United States v. Hardy, No. 19-4804 (4th Cir. 2021)Annotate this Case
The Fourth Circuit affirmed defendant's conviction for drug and firearm offenses. The court concluded that, even if the district court plainly erred by failing to give the 18 U.S.C. 3501(a) instruction to the jury, the error did not affect defendant's substantial rights. The court explained that any prejudice defendant suffered was minimized by the instructions the district court did give, and defendant did not meaningfully challenge the voluntariness or veracity of his confession. The court also concluded that the evidence was sufficient to support defendant's conviction for possession of a firearm as a felon (Count 3) and possession of a firearm in furtherance of drug trafficking (Count 4). Finally, the court concluded that there was no reversible error in the district court's sentencing procedures and the substantive sentence.