US v. Chikosi Legins, No. 20-4390 (4th Cir. 2022)
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Defendant, a former federal prison guard, was indicted for sexually assaulting a prisoner twice and then lying to law enforcement about it. A jury convicted Defendant only of making a false statement to law enforcement while acquitting him of the more substantial sex-crime charges. Following that verdict, the district court made two decisions that increased Defendant’s sentence. First, it imposed an enhanced statutory maximum that was neither charged nor submitted to the jury. Second, it varied upward to impose the sentence Defendant would have faced if he had been convicted of sexually abusing the prisoner. On appeal, Defendant challenged his false-statements conviction.
The Fourth Circuit rejected Defendant’s challenge to his false-statement conviction. The court held that sufficient evidence supported that conviction, and any arguable inconsistency with the jury’s acquittal on other counts does not invalidate the false-statement conviction. The court reasoned that sufficient evidence supported the finding that both of Defendant’s statements were false for the reason charged—that is, Defendant had performed a sexual act on an inmate.
Further, the court agreed that the district court judge improperly imposed an enhanced statutory maximum penalty based on a judicial finding not in the indictment or found by the jury. However, the court found the error harmless, reasoning that although Defendant could have been charged, he was not. And absent a charge and conviction, Defendant was not subject to the 8-year statutory maximum sentence. Finally, the court held that the district court did not impose an unreasonable sentence.
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