Intended Loss, Sophisticated Means, and Multi‑Object Money‑Laundering Conspiracies in the Fourth Circuit: Commentary on United States v. Anyanwu

Intended Loss, Sophisticated Means, and Multi‑Object Money‑Laundering Conspiracies in the Fourth Circuit:
A Commentary on United States v. Kaodichimma Anyanwu (4th Cir. Dec. 18, 2025) (Unpublished)

I. Introduction

This commentary examines the unpublished per curiam decision of the United States Court of Appeals for the Fourth Circuit in United States v. Kaodichimma Okechukwu Anyanwu, No. 23‑4429 (Dec. 18, 2025), affirming a conviction and sentence for a money‑laundering conspiracy under 18 U.S.C. § 1956(h).

Although unpublished and therefore not binding precedent in the Fourth Circuit, the opinion is instructive in three important areas:

  • The treatment of multi‑object money‑laundering conspiracies under § 1956(h), and how a challenge to only one object crime fares on appeal.
  • The continued deference to Sentencing Guidelines commentary on “intended loss” and “sophisticated means” following United States v. Boler and United States v. Sanders.
  • The evidentiary and instructional standards governing relevance (Fed. R. Evid. 401–402) and the use of a willful‑blindness (deliberate ignorance) jury instruction.

The defendant, Kaodichimma Anyanwu, was convicted by a jury of a conspiracy to commit two forms of money laundering:

  • Concealment money laundering under 18 U.S.C. § 1956(a)(1)(B)(i), and
  • Transactional money laundering under 18 U.S.C. § 1957.

He received a 33‑month term of imprisonment and three years of supervised release. On appeal, he raised four principal claims:

  1. The evidence was insufficient to support the conspiracy object of transactional money laundering under § 1957.
  2. The district court improperly excluded two defense exhibits: New York census data and a government press release regarding a Yahoo data breach.
  3. The district court erred in instructing the jury on willful blindness.
  4. The district court miscalculated the Sentencing Guidelines range by:
    • using intended loss instead of actual loss, and
    • applying a “sophisticated means” enhancement to the money‑laundering scheme.

The Fourth Circuit affirmed on all grounds. While the case does not announce new binding precedent, it consolidates and applies recent circuit authority on Guidelines deference (Boler; Sanders) and reiterates the practical consequences of charging and proving a multi‑object § 1956(h) conspiracy.

II. Summary of the Opinion

The Fourth Circuit’s holdings can be distilled as follows:

  1. Sufficiency of the Evidence (Multi‑Object § 1956(h) Conspiracy).
    The government charged a conspiracy to commit both concealment money laundering (§ 1956(a)(1)(B)(i)) and transactional money laundering (§ 1957). The jury returned a verdict finding both objects. On appeal, Anyanwu challenged only the sufficiency of the evidence for the transactional money‑laundering conspiracy object. Relying on United States v. Miller, 41 F.4th 302 (4th Cir. 2022), the court held that because a § 1956(h) conspiracy is sustained by proof of an agreement to commit either object crime, the conviction stands even if the transactional‑laundering evidence were insufficient, so long as concealment‑laundering evidence supports the verdict. The conviction was thus affirmed without revisiting the transactional‑laundering sufficiency.
  2. Evidentiary Rulings (Relevance and Abuse of Discretion).
    The district court did not abuse its discretion in excluding:
    • Census data about New York’s population, offered to challenge cell‑site evidence placing devices near certain ATMs.
    • A government press release concerning a Yahoo data breach, offered to cast doubt on the attribution of email accounts used in the scheme.
    The court held that such generalized data were irrelevant to the specific cell‑site and email evidence at issue.
  3. Willful Blindness Instruction.
    Applying United States v. Ravenell, 66 F.4th 472 (4th Cir. 2023), the court held that a willful‑blindness instruction is proper where evidence supports either actual knowledge or deliberate ignorance, particularly where a defendant claims lack of guilty knowledge. The record supported both actual knowledge and deliberate ignorance, so the instruction was appropriate.
  4. Sentencing – Intended Loss Under § 2B1.1.
    Under the 2021 Guidelines, § 2B1.1 did not define “loss” in the text. The commentary defined loss as the greater of actual and intended loss. United States v. Boler, 115 F.4th 316 (4th Cir. 2024), held that “loss” is ambiguous and that courts may defer to the commentary’s intended‑loss definition. Therefore, the district court correctly applied a six‑level enhancement based on intended, not actual, loss.
  5. Sentencing – Sophisticated Means for Money Laundering Under § 2S1.1.
    Relying on United States v. Sanders, 146 F.4th 372 (4th Cir. 2025), the court held that:
    • “Sophisticated means” in § 2S1.1 is ambiguous, permitting reliance on the commentary defining it as “complex or intricate offense conduct” that typically uses fictitious entities, shell corporations, multiple transaction levels, or offshore accounts.
    • The enhancement applies only where the conduct exceeds the minimum necessary to commit the offense, yet need not be the “most complex means possible.”
    Reviewing for clear error, the court concluded that the record supported the district court’s two‑level sophisticated‑means enhancement.

III. Detailed Analysis

A. Multi‑Object Money‑Laundering Conspiracies Under § 1956(h)

1. Legal Framework

The charge in this case is conspiracy under 18 U.S.C. § 1956(h), which criminalizes an agreement to commit a substantive money‑laundering offense under § 1956 or § 1957. The Fourth Circuit in United States v. Green, 599 F.3d 360 (4th Cir. 2010), articulated the elements:

  1. An agreement between two or more persons to commit one or more money‑laundering offenses under § 1956(a) or § 1957;
  2. The defendant’s knowledge that the laundered funds were proceeds of unlawful activity; and
  3. The defendant’s knowing and voluntary participation in the conspiracy.

Here, the count alleged a conspiracy with two distinct object offenses:

  • Concealment money laundering – transactions designed to conceal or disguise the nature, location, source, ownership, or control of criminal proceeds (18 U.S.C. § 1956(a)(1)(B)(i)); and
  • Transactional money laundering – monetary transactions over $10,000 with criminally derived property (18 U.S.C. § 1957).

A key point, drawn from United States v. Miller, 41 F.4th 302 (4th Cir. 2022), and reiterated here, is that liability under § 1956(h) can be established by a conspiracy to commit either object crime. If the jury is instructed and returns a verdict indicating agreement as to both objects, the conviction is valid so long as the evidence is sufficient as to at least one object.

This principle is rooted in long‑standing doctrine on general verdicts in multi‑object conspiracy cases. As a practical matter, it means:

  • A defendant cannot secure reversal simply by undermining the sufficiency of the evidence as to one object, if another object is adequately supported.
  • Prosecutors often draft conspiracy counts broadly, pleading multiple objects to preserve the conviction even if one theory later proves weaker.

2. Application in Anyanwu

The jury in Anyanwu found that the defendant joined a conspiracy to commit both concealment and transactional money laundering. On appeal, however, he challenged only the sufficiency of the evidence supporting the transactional money‑laundering object under § 1957.

The panel’s key move is concise but significant: it cites Miller for the proposition that “liability under § 1956(h) can be established by showing a conspiracy to commit either object crime.” Because:

  • the jury expressly found both concealment and transactional money laundering as objects, and
  • Anyanwu did not challenge the sufficiency of the evidence for the concealment‑laundering object,

the conviction stands even assuming (without deciding) that the evidence on the § 1957 object might have been insufficient. The panel therefore does not reach the merits of the transactional‑laundering sufficiency claim.

This illustrates in stark form how the structure of the indictment and the scope of the appellate challenge can determine the outcome: the unchallenged concealment object alone suffices to sustain the § 1956(h) conviction.

3. Doctrinal and Practical Implications

The court’s reasoning underscores several practical points:

  • Charging practice. Prosecutors are incentivized to allege multiple money‑laundering objects within a single § 1956(h) conspiracy count. So long as evidence is strong for at least one object, the conviction is insulated on appeal, even if another object is debatable.
  • Defense strategy. A defendant facing a multi‑object conspiracy conviction must be careful to challenge every object that could independently support the conviction. Focusing narrowly on a single object, while leaving others unchallenged, can render the appeal effectively academic.
  • Appellate review economy. The approach avoids the need for appellate courts to undertake granular sufficiency analysis as to each object if at least one is unassailably supported.

For future cases in the Fourth Circuit, Anyanwu offers a clear reminder: in a § 1956(h) conspiracy with multiple objects, a valid verdict on one object—supported by sufficient evidence—is enough; a failure to challenge that object’s sufficiency generally dooms the appeal.

B. Evidentiary Rulings: Relevance and the “Low Bar” in Practice

1. Standards and Precedents

The court applies the familiar abuse‑of‑discretion standard to the district court’s evidentiary rulings, citing United States v. Elsheikh, 103 F.4th 1006 (4th Cir. 2024). A trial court abuses its discretion if:

  • it is guided by erroneous legal principles, or
  • it relies on clearly erroneous factual findings.

Federal Rule of Evidence 402 provides that relevant evidence is generally admissible unless another rule or law excludes it. “Relevance” is defined under Rule 401 as having any tendency to make a fact of consequence more or less probable than it would be without the evidence.

The Fourth Circuit has often described the relevance threshold as a “low barrier,” as reiterated here through:

  • United States v. Cowden, 882 F.3d 464, 472 (4th Cir. 2018): evidence is relevant if “sufficiently related to the charged offense.”
  • United States v. Leftenant, 341 F.3d 338, 346 (4th Cir. 2003): evidence is admissible if it is “worth consideration by the jury, or has a plus value.”

2. The Excluded Evidence in Anyanwu

Anyanwu’s proffered evidence consisted of:

  1. New York census data – generalized demographic or population data, used to argue that being in a particular geographic area (as shown by cell‑site records) does not uniquely identify the defendant.
  2. A government press release about a Yahoo data breach – used to suggest that the email accounts involved in the scheme could have been compromised, thus weakening the inference that the defendant controlled them.

The district court excluded both as irrelevant. The Fourth Circuit affirmed, reasoning:

  • Census data about the population at large had “no bearing” on the government’s use of specific cell site data linking particular cellular devices to ATM locations at relevant times.
  • The Yahoo breach information was likewise irrelevant because there was no evidence that the specific email accounts used in the scheme were actually affected or likely to have been affected.

In other words, the defense offered general background information without a case‑specific link. The low bar for relevance still requires some concrete tie between the proffered evidence and the facts in dispute. Hypothetical or speculative possibilities (like the mere existence of a data breach or a large population) are not enough without connecting evidence.

3. Significance

The ruling illustrates that:

  • Courts will exclude generalized contextual evidence when it is not coupled with specific proof that it affected the defendant’s devices, accounts, or transactions.
  • Defense counsel seeking to undermine digital or forensic evidence must usually bring evidence that is particular to the devices or accounts at issue (e.g., logs showing compromise, expert testimony about vulnerabilities with a specific provider, or concrete data showing misattribution).

Thus, while relevance is indeed a “low barrier,” courts will still screen out evidence that is only marginally or conjecturally connected to the factual issues at trial.

C. Willful Blindness (Deliberate Ignorance) Instruction

1. Legal Concept and the Ravenell Framework

To convict Anyanwu of money‑laundering conspiracy, the government had to prove that he:

  • knew the funds were proceeds of illegal activity, and
  • knowingly and voluntarily joined the conspiracy.

As United States v. Ravenell, 66 F.4th 472 (4th Cir. 2023), makes clear, this “knowledge” requirement can be satisfied by:

  • Actual knowledge, or
  • Willful blindness (deliberate ignorance): the defendant consciously avoids learning the truth, taking deliberate actions to remain ignorant of the illicit nature of the funds.

A willful‑blindness instruction is appropriate in two principal scenarios:

  1. Where the trial evidence supports both actual knowledge and deliberate ignorance; or
  2. Where the defendant claims lack of guilty knowledge but the evidence supports an inference that he deliberately avoided learning incriminating facts.

2. Application in Anyanwu

Anyanwu argued that the willful‑blindness instruction was improper because there was no evidence he took “deliberate actions to avoid learning the specifics” of the scheme.

The Fourth Circuit, referring to the record, concluded the opposite: the evidence supported both actual knowledge and deliberate ignorance. While the opinion does not catalog this evidence in detail, its conclusion implies:

  • The overall pattern of Anyanwu’s conduct (such as receiving or moving funds under suspicious circumstances, possibly using ATMs and linked email accounts) was such that a reasonable juror could infer either that he knew the money’s illegal origin or that he consciously chose not to inquire.

Because the evidence fit within the Ravenell framework, the district court did not abuse its discretion in giving the willful‑blindness instruction.

3. Broader Significance

  • The decision confirms that, in white‑collar and money‑laundering cases, courts are comfortable allowing juries to consider willful blindness where the defendant’s conduct reflects “too many red flags” to credibly claim innocent ignorance.
  • For prosecutors, Anyanwu provides another data point that satisfying the knowledge element may be done by circumstantial evidence of avoidance, not only by direct proof of awareness.
  • For defendants, claiming ignorance is risky if the transactional patterns are strongly suggestive of wrongdoing and if the record can support a finding that the defendant intentionally did not ask questions.

D. Sentencing Guidelines Issues

1. Intended vs. Actual Loss Under § 2B1.1 and Boler

Anyanwu challenged the use of intended loss—rather than actual loss—in calculating the monetary enhancement under the 2021 version of the Guidelines, specifically § 2B1.1(b). Under that version:

  • The guideline text did not define “loss.”
  • The commentary stated that “loss” is the greater of:
    • Actual loss: the real monetary harm suffered, and
    • Intended loss: the pecuniary harm the defendant sought to inflict, even if it was unlikely or impossible to occur.

In United States v. Boler, 115 F.4th 316 (4th Cir. 2024), the Fourth Circuit confronted this interpretive issue. It held:

  • The word “loss” in § 2B1.1 is ambiguous because it reasonably could mean either actual financial harm or intended financial harm.
  • When a Guideline term is ambiguous, courts may rely on the Sentencing Commission’s commentary to resolve the ambiguity, so long as the commentary is consistent with the Guideline’s text and structure.

Accordingly, Boler approved the use of the commentary’s “greater of actual or intended loss” rule. In Anyanwu, the panel simply applies Boler:

  • Because “loss” is ambiguous under the 2021 Guidelines, the district court properly deferred to the commentary in using intended loss to calculate the enhancement.
  • The district court therefore did not err in applying a six‑level enhancement based on the intended loss amount.

From a policy perspective, this tends to produce higher loss calculations in fraud and money‑laundering cases, especially where a scheme is thwarted mid‑course or where only some intended victims suffer actual loss.

2. Sophisticated Means for Money Laundering Under § 2S1.1 and Sanders

The court also addressed a two‑level enhancement for use of sophisticated means in a money‑laundering scheme under USSG § 2S1.1. The key points:

  • In United States v. Sanders, 146 F.4th 372 (4th Cir. 2025), the Fourth Circuit held that the term “sophisticated means” in § 2S1.1 is ambiguous, permitting courts to consult the commentary.
  • The commentary defines “sophisticated means” as “complex or intricate offense conduct” and states that it “typically involves the use of fictitious entities, shell corporations, two or more levels of transactions, or offshore accounts.” USSG § 2S1.1 cmt. n.5.
  • Sanders clarified that:
    • The enhancement applies only when there is proof of complexity beyond the minimum conduct needed to commit the basic money‑laundering offense.
    • However, the defendant does not have to employ the most complex or elaborate scheme conceivable; “more than minimal complexity” is sufficient.

In Anyanwu, the court reviews the sophisticated‑means finding for clear error and concludes that the record supports the enhancement, without describing the scheme in detail. Given the references to ATM withdrawals and linked email accounts, the scheme likely involved multiple layers or coordinated transactions characteristic of money laundering, exceeding a simple, one‑off transaction.

The decision thus:

  • Reaffirms that § 2S1.1’s sophisticated‑means enhancement is available when the laundering conduct involves multi‑step structuring, multiple accounts, or analogous complexities.
  • Confirms Sanders’ approach: courts may rely on the commentary to interpret “sophisticated means” and will defer to district courts’ factual findings unless clearly erroneous.

3. Combined Sentencing Impact

Together, the intended‑loss and sophisticated‑means rulings significantly affect sentencing exposure in economic and money‑laundering cases:

  • Intended loss can be substantially greater than actual loss, especially when schemes are intercepted or only partially successful, resulting in higher offense levels.
  • Sophisticated means adds another two levels where the conduct is more coordinated or layered than a simple transfer, even if it does not involve shell corporations or offshore havens.

For defendants, these rulings underscore the importance of contesting both the loss methodology and the characterization of the scheme’s complexity at sentencing, ideally with detailed factual and expert evidence. For prosecutors, the opinion confirms that the Fourth Circuit remains receptive to leveraging Guidelines commentary to support enhancements, provided the textual term is ambiguous.

IV. Key Precedents Cited and Their Roles

  • United States v. Savage, 885 F.3d 212 (4th Cir. 2018).
    Provides the standard of review for sufficiency challenges and Rule 29 motions: de novo review, with the evidence viewed in the light most favorable to the government. Emphasizes that reversal for insufficiency is reserved for cases where the prosecution’s failure is “clear.”
  • United States v. Rodriguez‑Soriano, 931 F.3d 281 (4th Cir. 2019).
    Defines substantial evidence as that which a reasonable factfinder could accept as adequate to support guilt beyond a reasonable doubt—reaffirming the high bar for sufficiency challenges.
  • United States v. Green, 599 F.3d 360 (4th Cir. 2010).
    Sets forth the elements of a § 1956(h) money‑laundering conspiracy: agreement, knowledge that the funds were unlawful proceeds, and voluntary participation.
  • United States v. Miller, 41 F.4th 302 (4th Cir. 2022).
    Establishes that liability under § 1956(h) may rest on a conspiracy to commit either of the object crimes—here, concealment money laundering or transactional money laundering. Forms the basis for upholding the conviction where only one object was challenged on appeal.
  • United States v. Elsheikh, 103 F.4th 1006 (4th Cir. 2024).
    Articulates the abuse‑of‑discretion standard for evidentiary rulings, focusing on whether the district court relied on erroneous legal principles or clearly erroneous fact‑finding.
  • United States v. Cowden, 882 F.3d 464 (4th Cir. 2018), and United States v. Leftenant, 341 F.3d 338 (4th Cir. 2003).
    Explain the broad concept of relevance—any evidence “worth consideration by the jury” with “plus value”—while still allowing courts to exclude evidence lacking a concrete connection to contested facts.
  • United States v. Ravenell, 66 F.4th 472 (4th Cir. 2023).
    Provides the framework for willful‑blindness instructions: appropriate where evidence supports actual knowledge or deliberate ignorance, especially when the defendant denies knowledge but circumstantial evidence indicates conscious avoidance.
  • United States v. Dennings, 922 F.3d 232 (4th Cir. 2019), and United States v. Shephard, 892 F.3d 666 (4th Cir. 2018).
    Set out the standards for sentencing review: overall reasonableness reviewed under an abuse‑of‑discretion standard; Guidelines calculations reviewed for clear error (facts) and de novo (legal questions).
  • United States v. Boler, 115 F.4th 316 (4th Cir. 2024).
    Holds that “loss” in § 2B1.1 is ambiguous, permitting reliance on commentary defining loss as the greater of actual and intended loss; thereby authorizing the use of intended loss enhancements in the Fourth Circuit.
  • United States v. Sanders, 146 F.4th 372 (4th Cir. 2025).
    Concludes that “sophisticated means” in § 2S1.1 is ambiguous and endorses reliance on commentary defining it. Clarifies that the enhancement applies only when there is additional complexity beyond the minimal elements of money laundering, but does not require the most elaborate scheme possible.

V. Complex Concepts Simplified

1. Multi‑Object Conspiracy Under § 1956(h)

A conspiracy charge can list several “object” crimes—things the conspirators agreed to do. For § 1956(h):

  • Object 1 might be concealment money laundering (hiding the illegal source of funds).
  • Object 2 might be transactional money laundering (spending more than $10,000 in dirty money).

If the jury finds a defendant guilty of a conspiracy to commit both objects, the conviction is valid so long as the evidence is strong enough for at least one of them. Even if the evidence is weak for the second object, the conviction stands if the first is well supported.

2. Willful Blindness (Deliberate Ignorance)

Willful blindness is a legal substitute for actual knowledge. Instead of proving that a person directly knew something was illegal, the government can show:

  • There were obvious signs of illegality (red flags), and
  • The person deliberately avoided learning the truth—by not asking questions or looking away.

A simple example: someone paid a large fee to transport “packages” for strangers, receives them in unusual ways, and is ordered not to open them. If they never ask what is inside, a jury might find they were willfully blind to the fact that the packages contained contraband.

3. Intended Loss vs. Actual Loss

  • Actual loss is the real amount of money victims lost—for example, the dollars actually stolen or paid out.
  • Intended loss is how much the defendant tried to steal, even if he was stopped early or failed. It includes amounts that were “unlikely or impossible” to materialize.

Under Fourth Circuit law (following Boler), when the Guideline is ambiguous, judges may use the commentary’s rule that loss is the greater of actual or intended loss. This often increases the sentencing range.

4. Sophisticated Means in Money Laundering

“Simple” money laundering could be as basic as taking cash from a crime and depositing it once in your own bank account. “Sophisticated means” means the defendant went further—for instance:

  • Moving money through several accounts or layers of transactions.
  • Using shell companies or third parties to disguise ownership.
  • Sending funds abroad to hide them.

The enhancement applies only if the conduct is more complex than necessary to commit basic money laundering, but it does not require the most elaborate scheme imaginable.

5. Standards of Review: Why They Matter

  • De novo review (e.g., for legal questions and Rule 29 sufficiency challenges) means the appellate court decides the issue anew, giving no deference to the district court’s legal conclusions.
  • Abuse of discretion (e.g., for evidentiary rulings, jury instructions, and many sentencing decisions) is highly deferential. The appellate court will affirm unless the lower court’s decision was unreasonable, based on a legal error, or on clearly incorrect fact‑finding.
  • Clear error (for many factual findings at sentencing) is even more forgiving; the appellate court must be left with a “definite and firm conviction” that a mistake has been made to reverse.

These standards explain why it is difficult to overturn jury verdicts and sentencing determinations on appeal, absent truly significant errors.

VI. Impact and Future Litigation

Although unpublished and non‑precedential, Anyanwu is likely to exert persuasive influence within the Fourth Circuit—especially at the district‑court level—on several fronts:

  • Multi‑object § 1956(h) conspiracies. The case reinforces the lesson of Miller that charging multiple laundering objects in a single conspiracy count provides a strong buffer against sufficiency challenges. Defense counsel must anticipate this by attacking all objects that can sustain the conviction.
  • Guidelines commentary deference. Together with Boler and Sanders, Anyanwu shows a stable doctrinal line: where a Guideline term (such as “loss” or “sophisticated means”) is ambiguous, the Fourth Circuit will permit reliance on commentary. This may affect how defense counsel frame challenges in light of broader national debates about deference to guidelines commentary.
  • Evidentiary strategy in digital‑evidence cases. The opinion signals skepticism toward generic, non‑case‑specific evidence (like broad census or general data‑breach information) offered to undermine precise forensic evidence (like cell‑site or account‑specific records). Future litigants will likely need more tightly tailored technical proof to cast doubt on digital attribution.
  • Knowledge and willful blindness in financial crimes. By upholding the willful‑blindness instruction on a relatively succinct record, the court underscores that money‑laundering and fraud defendants will rarely succeed by claiming ignorance in the face of suspicious transactional patterns.

In sum, Anyanwu cements, at the persuasive level, a pragmatic approach: preserving convictions in complex financial cases through flexible evidentiary rulings, robust use of conspiracy doctrine, and deferential review of guideline‑based sentencing decisions infused with commentary‑driven interpretations.

VII. Conclusion

United States v. Anyanwu is a compact but doctrinally rich affirmation of how the Fourth Circuit currently handles money‑laundering conspiracies, evidence, jury instructions on knowledge, and key Sentencing Guidelines enhancements.

On the conspiracy side, the case underscores that a multi‑object § 1956(h) conviction stands if any one object is sufficiently supported, placing a premium on comprehensive appellate challenges. On evidentiary and instructional issues, it reflects deferential review and a willingness to approve willful‑blindness instructions where circumstantial evidence implies conscious avoidance of the truth.

On sentencing, Anyanwu fits squarely within a line of decisions that:

  • treat “loss” and “sophisticated means” as ambiguous guideline terms,
  • permit reliance on commentary to resolve those ambiguities, and
  • thereby authorize intended‑loss calculations and sophisticated‑means enhancements in appropriate cases.

While the opinion is unpublished and not formally binding, it provides a clear snapshot of the Fourth Circuit’s practical approach to economic‑crime sentencing and reinforces the importance of Guidelines commentary in that calculus. For practitioners, the case is a useful roadmap of current doctrine in money‑laundering prosecutions and sentencing in the Fourth Circuit.

Case Details

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

Comments