US v. Denton: Denton was under investigation for blowing up his ex-girlfriend’s new boyfriend’s truck. After being arrested for violating a protective order, Denton’s phone was seized and searched. Investigators found Facebook messages in which he discussed trafficking in drugs. He was eventually charged and convicted of conspiracy to distribute 50 grams or more of methamphetamine (mixture) and explosives offenses related to the truck bombing. He was sentenced to 360 months in prison.
The Fourth Circuit affirmed Denton’s convictions and sentence, rejecting many arguments, most of them raised for the first time on appeal. Most notably, Denton argued that there was insufficient evidence to hold him personally responsible for at least 50 grams of methamphetamine, regardless of how much was involved in the conspiracy as a whole. Working through each witness who testified at trial and noting the proof of Denton’s connection to a particular meth cook, the court concluded that “there was substantial evidence that Denton conspired to distribute” that amount. Furthermore, while the court agreed that the district court improperly instructed the jury on the issue of conspiracy liability, it ultimately concluded (under plain error) that the error did not seriously affect the fairness, integrity, or public reputation of judicial proceedings because the “trial evidence overwhelmingly established” the drug weight attributable to Denton.