United States v. Spencer, No. 16-4026 (4th Cir. 2017)Annotate this Case
Defendant appealed his 45-month sentence after pleading guilty to mailing a threatening letter in violation of 18 U.S.C. 876(c). Defendant's conviction stemmed from him sending a threatening letter to a federal courthouse that was covered with white powder. The court concluded that defendant failed to establish that any lack of notice of the district court's intention to depart from the advisory Guidelines range affected his substantial rights. The court rejected defendant's claim that the severity of the sentence rested on improper sentencing factors and unfounded factual findings. In this case, the inferences drawn by the district court were within the bounds of its discretion. Because defendant's sentence was procedurally and substantively reasonable, the court affirmed the judgment.