United States v. Crawford: Clarifying the Obstruction-of-Justice Enhancement and Reaffirming Limits on “Reasonable Doubt” Definitions

1. Introduction

United States v. Stephen C. Crawford, No. 24-4243 (4th Cir. Aug. 14, 2025), arose from a fatal prison altercation at USP Hazelton in 2015. A jury found inmate Stephen Crawford guilty of voluntary manslaughter and two assault counts after video evidence showed him stabbing fellow inmate Arvel Crawford. The district court imposed a 188-month sentence.

On appeal, Crawford challenged four discrete rulings:

Exclusion of defense witness Davon Easton under Federal Rule of Evidence 404(b).
Refusal to issue Crawford’s proposed supplemental definition of “reasonable doubt.”
Application of a two-level obstruction-of-justice enhancement for allegedly suborning perjury by witness Roger Biel.
Denial of a downward departure under USSG § 5K2.10 for victim misconduct.

In an unpublished per curiam opinion, the Fourth Circuit affirmed in full. Although unpublished, the decision elaborates two themes that will guide future district-court practice: (i) the breadth of § 3C1.1’s obstruction enhancement when a defendant knowingly presents perjured testimony, and (ii) the circuit’s continued resistance to elaborating on the meaning of “reasonable doubt.”

2. Summary of the Judgment

The Fourth Circuit held:

Rule 404(b) Exclusion: Crawford waived appellate review by not addressing the district court’s alternate, independent basis for excluding Easton’s testimony—namely, that it was impermissible propensity evidence.
Reasonable-Doubt Instruction: The district court acted within its discretion by refusing to expand on the phrase “reasonable doubt,” limiting the charge to the standard formulation that it is “doubt based on reason and common sense.”
Obstruction-of-Justice Enhancement: Even though the court did not make an express “subornation of perjury” finding, the record—including Crawford’s own allocution—supported the conclusion that he willfully attempted to obstruct justice through Biel’s false testimony.
§ 5K2.10 Downward Departure: The refusal to depart was unreviewable because the district court understood its authority but declined to exercise it.

3. Analysis

3.1 Precedents Cited and Their Influence

Brown v. Nucor Corp., 785 F.3d 895 (4th Cir. 2015) — Establishes that failure to challenge alternate grounds for a ruling waives appellate review. Applied to bar Crawford’s evidentiary argument.
United States v. Queen, 132 F.3d 991 (4th Cir. 1997) — Sets the four-part test for admitting prior-act evidence, reinforcing why Easton’s testimony was inadmissible.
United States v. Williams, 152 F.3d 294 (4th Cir. 1998) & progeny (Frazer 2024; Watkins 2024) — Express deep skepticism toward defining “reasonable doubt”; cited to justify the truncated instruction.
United States v. Andrews, 808 F.3d 964 (4th Cir. 2015) — Allows § 3C1.1 enhancement where the defendant orchestrated or knew of perjured testimony, without a formal “subornation” finding; directly parallels Crawford.
Gall v. United States, 552 U.S. 38 (2007) & Fluker, Charboneau — Confirm the abuse-of-discretion and clear-error framework for sentencing review.
Torres-Reyes, 952 F.3d 147 (4th Cir. 2020) — Bars appellate review of discretionary refusals to depart.

3.2 The Court’s Legal Reasoning

3.2.1 Evidence Exclusion under Rule 404(b)

The district court found that Davon Easton’s proposed testimony sought to show Arvel’s propensity for violence—a purpose prohibited by Rule 404(b)(1). Even had Crawford provided timely notice, the testimony failed Queen’s relevancy-necessity test. Because Crawford’s brief attacked only the notice ruling and ignored the propensity ground, Brown v. Nucor compelled waiver.

3.2.2 Reasonable-Doubt Instruction

The panel reiterated a line of Fourth-Circuit authority discouraging judges from defining “reasonable doubt,” reasoning that definitions more often confuse than clarify. The trial court’s minimal description—“doubt based on reason and common sense, self-evident in meaning”—satisfied due-process obligations under Watkins and avoided the “confusion trap” condemned in Williams. Under Kivanc, Crawford could not show that the omission “seriously impaired” his defense.

3.2.3 Obstruction-of-Justice Enhancement (§ 3C1.1)

The heart of the opinion addresses whether the district court needed an explicit finding that Crawford suborned Biel’s perjury. Citing Andrews, the panel explained that § 3C1.1 covers any willful obstruction connected to the case. Three key facts supported the enhancement:

Perjury proved: Video evidence irrefutably contradicted Biel’s testimony, satisfying Dunnigan’s falsity-materiality-intent elements.
Defendant’s knowledge: Crawford admitted knowing Biel never saw the stabbing, yet allowed or encouraged the testimony.
Trial conduct: Daily strategy meetings between Crawford and counsel, plus the district court’s credibility findings, permitted the inference that testimony was orchestrated, not accidental.

Thus, the enhancement was valid even absent an express “subornation” label; the substance—willful obstruction—controlled. This clarification tightens the nexus between defendant knowledge and perjured testimony in future § 3C1.1 disputes.

3.2.4 Downward Departure for Victim Misconduct (§ 5K2.10)

A refusal to depart is unreviewable unless the sentencing court misapprehends its authority. The district judge explicitly recognized the discretion to depart but found the video record did not show significant provocation by the victim. Accordingly, appellate jurisdiction was absent.

3.3 Likely Impact of the Decision

Sentencing Practice: Prosecutors may rely on Crawford to argue that a defendant’s implicit or circumstantial role in presenting false testimony suffices for § 3C1.1. Defense counsel must now more vigorously vet witnesses to prevent inadvertent exposure to the enhancement.
Jury Instructions: The opinion cements the Fourth Circuit’s “less-is-more” stance on defining reasonable doubt, deterring creative defense proposals in the future.
Waiver Doctrine: The case serves as a cautionary tale—address all grounds supporting an adverse ruling, or lose appellate review under Brown.
Victim-Misconduct Departures: Reiterates that denials are practically bullet-proof on appeal, signaling to practitioners that record-making at sentencing is critical.

4. Complex Concepts Simplified

Rule 404(b): A rule barring evidence introduced solely to show that a person acted in conformity with prior bad acts. It may come in for other purposes (motive, intent, identity, etc.), but not to prove propensity.
Reasonable Doubt: The highest standard of proof in U.S. law. It does not require absolute certainty, but it does require that no logical reason to doubt guilt remains. Courts often avoid elaborate definitions to prevent juror confusion.
Obstruction-of-Justice Enhancement (USSG § 3C1.1): A two-level sentence increase when the defendant willfully attempts to hinder the investigation, trial, or sentencing—e.g., through lies, threats, destroyed evidence, or suborning perjury.
Subornation of Perjury: Persuading or allowing another person to lie under oath, knowing the testimony is false.
Downward Departure vs. Variance: A departure is an adjustment authorized by the Sentencing Guidelines’ policy statements; a variance is any sentence outside the Guidelines based on 18 U.S.C. § 3553(a) factors.

5. Conclusion

United States v. Crawford may be unpublished, but it sharpens several doctrinal edges in Fourth-Circuit criminal practice. First, it confirms that the obstruction-of-justice enhancement applies when a defendant knowingly permits false testimony, even without a formal finding of “subornation.” Second, it reinforces an entrenched rule: defining “reasonable doubt” is fraught with peril and generally disfavored. Finally, it showcases the unforgiving nature of waiver and the narrow appellate window to attack discretionary sentencing decisions. Collectively, these clarifications will influence evidentiary strategy, jury-instruction requests, and sentencing advocacy across the circuit.