Case Summaries: Fourth Circuit Court of Appeals (March 2025)

This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during March 2025. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here. Knock and announce before execution of search warrant was not required by the Fourth Amendment or federal statute when exigent circumstances existed U.S. v. Williams, 130 F.4th 177 (Mar. 4, 2025). Local police in the District of Maryland were investigating Noah Smothers, whom they suspected of high-level drug trafficking. During the investigation, they discovered that Smothers was distributing large amounts of marijuana and other drugs to Scott Willliams and his son, Taeyan Williams. That pair were in turn distributing the drugs to college students in the area. A dispute about money arose between the three men at some point, and they arranged a meeting to discuss the issue. At some point after the meeting date, Smothers vanished, along with the contents of his storage unit. Police eventually obtained a search warrant for Williams’ home to look for evidence relating to Smother’s disappearance.  Officers found more than 72 pounds or marijuana, more than 245 grams of cocaine, more than 545 grams of methamphetamine, a drug ledger, and more than $210,000 in currency, although they did not recover evidence relating to Smother’s disappearance. The pair were indicted for various gun, drugs, robbery, kidnapping, destruction of evidence, and conspiracy offenses. The defendants were tried jointly. Both were convicted of conspiracy to distribute drugs and possession [...]