US v. Rodney Coby, No. 22-4237 (4th Cir. 2023)
Annotate this Case
A jury found Defendant guilty of six drug-related offenses, and the district court sentenced him to 40 years in prison. The district court increased Defendant's offense level by two because it found he was “an organizer, leader, manager, or supervisor” within the meaning of Guidelines Section 3B1.1(c). Second, the court increased Defendant’s offense level by four because it concluded Defendant misrepresented fentanyl as heroin. Defendant raised two challenges to the verdict. Defendant also raised two challenges to his sentence.
The Fourth Circuit rejected Defendant’s sufficiency of the evidence challenge and his claim that the district court committed reversible error in instructing the jury. The court vacated Defendant’s sentence and remanded for resentencing. The court held that the government was not required to prove that the victim died from a fentanyl overdose—it was required to show that she died from using a “substance” containing fentanyl for whose distribution Defendant was legally responsible. The government introduced sufficient evidence for the jury to conclude it had met that burden. The jury heard evidence Defendant supplied the drugs the victim consumed on the day of her death and that she died around three hours later from a drug overdose. Here, a jury could conclude a substance distributed by Defendant was the cause of the victim’s death. However, the court concluded that the district court erred in applying a provision that was not part of the Sentencing Guidelines when Defendant committed his offenses and that Defendant is entitled to relief even under the plain-error standard.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.