United States v. Williamson, No. 18-4837 (4th Cir. 2020)Annotate this Case
Drugs distributed for the "personal use" of an accomplice may be included as relevant conduct for the crime of aiding-and-abetting the distribution of a controlled substance. The Fourth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of aiding-and-abetting the distribution of methamphetamine. The court held that the district court did not err in including quantities that the accomplice used recreationally in defendant's sentence. The court also held that the district court did not commit clear error in its sentencing analysis, rejecting defendant's claims to the contrary.