), cert. denied, 145 S. Ct.

2756 (2025). “But matters change when a defendant fails to timely raise an issue before

the district court.” Id. “In that situation, reviewing courts typically apply the more

government-friendly plain-error doctrine.” Id. Here, Simmons did not move to withdraw

his guilty plea in the district court, but he presented a pro se letter concerning the Second

Amendment at the end of his sentencing hearing. Even assuming the issue was properly

preserved, we conclude that it is foreclosed by our decision in Hunt. See id. at 702 (holding

that neither New York State Rifle & Pistol Assoc. v. Bruen, 597 U.S. 1 (2002), nor United

States v. Rahimi, 602 U.S. 680 (2024), abrogated our precedent “foreclosing as-applied

challenges to Section 922(g)(1) and those decisions thus remain binding”). Moreover, the

magistrate judge and district court substantially complied with Rule 11 when accepting

Simmons’s guilty plea; and he has not shown any plain error affecting his substantial rights.

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In Simmons’s remaining three issues, he challenges the procedural and substantive

reasonableness of his sentence. “We ‘review all sentences—whether inside, just outside,

or significantly outside the Guidelines range—under a deferential abuse-of-discretion

standard.’” United States v. Smith, 134 F.4th 248, 256 (4th Cir. 2025) (quoting Gall v.

United States, 552 U.S. 38, 41 (2007)). “In reviewing whether a sentence is reasonable,

we ensure that the district court committed no significant procedural error, such as failing

to calculate (or improperly calculating) the Guidelines range, treating the Guidelines as

mandatory, failing to consider the [18 U.S.C.] § 3553(a) factors, selecting a sentence based

on clearly erroneous facts, or failing to adequately explain the chosen sentence.” Id.

(citation modified). “The [sentencing] court’s explanation must satisfy us that it ‘has

considered the parties’ arguments and has a reasoned basis for exercising its own legal

decision-making authority in light of § 3553(a).’” Id. at 264.

“A sentence is substantively unreasonable only where under the totality of the

circumstances, the sentencing court abused its discretion in concluding that the sentence it

chose satisfied the standards set forth in § 3553(a).” United States v. Devine, 40 F.4th 139,

153 (4th Cir. 2022) (citation modified). “‘[A]ny sentence that is within or below a properly

calculated Guidelines range is presumptively reasonable.’” Id. “‘[A] defendant can only

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
United States v. Olano
507 U.S. 725 (Supreme Court, 1993)
United States v. Vonn
535 U.S. 55 (Supreme Court, 2002)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
United States v. James O. Bakker
925 F.2d 728 (Fourth Circuit, 1991)
Josiah Deyton v. Alvin Keller, Jr.
682 F.3d 340 (Fourth Circuit, 2012)
United States v. Mikkel McKinnie
21 F.4th 283 (Fourth Circuit, 2021)
United States v. Lee Elbaz
52 F.4th 593 (Fourth Circuit, 2022)
United States v. Glenda Taylor-Sanders
88 F.4th 516 (Fourth Circuit, 2023)
United States v. Daniel Kemp, Sr.
88 F.4th 539 (Fourth Circuit, 2023)
United States v. Keyon Paylor
88 F.4th 553 (Fourth Circuit, 2023)
United States v. Reshod Everett
91 F.4th 698 (Fourth Circuit, 2024)
United States v. Darrius King
91 F.4th 756 (Fourth Circuit, 2024)
United States v. Rahimi
602 U.S. 680 (Supreme Court, 2024)
United States v. Matthew Hunt
123 F.4th 697 (Fourth Circuit, 2024)
United States v. Quamaine Smith
134 F.4th 248 (Fourth Circuit, 2025)

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