US v. Claybrooks, No. 22-4426 (4th Cir. 2024)
Annotate this CaseIn this case, the defendant, Jahsir Claybrooks, pleaded guilty to possession of a stolen firearm. The probation office determined that at the time of the offense, Claybrooks was an unlawful user of controlled substances and under indictment for a felony, making him a "prohibited person" not allowed to possess a firearm. As a result, his sentence was calculated based on this status. Claybrooks challenged this designation, arguing that he was not an unlawful drug user and that the statute was unconstitutionally vague. He also asserted that the district court erred in determining he was under indictment at the time of his offense and in imposing a sentence above the recommended guidelines. Finally, Claybrooks argued that the district court should have conducted an analysis of the firearms statutes at issue in accordance with a recent Supreme Court case. The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, concluding that the district court did not commit reversible error. The court found that the district court correctly determined that Claybrooks was an unlawful user of controlled substances at the time of the offense, the relevant statute was not unconstitutionally vague, and the district court did not err in imposing an above-guidelines sentence. The court also dismissed Claybrooks' argument regarding the need for an analysis of the firearms statutes, as he raised this issue for the first time on appeal.
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