United States v. Watson: Modified Categorical Approach, “Relating To” Predicate Sex Offenses, and State Registration Duties Under § 2260A

I. Introduction

In United States v. Roland Vance Watson, No. 24‑4290 (4th Cir. Dec. 12, 2025) (unpublished, on rehearing), the Fourth Circuit revisited and reaffirmed its earlier affirmance of a lengthy child-exploitation sentence after granting rehearing prompted by the defendant’s pro se supplemental brief.

Watson pled guilty in the Western District of North Carolina to:

Count 2: Production of child pornography, in violation of 18 U.S.C. § 2251(a), with enhanced penalties under § 2251(e); and
Count 6: Committing a felony involving a minor while being required to register as a sex offender, in violation of 18 U.S.C. § 2260A.

He received a total sentence of 460 months’ imprisonment. Appointed counsel filed an Anders v. California brief asserting no meritorious issues. The panel initially affirmed. Afterward, Watson filed a pro se supplemental brief, and counsel moved to withdraw the prior opinion. Treating that motion as a petition for rehearing, the court granted rehearing but ultimately reaffirmed the conviction and sentence.

The opinion, although unpublished and non‑precedential, is significant for three interrelated reasons:

It applies plain error review to alleged defects in the Rule 11 plea colloquy and in the application of the § 2251(e) sentencing enhancement.
It clarifies how an out‑of‑state sex offense triggers sex‑offender registration obligations in North Carolina, thereby satisfying the “required to register” element of § 2260A.
It assumes, for argument’s sake, that the categorical / modified categorical approach applies to § 2251(e), and then uses the Fourth Circuit’s broad “relating to” doctrine (from United States v. Hardin) to conclude that Watson’s New Jersey sexual assault conviction qualifies as a predicate, making any failure to conduct a formal categorical analysis non‑prejudicial on plain‑error review.

II. Summary of the Opinion

The panel’s key holdings can be summarized as follows:

Validity of the guilty plea (Rule 11):
- The magistrate judge’s Rule 11 colloquy contained some omissions under Fed. R. Crim. P. 11(b)(1)(D), (E), (H), (M), but on plain‑error review those omissions did not affect Watson’s substantial rights.
- The record showed Watson was competent, his plea was knowing and voluntary, and there was an adequate factual basis.
§ 2260A conviction – “required to register as a sex offender” in North Carolina:
- Watson’s prior New Jersey conviction “triggered a requirement” that he register as a sex offender in New Jersey, as recognized in United States v. Winczuk, 67 F.4th 11 (1st Cir. 2023).
- Under North Carolina’s sex offender registration statute, N.C. Gen. Stat. §§ 14‑208.7(a), 14‑208.6(4)(b), that out‑of‑state conviction likewise required him to register in North Carolina.
- Therefore, his argument that he was not “required to register” in North Carolina failed on plain‑error review, and his § 2260A conviction stands.
§ 2251(e) enhancement – prior New Jersey sexual assault conviction:
- Section 2251(e) raises the penalty range from 15–30 years to 25–50 years where the defendant has a prior conviction under federal or state law “relating to aggravated sexual abuse, sexual abuse, abusive sexual contact involving a minor or ward, or sex trafficking of children.”
- Assuming arguendo that the categorical approach applies, the court held:
  - New Jersey’s sexual assault statute, N.J. Stat. Ann. § 2C:14‑2(c), is divisible (consistent with United States v. Mendez‑Sosa, 782 F.3d 1061 (9th Cir. 2015)), so the modified categorical approach applies (United States v. Fulks, 120 F.4th 146 (4th Cir. 2024); Descamps v. United States, 570 U.S. 254 (2013)).
  - Looking to a limited set of “Shepard documents,” the court identified the specific variant of the New Jersey offense of which Watson was convicted, and held that it qualifies as “relating to” abusive sexual contact involving a minor.
  - Under Hardin, the “relating to” language means that the state offense need not match the generic definition perfectly; it need only “stand in some relation” to the listed generic offense.
- Because Watson’s prior conviction clearly qualified under § 2251(e), any failure by the district court to articulate a categorical analysis did not affect his substantial rights and therefore was not plain error.
Reasonableness of the sentence:
- The district court correctly calculated the Guidelines range for Count 2 as 360–600 months (total offense level 42, criminal history category V) and acknowledged the mandatory 10‑year consecutive sentence on Count 6 under § 2260A.
- The court considered the 18 U.S.C. § 3553(a) factors, addressed the parties’ arguments, allowed Watson to allocute, and adequately explained its choice of a within‑Guidelines sentence on Count 2.
- Applying Gall v. United States, 552 U.S. 38 (2007), and the presumption of reasonableness for within‑Guidelines sentences recognized in United States v. Henderson, 107 F.4th 287 (4th Cir.), cert. denied, 145 S. Ct. 578 (2024), the panel held the sentence both procedurally and substantively reasonable.
Anders framework and rehearing:
- After conducting a full Anders review, the panel originally affirmed.
- Upon Watson’s pro se supplemental brief and his counsel’s request to withdraw the prior opinion (treated as a petition for rehearing), the court granted rehearing, considered the new arguments, and again affirmed the judgment.
- It denied Watson’s motion to appoint new counsel and reiterated counsel’s obligation to inform Watson of his right to seek certiorari.

III. Detailed Analysis

A. Procedural Setting and the Anders Framework

The case arises from an Anders appeal. Under Anders v. California, 386 U.S. 738 (1967), if court‑appointed counsel believes an appeal is wholly frivolous, counsel may file a brief identifying anything in the record that might arguably support the appeal and request leave to withdraw. The appellate court then undertakes an independent review of the entire record. If it finds no non‑frivolous issues, it may allow counsel to withdraw and dismiss or affirm.

Here:

Counsel filed an Anders brief, claiming no meritorious issues.
The panel did its own review and affirmed the conviction and sentence in a first opinion.
Later, Watson filed a pro se supplemental brief after obtaining an extension. This is common when a defendant disagrees with counsel’s Anders assessment.
Counsel then moved to “withdraw” the prior opinion. The panel sensibly construed this as a petition for rehearing under Federal Rule of Appellate Procedure 40.
The court granted rehearing, revisited the case in light of Watson’s pro se arguments, and issued the present opinion, reaffirming the district court’s judgment.

Procedurally, this shows that Anders affirmances are not set in stone until the appellate process is fully completed. Meaningful pro se submissions can prompt rehearing, but—especially on plain‑error review—they still face steep substantive hurdles.

B. Validity of the Guilty Plea Under Rule 11

1. Governing standards

The panel begins by confirming that Watson’s guilty plea meets the constitutional and procedural requirements:

Under United States v. Fisher, 711 F.3d 460, 464 (4th Cir. 2013), a guilty plea is valid if it is made voluntarily, knowingly, and intelligently, with “sufficient awareness of the relevant circumstances and likely consequences.”
Fed. R. Crim. P. 11(b)(1) requires the court, before accepting a plea, to advise the defendant of, and ensure he understands, his trial rights, the nature of the charges, and the maximum and minimum penalties.
Rule 11(b)(2) requires confirmation that the plea is voluntary and not the product of threats or unapproved promises.
Rule 11(b)(3) requires an adequate factual basis for the plea.
Under United States v. Nicholson, 676 F.3d 376, 382 (4th Cir. 2012), the court must also ensure that the defendant is competent to enter the plea.

Because Watson did not move in the district court to withdraw his plea, the Fourth Circuit’s review is limited to plain error, per United States v. King, 91 F.4th 756, 760 (4th Cir. 2024).

2. Plain error framework

Citing United States v. Jones, 157 F.4th 375, 377 (4th Cir. 2025), the panel restates the now‑standard four‑part test:

There must be an error;
The error must be plain (clear or obvious under current law);
The error must affect the defendant’s substantial rights (usually meaning there is a reasonable probability of a different outcome absent the error); and
The error must seriously affect the fairness, integrity, or public reputation of judicial proceedings.

In the context of Rule 11 errors, Greer v. United States, 593 U.S. 503 (2021), is especially important. Greer holds that on plain error review of a plea‑colloquy defect, the defendant bears the burden of showing “a reasonable probability that, but for the error, he would not have entered the plea.” The panel invokes Greer to emphasize that mere technical defects in the colloquy are insufficient without a showing of prejudice.

3. Application in Watson

The magistrate judge omitted certain advisements required by Rule 11(b)(1)(D), (E), (H), (M) (the opinion does not specify which aspects, but these subsections include rights like trial rights, confront/cross‑examine rights, assistance of counsel at trial, and possible immigration consequences).

Yet, the panel concludes:

Watson was competent to plead guilty.
The plea was knowing and voluntary: there is no indication of coercion or misunderstanding of core rights or penalties.
There was a sufficient factual basis for both counts.
The omissions did not affect his substantial rights under Greer—there is no showing that Watson would have rejected the plea and insisted on trial had the magistrate judge given the fuller advisements.

Accordingly, even though some Rule 11 errors existed, they were not reversible plain errors.

The panel also dismisses Watson’s complaint that the district court refused to consider an untimely victim statement from his prior state‑court offense, holding in a footnote that the court “properly declined to consider that information.” That reinforces the district court’s discretion to enforce timeliness and manage the record at sentencing.

C. Sex‑Offender Registration and the § 2260A Conviction

1. Statutory framework: 18 U.S.C. § 2260A

Section 2260A provides, in substance, that:

A person who commits certain federal offenses involving a minor (such as production of child pornography under § 2251) while
“being required by Federal or other law to register as a sex offender,”

is subject to a mandatory 10‑year term of imprisonment, to run consecutively to any other term of imprisonment.

The critical phrase for Watson’s appeal is “being required … to register as a sex offender.”

2. Watson’s argument and standard of review

Watson, in his pro se brief, argued that he was not required to register as a sex offender in North Carolina. Because he did not raise this objection below, the panel again reviews for plain error under Jones.

3. New Jersey registration requirement

The panel first notes that Watson’s prior New Jersey conviction “triggered a requirement that [he] register as a sex offender in New Jersey,” citing United States v. Winczuk, 67 F.4th 11, 13 (1st Cir. 2023). Winczuk addressed New Jersey’s sex‑offender registration statute (part of “Megan’s Law”) and held that certain sexual assault convictions automatically give rise to a registration requirement.

Thus, as a matter of New Jersey law, Watson had a duty to register as a sex offender there. This is important because many states, including North Carolina, use out‑of‑state convictions to trigger their own registration requirements.

4. North Carolina’s registration requirements

The panel then cites North Carolina’s sex‑offender registration provisions:

N.C. Gen. Stat. § 14‑208.7(a): requires a person with a “reportable conviction” who moves into or resides in North Carolina to register as a sex offender.
N.C. Gen. Stat. § 14‑208.6(4)(b): defines a “reportable conviction” to include an out‑of‑state offense that is substantially similar to a North Carolina sex offense or that triggers registration in the other state.

The court reasons that because Watson’s New Jersey conviction required registration in that state, it constituted a “reportable conviction” in North Carolina, thereby making him “required … to register as a sex offender” under North Carolina law.

5. Effect on § 2260A

Because Watson’s duty to register flowed from his New Jersey conviction and North Carolina’s statutory scheme, the factual premise of Count 6—committing a qualifying federal felony involving a minor while required to register—was satisfied. The panel, again on plain‑error review, finds no error, much less plain error, in the § 2260A conviction.

This portion of the opinion underscores that what matters for § 2260A is the legal requirement to register, not whether the defendant actually registered, nor whether he subjectively believed he had to register. If state law objectively required registration based on an out‑of‑state predicate, the § 2260A element is met.

D. The § 2251(e) Enhancement and the Categorical / Modified Categorical Approach

1. Statutory framework of § 2251(e)

Watson’s primary sentencing argument focused on § 2251(e), which enhances penalties for production of child pornography where the defendant has certain prior sex‑offense convictions.

For a first conviction under § 2251(a), § 2251(e) provides a sentencing range of 15 to 30 years. But if the defendant:

has one prior conviction under … the laws of any State relating to aggravated sexual abuse, sexual abuse, abusive sexual contact involving a minor or ward, or sex trafficking of children …

the range increases to 25 to 50 years.

Watson argued that:

The district court applied this enhanced range based on his prior New Jersey sexual assault conviction; but
The court did so without first performing a categorical analysis to determine whether that prior conviction qualifies as a predicate under § 2251(e).

Because he did not object below, the appellate review is for plain error.

2. The categorical and modified categorical approaches

The panel accepts, for argument’s sake, Watson’s premise that the categorical approach applies to § 2251(e). Under Descamps v. United States, 570 U.S. 254, 257 (2013), the categorical approach requires the court to:

Compare the elements of the statute of prior conviction with the elements of the relevant “generic” offense; and
Ignore the specific facts of the defendant’s conduct in the prior case.

If the statute of conviction covers a broader range of conduct than the generic offense, the conviction does not categorically qualify, unless the statute is divisible—i.e., it lists alternative elements, creating multiple, distinct crimes.

If the statute is divisible, courts use the modified categorical approach:

Per United States v. Fulks, 120 F.4th 146, 154–55 (4th Cir. 2024), and Shepard v. United States, 544 U.S. 13 (2005), the court consults a limited set of records (charging document, plea agreement, plea colloquy transcript, jury instructions, etc.)—“Shepard documents”—to determine which statutory alternative formed the basis for the conviction.
Once the specific alternative (crime) is identified, the court then performs a categorical comparison between that specific crime’s elements and the elements of the relevant generic offense.

3. Divisibility of the New Jersey statute

Watson’s prior conviction was under N.J. Stat. Ann. § 2C:14‑2(c), New Jersey’s second‑degree sexual assault statute. As the panel notes—citing United States v. Mendez‑Sosa, 782 F.3d 1061, 1064 (9th Cir. 2015)—§ 2C:14‑2(c) is divisible, consisting of multiple, alternative ways to commit sexual assault (e.g., different age combinations and circumstances).

Because of that divisibility, the panel applies the modified categorical approach:

Look to Shepard documents to determine which specific subsection of § 2C:14‑2(c) Watson was convicted under;
Then compare the elements of that specific offense to the relevant “generic” category under § 2251(e): e.g., “sexual abuse” or “abusive sexual contact involving a minor.”

The opinion does not reproduce the exact New Jersey statutory language or specify the precise subsection (e.g., age threshold, nature of contact). However, the panel concludes that the variant of the New Jersey offense for which Watson was convicted is sufficiently related to “abusive sexual contact involving a minor.”

4. The “relating to” language and Hardin

A key doctrinal piece is the statutory phrase “relating to” in § 2251(e). The Fourth Circuit has already interpreted this phrase broadly in another context in United States v. Hardin, 998 F.3d 582 (4th Cir. 2021).

In Hardin, the court held that when a federal enhancement requires that a prior conviction be for an offense “relating to” specified generic crimes, a perfect match of elements is not necessary. Instead, it suffices that the state offense:

“conduct only needs to stand in some relation; to have bearing or concern; to pertain; refer; to bring into association with or connection with abusive sexual [contact] involving a minor.”

(Watson quoting Hardin, with minor modifications.) This is a more forgiving standard than the strict categorical match used in some other contexts (such as the Armed Career Criminal Act where “relating to” is absent).

Applying Hardin to § 2251(e), the panel reasons that:

Even if the New Jersey statute is not a perfect element‑for‑element match with the generic federal crime of “abusive sexual contact involving a minor,”
It still plainly “relates to” that generic crime because it criminalizes sexual acts or contact with a minor that are abusive in nature.

5. Plain‑error overlay: no effect on substantial rights

Crucially, the panel declines to definitively resolve whether the district court erred by not explicitly conducting a categorical analysis. Instead, it assumes (favorably to Watson) that:

§ 2251(e) does require a categorical analysis; and
The district court did not conduct that analysis on the record.

Even under those assumptions, the panel holds there was no plain error because:

Watson’s New Jersey conviction clearly qualifies as a § 2251(e) predicate under the modified categorical approach and the “relating to” standard;
So even if the district court’s method was imperfect, the result (application of the enhanced sentencing range) was legally correct;
Accordingly, any error did not affect Watson’s substantial rights—there is no reasonable probability that the outcome (the enhancement) would have been different if the district court had applied the categorical approach explicitly.

In effect, the panel’s message is: even if the sentencing court’s explanation was analytically incomplete, the prior conviction indisputably fits within the statute as interpreted by Hardin, and so reversal is unwarranted on plain‑error review.

6. Precedential and practical implications

Although unpublished, this portion of Watson is instructive in several respects:

It reinforces that the “relating to” gloss from Hardin applies to § 2251(e), further broadening the range of state sex offenses that will qualify as predicates for enhanced penalties in child‑pornography production cases.
It confirms that N.J. Stat. Ann. § 2C:14‑2(c)—at least the variant applicable to Watson’s conviction—categorically “relates to” abusive sexual contact involving a minor for § 2251(e) purposes.
It emphasizes the difficulty of challenging sentencing enhancements on plain‑error review when the record clearly supports the enhancement under existing case law.
It illustrates a recurring appellate pattern: courts may assume certain doctrinal questions (like the applicability of the categorical approach) without definitively resolving them, when the outcome would be the same either way.

E. Reasonableness of the Sentence

1. Legal framework: Gall, Provance, Henderson

The panel next evaluates the sentence under the standard articulated in Gall v. United States, 552 U.S. 38 (2007):

First, review for procedural reasonableness: Did the district court properly calculate the Guidelines range, treat the Guidelines as advisory, consider the § 3553(a) factors, refrain from relying on clearly erroneous facts, and adequately explain the sentence?
Second, if the sentence is procedurally sound, review for substantive reasonableness: Is the sentence reasonable under the totality of the circumstances?

When the sentence falls within the correctly calculated advisory Guidelines range, the Fourth Circuit applies a presumption of substantive reasonableness, as reaffirmed in United States v. Henderson, 107 F.4th 287, 297 (4th Cir.), cert. denied, 145 S. Ct. 578 (2024). That presumption can be rebutted only by showing that the sentence is unreasonable when measured against the § 3553(a) factors.

United States v. Provance, 944 F.3d 213 (4th Cir. 2019), further instructs courts to look at the sentencing explanation and the overall record to determine whether the chosen sentence adequately reflects the statutory sentencing purposes.

2. Application to Watson’s 460‑month sentence

On Count 2 (§ 2251(a) production), the district court calculated:

Total offense level: 42
Criminal history category: V
Advisory Guidelines range: 360–600 months’ imprisonment

The court also recognized the mandatory 10‑year consecutive sentence for Count 6 under § 2260A. It then:

Heard argument from the parties on the appropriate sentence;
Allowed Watson to address the court;
Considered the § 3553(a) factors; and
Imposed a sentence that the panel describes as a “within‑Guidelines sentence on Count 2,” resulting in a total term of 460 months’ imprisonment across both counts.

The panel finds:

No procedural error: The Guidelines were properly calculated, the statutory factors were considered, and the court articulated a rationale for the chosen sentence.
No substantive error: The sentence falls within the advisory range for Count 2, and Watson failed to rebut the presumption that such a sentence is reasonable under the § 3553(a) factors.

Accordingly, the panel holds that the district court did not abuse its discretion in imposing the 460‑month total sentence.

IV. Complex Concepts Simplified

1. Anders appeals

In an Anders appeal:

Appointed counsel believes the appeal has no non‑frivolous issues but cannot simply abandon the client.
Instead, counsel files an Anders brief: it outlines any arguably supportable issues and explains why they lack merit.
The appellate court independently reviews the record. If it agrees that there are no meritorious issues, it may allow counsel to withdraw and affirm or dismiss.
The defendant can also file a pro se brief, as Watson did, raising any issues counsel did not press.

Here, the process went a step further when the panel granted rehearing in light of Watson’s pro se arguments.

2. Plain error review

Plain error review applies when a defendant failed to object at trial or sentencing. To win on plain error, the defendant must satisfy all four prongs:

Error: Something the court did (or failed to do) violated the law.
Plain: The error is clear or obvious under current law.
Substantial rights: The error affected the outcome—e.g., there is a reasonable probability the result would have been different without the error.
Fairness/integrity: The error seriously undermines the integrity or public reputation of judicial proceedings.

Failing any one of these prongs means no relief. This is why unpreserved challenges to plea colloquies and sentencing enhancements are so difficult to win.

3. Rule 11 plea colloquy

Rule 11 is the procedural rule that governs how federal courts accept guilty pleas. The court must:

Explain the defendant’s rights (jury trial, confrontation, self‑incrimination, etc.);
Describe the charges and potential penalties (including mandatory minimums);
Ensure the plea is voluntary and not coerced;
Confirm there is a factual basis—facts that, if true, satisfy each element of the offense.

Minor omissions can be harmless, especially when the defendant does not claim that he would have gone to trial if better informed.

4. Categorical and modified categorical approaches

When federal law enhances a sentence based on prior convictions for certain types of offense (e.g., “sexual abuse,” “violent felony,” “drug trafficking”), courts often use the categorical approach:

They look only at the elements of the prior offense—not the actual facts of what the defendant did.
If the statute covers conduct that is broader than the generic definition, the conviction does not qualify (unless the statute is divisible and the modified categorical approach can be used).

The modified categorical approach applies when the statute is divisible, meaning it lists multiple, alternative elements that create several different crimes. The court may look at a limited set of court records to determine exactly which alternative formed the basis for the conviction, and then compare that specific crime’s elements to the generic definition.

5. “Relating to” language

Many federal enhancement statutes, like § 2251(e), do not require a prior conviction to be exactly for “sexual abuse” or “abusive sexual contact.” Instead, they require a prior conviction “relating to” those offenses.

In the Fourth Circuit, under Hardin, “relating to” is read broadly:

The prior offense does not need to match every element of the generic federal offense.
It is enough if the offense has a meaningful connection—“some relation”—to the generic crime, such as criminalizing abusive sexual conduct with a minor.

This makes it easier for the government to establish that a prior state conviction qualifies as a predicate under enhancement provisions like § 2251(e).

6. Sex‑offender registration and § 2260A

For § 2260A, the key question is whether the defendant was “required … to register as a sex offender” under federal or state law at the time he committed the new federal offense.

Many states, like North Carolina, automatically require registration when a person has a qualifying sex offense in another state.
Even if the defendant never actually registered, or was never told to register, if the law objectively required registration, he is within § 2260A’s reach.

Watson’s New Jersey conviction required him to register there, which, under North Carolina statutes, in turn required him to register in North Carolina. That sufficed for § 2260A.

V. Impact and Broader Significance

1. Sex‑offense predicates for § 2251(e)

Even though Watson is unpublished, it reinforces and illustrates several important points for future litigation involving § 2251(e):

The Fourth Circuit’s broad reading of “relating to” from Hardin now expressly informs how predicates are evaluated under § 2251(e). Many state sex‑offense statutes that criminalize sexual contact with minors will qualify, even if they differ in details (e.g., age brackets, specific conduct, or required mental states).
Divisible statutes like New Jersey’s § 2C:14‑2(c) will be analyzed under the modified categorical approach, limiting the inquiry to the particular offense of conviction identified in Shepard documents. This can sometimes help defendants (if they pled to a non‑qualifying variant), but here it did not.
Sentencing courts should be mindful to make the categorical / modified categorical analysis explicit on the record. Even though the failure to do so did not amount to plain error here, clear on‑the‑record reasoning is better appellate practice and reduces later challenges.

2. Registration obligations and § 2260A

The decision also clarifies the interplay between out‑of‑state sex offenses and North Carolina’s registration scheme for purposes of § 2260A:

A conviction that triggers registration in another state (like New Jersey) will often be a “reportable conviction” in North Carolina under N.C. Gen. Stat. §§ 14‑208.7(a), 14‑208.6(4)(b).
For federal prosecutors, this makes it comparatively straightforward to establish that a defendant was “required to register” in North Carolina when committing a new federal sex crime.
For defendants, it highlights the importance of understanding that registration duties can follow them across state lines and can significantly enhance federal criminal exposure under § 2260A.

3. Preservation of objections and plain‑error constraints

Watson is also a cautionary tale about failing to object:

Had Watson’s counsel objected to the Rule 11 omissions or the § 2251(e) enhancement at the time of plea or sentencing, the appellate court would have reviewed under the more favorable abuse‑of‑discretion or harmless‑error standards.
On plain‑error review, Watson had to show not just theoretical legal error but concrete prejudice—something the panel found absent given the strength of the underlying law and record.

Practically, the case underscores the need for defense counsel to:

Scrutinize potential sexual‑offense predicates at sentencing and raise any plausible categorical‑approach challenges;
Create a clear record if they contend a prior conviction does not qualify under federal enhancement statutes;
Address registration issues explicitly when § 2260A is charged, including how state registration statutes operate on out‑of‑state convictions.

4. Anders practice and appellate procedure

Finally, Watson shows that:

An Anders affirmance is not the end of the road if a defendant timely files a substantive pro se brief raising new issues.
Appellate courts may treat a motion to withdraw a prior opinion as a petition for rehearing, granting it when warranted but still ultimately affirming if the new issues lack merit.
Even on rehearing, where the court fully considers newly raised issues, plain‑error review remains a formidable barrier to relief.

VI. Conclusion

United States v. Watson reaffirms that:

Guilty pleas will not be set aside for technical Rule 11 omissions absent a concrete showing of prejudice on plain‑error review.
Out‑of‑state sex convictions that trigger registration—such as certain New Jersey sexual assaults—can and do create ongoing registration duties in North Carolina, supporting federal enhancements under § 2260A.
Under the Fourth Circuit’s broad “relating to” doctrine, prior state sexual‑offense convictions that involve abusive sexual contact with minors will readily qualify as predicates for enhanced penalties under § 2251(e), even where the district court did not explicitly articulate a categorical analysis.
Within‑Guidelines sentences—particularly in serious child‑exploitation cases—are likely to be upheld as both procedurally and substantively reasonable under Gall and its progeny, including Henderson.

Although unpublished and not binding precedent, Watson is a useful illustration of how the Fourth Circuit applies the modified categorical approach, the expansive “relating to” standard, and plain‑error review in the context of child‑exploitation sentencing and sex‑offender registration–based enhancements. It signals that challenges to such enhancements will face high hurdles on appeal unless objections are clearly preserved and supported in the district court.