United States v. Joseph Bourabah

── United States v. Joseph Bourabah ── Court: Court of Appeals for the Fourth Circuit Date: April 29, 2026 Category: General USCA4 Appeal: 24-4331 Doc: 54 Filed: 04/29/2026 Pg: 1 of 23 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 24-4331 UNITED STATES OF AMERICA, Plaintiff - Appellee, v. JOSEPH BOURABAH, Defendant - Appellant. No. 24-4577 UNITED STATES OF AMERICA, Plaintiff - Appellee, v. JOSEPH BOURABAH, Defendant - Appellant. Appeals from the United States District Court for the Eastern District of Virginia, at Norfolk. John A. Gibney, Jr., Senior District Judge. (2:23-cr-00037-JAG-RJK-1) Submitted: March 11, 2026 Decided: April 29, 2026 USCA4 Appeal: 24-4331 Doc: 54 Filed: 04/29/2026 Pg: 2 of 23 Before KING, WYNN, and RUSHING, Circuit Judges. Affirmed by unpublished opinion. Judge Wynn wrote the opinion, in which Judge King and Judge Rushing joined. ON BRIEF: Patricia A. Rene, RENE LAW FIRM, Williamsburg, Virginia, for Appellant. Erik S. Siebert, United States Attorney, Alexandria, Virginia, Matthew J. Heck, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Norfolk, Virginia, for Appellee. Unpublished opinions are not binding precedent in this circuit. 2 USCA4 Appeal: 24-4331 Doc: 54 Filed: 04/29/2026 Pg: 3 of 23 WYNN, Circuit Judge: Criminal defendants enjoy a Sixth Amendment right to counsel. In some circumstances, they even enjoy a right to substitute that counsel if the relationship with counsel deteriorates beyond repair. But that substitution right has its limits—for reasons exemplified by this case. Here, a criminal defendant asked the court to dismiss his court-appointed counsel early in his case. The court obliged but warned him it was unlikely to do so again. Still, just a week before trial, the defendant returned to the court and asked the court to dismiss his second lawyer. This time, the court said no. The defendant then pleaded guilty to the crime. Months later, however, he had second thoughts and moved to withdraw his plea. The district court denied that motion, too, and ultimately sentenced him to 100 months’ imprisonment for a particularly cruel campaign of harassment directed at his victims. The defendant now appeals several of the district court’s decisions. But because we find no abuse of discretion in the district court’s denial of the motion to substitute counsel, in its refusal to allow the defendant to withdraw his guilty plea, or in the reasonableness of the sentence itself, we affirm. I. A. From approximately September 2021 to February 2023, Joseph Bourabah engaged in a targeted harassment campaign against his former friend, WR, 1 as well as members of 1 We use initials here, as did the trial court, to preserve the anonymity of the victims. 3 USCA4 Appeal: 24-4331 Doc: 54 Filed: 04/29/2026 Pg: 4 of 23 her extended family, including her mother, AM; her fiancé, SE2; SE2’s mother, SE1; and SE2’s father, ME. 2 The harassment began in September 2021, shortly after WR announced her engagement to SE2. Bourabah be