US v. Edward Jones, III, No. 14-4901 (4th Cir. 2015)
Annotate this Case
Download PDF
UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 14-4901 UNITED STATES OF AMERICA, Plaintiff - Appellee, v. EDWARD CLINTON JONES, III, Defendant - Appellant. Appeal from the United States District Court for the District of South Carolina, at Charleston. Richard M. Gergel, District Judge. (2:14-cr-00342-RMG-1) Submitted: July 31, 2015 Decided: September 3, 2015 Before WYNN, DIAZ, and FLOYD, Circuit Judges. Affirmed by unpublished per curiam opinion. Kimberly H. Albro, Research & Writing Specialist, FEDERAL PUBLIC DEFENDER’S OFFICE, Columbia, South Carolina, for Appellant. William N. Nettles, United States Attorney, Nathan S. Williams, Assistant United States Attorney, Charleston, South Carolina, for Appellee. Unpublished opinions are not binding precedent in this circuit. PER CURIAM: Edward Clinton Jones, III, appeals the 151-month sentence imposed by the district court following his guilty plea to solicitation of murder for hire, in violation of 18 U.S.C. §§ 373, 1958 (2012), and use of interstate commerce facilities in the commission of murder for hire, in violation of 18 U.S.C. § 1958. On appeal, procedurally Jones unreasonable, contends that the that his district sentence court erred is in failing to sua sponte order a mental competency hearing, and that the court improperly delegated judicial authority imposing a special condition of supervised release. in Finding no error, we affirm. Jones first contends that his sentence is procedurally unreasonable because the district court abused its discretion during sentencing by failing to explain its reasons for denying his motion for a downward variance. must ensure “significant that the procedural district error,” In reviewing a sentence, we court such as did not failing commit to any properly calculate the applicable Sentencing Guidelines range, failing to consider the 18 U.S.C. § 3553(a) (2012) factors, or failing to adequately explain the sentence. U.S. 38, 51 (2007). Gall v. United States, 552 In explaining its sentence, the district court is not required to “robotically tick through § 3553(a)’s every subsection.” United States v. Johnson, 445 F.3d 339, 345 2 (4th Cir. 2006). However, the court “must place on the record an ‘individualized assessment’ based on the particular facts of the case before it. This individualized assessment need not be elaborate or lengthy, but it must provide a rationale tailored to the particular case at hand ‘meaningful appellate review.’” and adequate to permit United States v. Carter, 564 F.3d 325, 330 (4th Cir. 2009) (quoting Gall, 552 U.S. at 50) (internal citation and footnote omitted)). We conclude discretion in that the imposing district the court 151-month did not abuse sentence. The its court thoroughly considered the § 3553(a) factors in finding that a within-Guidelines adequate sentence explanation those factors. for was the appropriate sentence and imposed provided upon an balancing Moreover, the record reflects that the court adequately considered Jones’ arguments for a downward variance but found those mitigating factors insufficient to warrant a below-Guidelines sentence. Jones next contends that the district court abused its discretion in failing to sua sponte order a mental competency hearing. hearing The district court must sua sponte order a competency “if there is reasonable cause to believe that the defendant may presently be suffering from a mental disease or defect rendering him mentally incompetent to the extent that he is unable to understand the nature 3 and consequences of the proceedings against him or to assist properly in his defense.” 18 U.S.C. § 4241(a) established (2012). through “Reasonable evidence of cause irrational may behavior, be the defendant’s demeanor at trial, and medical opinions concerning the defendant’s competence.” United States v. Bernard, 708 F.3d 583, 592-93 (4th Cir. 2013) (internal quotation marks omitted). The mere presence of mental illness is not, however, “equated with incompetence.” omitted). Id. Competency at turns 593 on (internal “whether quotation the marks defendant has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding — and whether he has a rational as well as factual understanding of the proceedings against him.” Id. (internal quotation marks omitted). Here, the district court did not err in failing to sua sponte order a competency hearing. See United States v. Dreyer, 705 F.3d 951, 960 (9th Cir. 2013) (stating that “a district court’s failure to conduct a competency hearing on its own motion will always be subject to plain error review”); see also Henderson v. (providing reflects United States, standard no for indication inappropriately at district was court medications, and any the 133 plain S. Ct. error that during aware court of acted the Jones’ adequately 4 1126-27 (2013) The record review). Jones point 1121, irrationally proceedings. mental The conditions inquired into or and Jones’ understanding of exists question is a the district court.” proceedings. left to “Whether the sound reasonable discretion cause of the Bernard, 708 F.3d at 592 (internal quotation marks omitted). The district court did not abuse its discretion in this case. Finally, Jones contends that the district court violated Article III of the Constitution by delegating its judicial authority to the probation officer to determine whether mental health treatment would be a condition of supervised release. probation officer has the authority to “manage aspects A of sentences and to supervise . . . persons on supervised release with respect to all conditions imposed by the court.” States v. Johnson, 48 F.3d 806, 808 (4th Cir. 1995). United A court may not, however, delegate to a probation officer a judicial function, as Constitution. improperly such a Id. delegation at delegated violates 808-09. the “To judicial Article determine authority of III if of a the court sentencing, [courts] have drawn a distinction between the delegation to a probation officer of a ministerial act or support service and the ultimate responsibility of imposing the sentence.” States v. Nash, 438 F.3d 1302, (internal quotation marks omitted). 1304-05 (11th Cir. United 2006) “Where the court makes the determination of whether a defendant must abide by a condition, it is permissible to delegate 5 to the probation officer the details of where and when the condition will be satisfied.” Id. (internal quotation marks, brackets, and ellipsis omitted). We conclude that the district court did not err in imposing on Jones the special condition of supervised release requiring mental health treatment. Jones undergo mental The court unequivocally ordered that health treatment as a condition of his supervised release and tasked the officer with the authority to determine the type of treatment necessary condition, a purely ministerial function. to fulfill the Thus, the court did not violate Article III. Accordingly, we affirm the district court’s judgment. dispense with conclusions are oral argument adequately because presented in the the facts We and legal materials before this court and argument would not aid the decisional process. AFFIRMED 6
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
