Circumstantial Proof of Drug Knowledge and Strict Enforcement of Rogers: Commentary on United States v. Scott (4th Cir. 2025)

Circumstantial Proof of Drug Knowledge and Strict Enforcement of Rogers: Commentary on United States v. Scott (4th Cir. 2025)

I. Introduction

This commentary examines the Fourth Circuit’s unpublished per curiam opinion in United States v. James Arthur Scott, No. 24‑4389 (4th Cir. Nov. 21, 2025), arising from a controlled delivery of cocaine hidden in wax-filled shoeboxes. The case presents two analytically distinct but practically important holdings:

  • First, the court affirms a drug-trafficking conviction under 21 U.S.C. § 841, holding that circumstantial evidence—particularly behavior around a suspicious parcel, the presence of loaded firearms, and the colloquial meaning of the addressee name “Lit Wick”—was sufficient for a rational jury to find that the defendant knew the package contained a controlled substance, not just some contraband.
  • Second, the court vacates the entire sentence and remands for full resentencing after finding a “Rogers error” in the way the district court imposed “standard” supervised-release conditions, applying its prior published decision in United States v. Smith, 117 F.4th 584 (4th Cir. 2024).

The defendant, James Scott, was convicted in the Eastern District of Virginia of possession with intent to distribute more than 500 grams of cocaine but acquitted of a related firearm charge under 18 U.S.C. § 924(c). He received a 108‑month prison sentence and four years of supervised release. On appeal, Scott challenged both the sufficiency of the evidence for his conviction and multiple aspects of his sentence.

Although unpublished and therefore nonbinding precedent in the Fourth Circuit, the opinion has real practical significance. It clarifies how the rigorous “knowledge” requirement announced in McFadden v. United States, 576 U.S. 186 (2015), can be satisfied with circumstantial evidence in a traditional cocaine case, and it reinforces a line of Fourth Circuit authority (Rogers, Singletary, Smith, Kemp) strictly policing the oral pronouncement of supervised-release conditions.

II. Summary of the Opinion

A. Factual Background

Special Agent Ashby Marshall of the Virginia State Police, specializing in parcel interdiction, noticed a suspicious package at a Newport News parcel facility on August 10, 2023. The package was addressed to “Lit Wick” at 1718 North King Street, Hampton, Virginia. The addressee did not match known occupants at that address, and the package’s packaging raised red flags.

A drug-sniffing dog alerted to the package, and a search warrant revealed two shoeboxes containing two kilograms of cocaine hidden within blocks of melted wax. Law enforcement rewrapped the parcel and made a controlled delivery later that day.

Detective Robert Stewart surveilled the address, which was part of a small group of buildings sharing a common parking lot. When he arrived, Scott was already in the lot, sitting in a Dodge Charger he had backed up to the tree line. He remained in the lot for more than an hour, leaving the car only briefly to get a snack from the trunk and never entering any building.

An undercover officer, posing as a UPS driver, arrived with the “Lit Wick” package. Before the officer could reach any building entrance, Scott exited his vehicle, intercepted the officer, accepted the package, placed it on the front passenger seat, and walked back around toward the driver’s side. At that point, uniformed officers entered the lot and arrested him.

A search of the vehicle incident to arrest revealed:

  • Two loaded semi-automatic pistols, each with a round chambered:
    • One in the center console, grip-up and immediately visible when the console was opened.
    • One in the trunk, plainly visible despite being partially covered by clothes.
  • A jacket on the front seat containing Scott’s wallet and $1,000 in cash.
  • A rental agreement in the trunk showing Scott had rented the car weeks earlier.

The regular UPS driver for that address, who had delivered there for three years, told police he had previously delivered packages addressed to “Lit Wick” at that location. He later identified Scott in a photo array as the person who had accepted those packages. At trial, he estimated about four such deliveries; at sentencing, the government asserted Scott had signed for nine “Lit Wick” packages.

B. Procedural Posture

Scott was charged with:

  • Possession with intent to distribute more than 500 grams of cocaine, in violation of 21 U.S.C. § 841; and
  • Possession of a firearm in furtherance of a drug-trafficking offense, in violation of 18 U.S.C. § 924(c).

He proceeded to jury trial. The jury convicted him on the drug charge and acquitted him on the § 924(c) firearm charge. The district court imposed:

  • 108 months’ imprisonment; and
  • Four years of supervised release, including “standard conditions of supervised release that have been adopted by this Court and are incorporated into this judgment.”

On appeal, Scott raised:

  1. A sufficiency-of-the-evidence challenge to his § 841 conviction, asserting the government failed to prove he knew the package contained a controlled substance.
  2. Several sentencing challenges, including:
    • Errors in the Guidelines calculation;
    • Improper reliance on acquitted conduct;
    • Substantive unreasonableness of the sentence; and
    • A Rogers-based challenge to the supervised-release conditions, arguing the district court had not properly pronounced or incorporated them.

C. The Court’s Disposition

The Fourth Circuit:

  • Affirmed Scott’s conviction under § 841, holding that the circumstantial evidence was sufficient to establish his knowledge that the package contained a controlled substance.
  • Vacated the entire sentence and remanded for a full resentencing, holding that the district court committed a Rogers error in the way it imposed “standard” supervised-release conditions, under binding circuit precedent in Smith.
  • Declined to reach Scott’s other sentencing arguments because the Rogers/Smith error required full resentencing.

III. Analysis of the Opinion

A. Precedents and Authorities Cited

1. Substantive Conviction (Knowledge and Sufficiency)

  • United States v. Williams, 130 F.4th 177 (4th Cir. 2025) The court relies on Williams for the familiar three elements of a § 841 possession-with-intent-to-distribute offense:
    1. Possession of a narcotic controlled substance;
    2. Knowledge of the possession; and
    3. Intent to distribute.
    The dispute in Scott’s case is squarely over the second element—knowledge—but under the heightened framework set by the Supreme Court’s McFadden decision.
  • McFadden v. United States, 576 U.S. 186 (2015) McFadden is the linchpin. The Supreme Court held that for § 841(a)(1), the government must prove the defendant knew:
    • That the substance was a controlled substance (i.e., on a federal schedule); or
    • Sufficient facts about its identity to know it was regulated as such.
    The Fourth Circuit quotes and applies McFadden to emphasize that it is not enough for the government to show the defendant knew he possessed something illegal in general; he must know he was dealing specifically with a controlled substance, not just some contraband.
  • United States v. Louis, 861 F.3d 1330 (11th Cir. 2017) The court cites Louis from the Eleventh Circuit, which similarly held that to prove a § 841 violation, the government must show the defendant knew the box contained a controlled substance, not merely some illegal contraband. This reinforces that McFadden applies beyond “designer drug” cases and extends to conventional drugs like cocaine.
  • Musacchio v. United States, 577 U.S. 237 (2016) The court uses Musacchio to explain the standard of sufficiency review: a conviction stands if “any rational trier of fact” could find each element proven beyond a reasonable doubt. The reviewing court must draw all reasonable inferences in favor of the government and assume the jury resolved evidentiary conflicts in the government’s favor.
  • United States v. Hunt, 99 F.4th 161 (4th Cir. 2024), cert. denied, 145 S. Ct. 1890 (2025) Cited for the Fourth Circuit’s articulation of the same sufficiency standard and the obligation to view evidence in the light most favorable to the government.
  • United States v. Powell, 469 U.S. 57 (1984) The court invokes Powell to explain that the jury’s acquittal on the § 924(c) firearm count does not undermine the sufficiency of the evidence for the § 841 conviction. Sufficiency review is conducted count-by-count; inconsistent verdicts do not invalidate a conviction supported by sufficient evidence.

2. Sentencing and Supervised-Release Conditions

  • United States v. Rogers, 961 F.3d 291 (4th Cir. 2020) Rogers established that a district court must orally pronounce all non-mandatory conditions of supervised release at the sentencing hearing. The court may do so by:
    • Stating the individual conditions on the record; or
    • Properly incorporating a discernible list (e.g., Sentencing Guidelines “standard conditions,” or a standing order) into the oral pronouncement.
    Any non-mandatory condition appearing for the first time only in the written judgment, and not clearly incorporated orally, is a nullity.
  • United States v. Singletary, 984 F.3d 341 (4th Cir. 2021) Singletary clarified the remedy: discretionary conditions first appearing in the written judgment are “nullities,” and a remand for resentencing is required when such an error occurs.
  • United States v. Smith, 117 F.4th 584 (4th Cir. 2024) Smith is the controlling authority in Scott’s case. There, the same district (Eastern District of Virginia) purported to impose “the standard conditions of supervised release that have been adopted by this Court—that is, this Court in the Eastern District of Virginia.” The Fourth Circuit held that to be insufficient incorporation under Rogers because:
    • At the time, the Eastern District of Virginia had no standing order or similar instrument adopting a set of “standard conditions”; and
    • Thus, it was unclear what, exactly, the district court was incorporating.
    The court in Scott’s case finds the district judge’s language “substantively identical” to that in Smith, and therefore holds that Smith “is controlling and compels” a finding of Rogers error.
  • United States v. Kemp, 88 F.4th 539 (4th Cir. 2023) Kemp addresses the scope of the remedy: defendants who prevail on a Rogers claim and request a full resentencing are entitled to “full vacatur” of their sentences. The court applies this rule, vacating Scott’s entire sentence and declining to address his remaining sentencing arguments.

3. Non-Judicial References

  • Dictionary and slang references to “lit” The court notes that “lit” is commonly used to describe being high or intoxicated, citing Dictionary.com and UrbanDictionary.com. This supports the inference that the fictitious addressee name “Lit Wick” alluded to drug or intoxicant use, and thus can be probative of knowledge that the package contained a controlled substance.

B. The Court’s Legal Reasoning

1. Sufficiency of the Evidence and the Knowledge Requirement

a. The McFadden Knowledge Standard Applied to a Parcel Case

The core substantive issue is whether the government introduced sufficient evidence that Scott knew he was dealing with a controlled substance. Under McFadden and § 841:

  • It is not enough to show he knew the package contained something illegal (e.g., stolen property, untaxed goods, counterfeit merchandise).
  • The government must show that he knew the nature of the substance was such that it was regulated as a controlled substance on a federal schedule.

The opinion acknowledges that counsel for Scott effectively conceded that he was engaged in some illegal activity. The question is whether a rational jury could go beyond that and infer specific knowledge of a controlled substance rather than generic contraband.

b. Circumstantial Inferences Supporting Knowledge of a Controlled Substance

The court’s analysis rests on the cumulative weight of several circumstantial facts, explicitly noting that each piece may not be persuasive on its own but is sufficient when viewed together:

  1. Nature of the Contraband and Mode of Delivery The court reasons that among forms of contraband that are:
    • Small enough to be shipped in a parcel carried by a single person; and
    • Valuable enough to justify the elaborate precautions and risk in the observed operation,
    controlled substances—particularly cocaine—are highly likely candidates. By contrast, certain other contraband (e.g., untaxed cigarettes, some forms of stolen property) are less likely to:
    • Be packaged this way; or
    • Reveal their illegality instantly upon being opened by an unintended recipient.
    The court emphasizes that the illegal nature of a box of cocaine would be obvious if misdelivered and opened, whereas the illicit status of untaxed cigarettes would not be immediately apparent.
  2. Scott’s Conduct at the Scene Several behavioral indicators support an inference of knowledge:
    • Scott arrived before the controlled delivery and remained in his car for more than an hour without entering any building.
    • He parked the vehicle backed up to the tree line, suggesting an effort to position himself strategically in the lot.
    • He immediately intercepted the “driver” in the parking lot before the package reached any building, then promptly placed the package in his passenger seat.
    The court characterizes this as “unusual behavior” that demonstrates a strong interest in ensuring that:
    • The package not be delivered to anyone else; and
    • He personally receive it.
    A rational jury could infer this intense control over the package’s delivery reflected his knowledge that it contained something highly incriminating whose discovery by another would have immediate consequences—consistent with controlled substances.
  3. The Guns: Tools of the Drug Trade The search revealed two loaded semi-automatic pistols, each with a round chambered—one in the center console, one in the trunk—“plainly visible” when their compartments were opened. Trial testimony explained that individuals involved in drug trafficking frequently carry loaded firearms to protect drugs and money.

    The court acknowledges Scott’s argument that the jury’s not-guilty verdict on the § 924(c) firearm-in-furtherance count reflects a rejection of the “guns-as-drug-tool” theory. But invoking Powell, the court notes:
    • Sufficiency review of one count does not consider the jury’s verdict on another count.
    • Inconsistent verdicts are tolerated; a conviction supported by sufficient evidence stands even if logically inconsistent with an acquittal on another count.
    Thus, the firearms may legitimately be considered as circumstantial proof of Scott’s knowledge and involvement in the drug trade, even though the jury declined to find the specific “in furtherance” nexus required by § 924(c).
  4. The Fictitious Name “Lit Wick” The addressee name “Lit Wick” is neither a known occupant nor a bona fide business at the delivery address. The court notes that “lit” is common slang for being “high” or intoxicated, and “wick” can be associated with candles or burning.

    The opinion relies on standard and slang dictionaries to support that “lit” includes the meaning “under the influence of liquor or narcotics” and “high, stoned, out of it.” From this, a reasonable jury could infer that “Lit Wick” was a deliberate, knowing play on drug use, evidencing familiarity with drug culture and reinforcing that the package contained drugs rather than some unrelated contraband.
  5. Prior Deliveries to “Lit Wick” Accepted by Scott The long-time UPS driver identified Scott as the person who had previously accepted several packages addressed to “Lit Wick” at the same address. Although the appellate opinion largely relies on this for context rather than a detailed analysis, it is significant in two ways:
    • It suggests that the August 10 delivery was part of an ongoing arrangement rather than a one-off transaction; and
    • It supports an inference that Scott knew the nature of the recurring shipments.

Taken together, these facts satisfy, in the court’s view, the McFadden-enhanced knowledge requirement: a rational juror could find beyond a reasonable doubt that Scott knew he was receiving cocaine or at least a controlled substance, not merely some undefined contraband.

c. Deference to the Jury Under Musacchio and Hunt

The court repeatedly invokes the deferential standard of review for sufficiency challenges:

  • All permissible inferences must favor the prosecution.
  • The reviewing court assumes the jury resolved any conflicting evidence in the government’s favor.
  • The question is not whether the appellate judges themselves are convinced, but whether “any rational trier of fact” could have found the elements beyond a reasonable doubt.

The opinion explicitly acknowledges that some of the inferences may not be individually compelling. However, under the cumulative-evidence and deferential-review frameworks, the district court correctly denied Scott’s Rule 29 motion, and the jury’s verdict stands.

2. Sentencing: Rogers, Smith, and the Oral Pronouncement of Supervised-Release Conditions

a. The Rogers Framework

Under Rogers, the district court’s sentencing obligation is clear:

  • All mandatory conditions of supervised release (those dictated by statute) are imposed by operation of law and need not be individually pronounced.
  • All non-mandatory (discretionary) conditions—including “standard” conditions recommended by the Guidelines—must be:
    • Orally pronounced at the sentencing hearing; or
    • Orally incorporated by clear reference to a specific, identifiable set of conditions (e.g., “all standard conditions set forth in U.S.S.G. § 5D1.3(c)”).

Where discretionary conditions appear only later in the written judgment without having been clearly pronounced or incorporated at the hearing, those conditions are not lawfully imposed.

b. What Happened in Scott’s Case

In Scott’s written judgment, thirteen “standard” supervised-release conditions appear. At the sentencing hearing, however, the district court did not read or describe them. Instead, the court stated that Scott must:

“comply with the standard conditions of supervised release that have been adopted by this Court and are incorporated into this judgment.”

At first glance, this may appear to be a straightforward incorporation-by-reference. But the crucial question under Rogers and Smith is: What specific list of conditions did “this Court” mean to adopt?

c. Smith as Controlling Authority

In Smith, the same district (Eastern District of Virginia) used essentially the same language:

“the standard conditions of supervised release that have been adopted by this Court—that is, this Court in the Eastern District of Virginia.”

The Fourth Circuit held in Smith that:

  • At the time, no standing order or uniform rule in the Eastern District of Virginia had formally adopted a defined set of “standard” supervised-release conditions.
  • Therefore, the sentencing judge’s reference to “standard conditions … adopted by this Court” was ambiguous and indeterminate.
  • The defendant, the parties, and any reviewing court could not know with certainty which conditions were being orally imposed.

In Scott’s case, the court finds the sentencing language to be “substantively identical” to that in Smith, notes that the case also arises from the Eastern District of Virginia, and concludes that Smith “is controlling and compels” the finding of a Rogers error.

d. The Error and Its Consequences

Because the Eastern District of Virginia had not adopted a transparent, external set of “standard” conditions at the relevant time, the district judge’s generic reference to conditions “adopted by this Court” failed to:

  • Specify which non-mandatory conditions applied; or
  • Incorporate a clear, discernible list that could be identified by the parties or a reviewing court.

Under Rogers and Singletary:

  • The thirteen “standard” conditions in the written judgment are “nullities” because they were not lawfully imposed at sentencing.
  • That constitutes reversible sentencing error.

The government conceded the Rogers/Smith error on appeal, making the issue straightforward.

e. Remedy Under Kemp: Full Vacatur and Resentencing

Kemp governs the remedy. It holds that when a defendant successfully establishes a Rogers violation and requests full resentencing, the appropriate remedy is:

  • A complete vacatur of the sentence; and
  • A remand for plenary resentencing.

Scott did request a full resentencing. Accordingly, the court:

  • Vacates the entirety of his sentence (not only the supervised-release portion); and
  • Remands the case for a new sentencing hearing at which the district court must:
    • Recalculate the Guidelines (if necessary);
    • Consider the 18 U.S.C. § 3553(a) factors anew; and
    • Properly pronounce or incorporate any discretionary supervised-release conditions.

Crucially, the court explicitly declines to address Scott’s other sentencing challenges (Guidelines calculations, use of acquitted conduct, substantive reasonableness), invoking Kemp’s observation that when a full resentencing is ordered due to a Rogers error, it is unnecessary—and often improper—to reach additional sentencing issues relating to the now-vacated proceeding.

C. Impact and Implications

1. Substantive Drug Law: Knowledge in Parcel-Interdiction Cases

Although unpublished, the opinion is a useful illustration for future § 841 prosecutions involving mail or parcel deliveries. It shows that:

  • Parcel cases remain highly circumstantial by nature. The government often has little direct evidence that a recipient knew the contents of a sealed package. Yet, consistent with McFadden, prosecutors must still prove knowledge that the contents are a controlled substance.
  • Circumstantial evidence can satisfy the McFadden standard. This decision highlights several types of circumstantial evidence that together can support a knowledge finding:
    • Repeated prior deliveries of similarly addressed packages to the same defendant;
    • The use of a fictitious or coded addressee name associated with drug use (“Lit Wick”);
    • Suspicious behavior at the delivery site (waiting for long periods, intercepting the driver before reaching any building, unusual parking); and
    • The presence and strategic placement of loaded firearms as “tools of the trade.”
  • Defense strategy implications. Defense counsel in parcel cases will need to:
    • Challenge the chain of inferences leading from behavior to specific drug knowledge;
    • Undercut the claimed significance of slang or fictitious names; and
    • Disentangle generic firearms possession from drug-specific inferences when a § 924(c) count fails.

In short, the opinion demonstrates how courts are applying McFadden in traditional drug-trafficking fact patterns, not just designer-drug or analogue cases where the decision first arose.

2. Supervised Release Practice in the Fourth Circuit (Especially EDVA)

The Rogers–Singletary–Smith–Kemp line, reinforced here, has significant practical consequences:

  • District courts must reform sentencing colloquies. Judges in the Fourth Circuit—and especially in the Eastern District of Virginia—can no longer rely on vague references to “standard conditions adopted by this Court” unless there is a clearly identifiable and publicly adopted list (e.g., a standing order), and they specifically incorporate that list.
  • Defense counsel should be vigilant. Counsel should:
    • Listen carefully to the oral pronouncement of supervised release;
    • Compare it to the written judgment; and
    • Object on the record when discretionary conditions appear only in writing or are incorporated ambiguously.
  • Government and courts must ensure clarity. To avoid recurrent Rogers errors:
    • Districts may adopt standing orders specifying “standard” conditions and make them part of the local rules;
    • Judges should expressly reference those documents (e.g., “all standard conditions set forth in Standing Order No. X” or “those in U.S.S.G. § 5D1.3(c)”); and
    • Alternatively, judges can simply read the conditions into the record, which, though time-consuming, is the safest approach.
  • The remedy is broad. Because a successful Rogers challenge often results in full vacatur and resentencing (as in Kemp and here), such errors impose substantial costs on judicial resources and create uncertainty for all parties.

3. Inconsistent Verdicts and the Use of Acquitted Conduct

Although the court did not reach Scott’s argument that sentencing should not rely on acquitted conduct, the case still has two notable implications:

  • Substantively, the court reaffirms the doctrine from Powell that inconsistent verdicts do not undermine the legal sufficiency of a conviction on another count. Thus, an acquittal on a § 924(c) count does not prevent the jury (or an appellate court) from inferring that firearms were related to drug trafficking when evaluating the drug count’s sufficiency.
  • Procedurally, given the full resentencing, Scott may have an opportunity on remand to reargue the extent to which acquitted conduct (the § 924(c) count) should influence the new Guidelines calculation or the § 3553(a) analysis. The appellate decision is neutral on that point, leaving the issue open for the district court to consider on remand.

IV. Complex Concepts Simplified

1. Knowledge of a “Controlled Substance” vs. Knowledge of “Illegality”

Under § 841 as interpreted in McFadden:

  • The defendant must know that what he possesses is a controlled substance—that is, some drug regulated under the federal schedules.
  • It is not sufficient that he knows the item is illegal in some other way, such as:
    • Stolen property;
    • Counterfeit goods; or
    • Untaxed cigarettes or alcohol.

In Scott’s case, this meant the government had to persuade the jury, via circumstantial evidence, that he knew or strongly understood that the parcel was a drug shipment, not just “something illegal.”

2. Sufficiency-of-the-Evidence Review

When a defendant argues that the evidence at trial was insufficient to support his conviction, appellate courts:

  • View the evidence in the light most favorable to the prosecution;
  • Assume the jury resolved conflicting testimony in the government’s favor; and
  • Ask only whether any rational jury could have found guilt beyond a reasonable doubt, not whether the judges themselves would have voted to convict.

This is a very high bar for defendants. It explains why the Fourth Circuit upheld Scott’s conviction even while acknowledging that some pieces of evidence were not especially strong standing alone.

3. What Is a “Rogers Error”?

A “Rogers error” has several components:

  1. The sentencing court imposes supervised release.
  2. Certain conditions of supervised release are discretionary (that is, not required by statute).
  3. The court:
    • Does not read or describe those conditions aloud at sentencing; and
    • Does not clearly incorporate a specific, publicly identifiable list of conditions.
  4. Some or all of those conditions appear only later, in the written judgment.

Result: Those conditions are not legally part of the sentence, and the entire sentence is typically vacated if the defendant raises the issue and seeks full resentencing.

4. “Incorporation by Reference” at Sentencing

A court can satisfy its obligation to pronounce non-mandatory supervised-release conditions by “incorporation” if it clearly references a specific list. For example:

  • “I impose all standard conditions set forth in U.S.S.G. § 5D1.3(c).”
  • “I impose the standard conditions described in Standing Order No. 2025‑01 of this district.”

By contrast, a vague statement like “standard conditions adopted by this Court” is inadequate when it is unclear what those “standard conditions” are or whether any document has formally adopted them. That is the crux of the error in both Smith and Scott’s case.

V. Conclusion

United States v. Scott, though unpublished, is a significant application of two important doctrinal strands in federal criminal law.

On the substantive side, it shows how the demanding knowledge requirement of § 841, as articulated in McFadden, can be met through circumstantial evidence in routine drug cases—particularly where the defendant’s behavior, the coded addressee name, the presence of guns, and the overall context of a parcel operation converge to support an inference that he knew he was receiving drugs, not merely some contraband.

On the sentencing side, the case further entrenches the Fourth Circuit’s strict enforcement of Rogers. District courts must precisely articulate or clearly incorporate all discretionary supervised-release conditions at the sentencing hearing. Reliance on vague references to “standard conditions” without a defined, adopted list will not suffice. The remedy for such an error is sweeping: full vacatur and resentencing, as confirmed by Kemp.

For practitioners, the decision underscores:

  • The need to carefully evaluate and challenge the inferences drawn from circumstantial evidence in drug prosecutions, particularly in parcel-interdiction contexts; and
  • The importance of scrutinizing sentencing colloquies for Rogers compliance, given that even seemingly minor defects in supervised-release pronouncements can result in complete resentencing.

In the broader legal landscape, Scott illustrates how appellate courts continue to balance:

  • Deference to jury fact-finding on substantive guilt; with
  • Stringent procedural safeguards at sentencing, particularly where liberty-restricting supervised-release conditions are concerned.

Case Details

Year: 2025
Court: Court of Appeals for the Fourth Circuit

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