Case Summaries: Fourth Circuit Court of Appeals (December 2023)

This post summarizes a published criminal law case released by the Fourth Circuit Court of Appeals during December 2023. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here. Petitioner was entitled to discovery and an evidentiary hearing on officer misconduct when substantial evidence of corruption came to light after his conviction U.S. v. Paylor, 88 F.4th 553 (Dec. 15, 2023). The defendant was charged with possession of firearm by felon in the District of Maryland. The defendant claimed that the officers planted the gun and stole money from his home during the arrest. He requested discovery relating to other misconduct allegations against one detective involved in his case. The government produced more than 30 internal affairs files relating to the detective, but the trial court only released four and a half of the files to defense counsel. The defense attorney did not think that information was sufficient to undercut the detective’s testimony and ultimately recommended that the defendant enter a guilty plea to the firearm offense. The defendant could have received 120 months for that crime. He was facing an additional 15 years for the revocation of a state suspended sentence. The parties eventually settled on a plea bargain where the state case would be resolved with a time served disposition and the defendant would receive a 60-month sentence for the federal crime. During the plea colloquy, the defendant acknowledged his guilt. Approximately two years later, the detective involved in the [...]