United States v. Seigler, No. 19-4491 (4th Cir. 2021)Annotate this Case
The Fourth Circuit affirmed defendant's conviction and sentence for conspiracy to manufacture, distribute, or possess with the intent to distribute controlled substances or to use a communication facility in committing and causing the facilitation of any felony controlled substance offense.
The court concluded that the evidence was sufficient to support defendant's convictions. The court also concluded that defendant has not demonstrated he is entitled to have his conviction vacated for a new trial because he has not shown error or prejudice. In this case, the court discerned no obvious problem with the verdict form despite the use of the "and/or" construction. Furthermore, because the conspiracy conviction can stand based on the first object of the conspiracy (drug distribution), the court need not consider defendant's challenge to the verdict form's wording of the second object of the conspiracy (use of a communication facility). The court further concluded that defendant has not met his initial burden of showing that he was entitled to a Franks hearing. Finally, the court concluded that the district court did not commit reversible error in holding defendant responsible for between four and eight pounds of methamphetamine in determining his base offense level, and the district court did not err by imposing a two-level sentencing enhancement for obstruction of justice under USSG 3C1.1.