United States v. Lockhart, No. 16-4441 (4th Cir. 2019)
Annotate this CaseDefendant appealed his conviction for possession of a firearm by a convicted felon and his mandatory minimum 15 year sentence under the Armed Career Criminal Act. The Fourth Circuit affirmed in light of United States v. Massenburg, 564 F.3d 337 (4th Cir. 2009), which imposed an extreme burden on a defendant seeking plain error review of a court's failure to provide correct sentencing information before accepting a guilty plea. The court held that defendant failed to demonstrate plain error affecting his substantial rights. In this case, defendant did not make any statement on the record indicating that he would have proceeded to trial if he had been given the correct sentencing information. Nor did he express surprise at the statement in the PSR of a potential ACCA designation or seek to withdraw his plea on that basis. Finally, the government proffered strong evidence supporting the felon in possession charge.
The court issued a subsequent related opinion or order on June 10, 2019.
The court issued a subsequent related opinion or order on January 10, 2020.
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