Court Affirms Convictions, Sentences, Versus Various Challenges

US v. Williams: A marijuana supplier disappeared and suspicion fell on Scott Williams and his son, Taeyan, who “operated a large-scale enterprise selling drugs to college students” supplied by the missing supplier. His body was never found, but a search of Scott’s home uncovered a large amount of cash, firearms, sizable amounts of multiple kinds of drugs, and “a drug ledger found under the mattress in Scott’s room.” The Williams’ were charged with numerous counts, including conspiracy to distribute drugs and kidnapping resulting in death. A jury found them guilty of some drug counts (but acquitted on the kidnapping, among others) and Scott guilty of possession with intent to distribute methamphetamine and conspiracy to destroy evidence. Scott was sentenced to a term 276 months in prison, Taeyan to 150 months.

On appeal, the Fourth Circuit affirmed the Williams’ convictions and sentences. Taeyan’s only argument was that there was insufficient evidence that he possessed with intent to distribute the marijuana and cocaine found in Scott’s home. The court disagreed, noting the difficult standard of review (“it is not enough for Taeyan to assert a non-frivolous argument” or show “there is some evidence that supports his position”), and pointing to evidence of his constructive possession of the drugs, noting that whether Taeyan lived there or not (he claimed he did not) was not determinative.

As to his conviction, Scott argued that the evidence found in his home should have been suppressed because the search warrant was executed without knocking. Recognizing this was not a basis for suppression under Hudson v. Michigan, Scott relied on 18 U.S.C. § 3109 as the basis for exclusion. The court did not decide the issue, concluding instead that the police had exigent circumstances that justified the no-knock search in the first place. As to his term of imprisonment, the court refused to decide that Scott was eligible for a two-point reduction under the “zero point” amendment to the Guidelines, leaving it for Scott to pursue via a § 3582(c)(2) motion. Finally, the court concluded that a condition of supervised release requiring Scott take part in mental health treatment, which left to the probation officer the nature and location of such treatment, was not an improper delegation of judicial authority.