United States v. Lawrence Anderson

── United States v. Lawrence Anderson ── Court: Court of Appeals for the Fourth Circuit Date: May 12, 2026 Category: General USCA4 Appeal: 23-4096 Doc: 49 Filed: 05/12/2026 Pg: 1 of 6 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 23-4096 UNITED STATES OF AMERICA, Plaintiff - Appellee, v. LAWRENCE REHMEIL ANDERSON, Defendant - Appellant. Appeal from the United States District Court for the Middle District of North Carolina, at Greensboro. William L. Osteen, Jr., District Judge. (1:20-cr-00416-WO-1) Submitted: December 31, 2025 Decided: May 12, 2026 Before NIEMEYER and HEYTENS, Circuit Judges, and KEENAN, Senior Circuit Judge. Affirmed by unpublished per curiam opinion. ON BRIEF: Peter D. Zellmer, PETER D. ZELLMER, PLLC, Greensboro, North Carolina, for Appellant. Clifton T. Barrett, United States Attorney, JoAnna G. McFadden, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Greensboro, North Carolina, for Appellee. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 23-4096 Doc: 49 Filed: 05/12/2026 Pg: 2 of 6 PER CURIAM: After Lawrence Rehmeil Anderson pled guilty to possession of a firearm by a convicted felon, in violation of 18 U.S.C. § 922(g)(1), the district court determined that he had previously committed three violent felonies on different occasions, thus qualifying him for an enhanced sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). On the parties’ joint motion, we remanded Anderson’s first appeal to the district court in light of Wooden v. United States, 595 U.S. 360 (2022) (clarifying the “multi- factored” inquiry into whether ACCA predicate offenses occurred on different occasions). On resentencing, the district court sentenced Anderson as an armed career criminal to 184 months’ imprisonment. Anderson appeals, challenging the validity of his conviction and contending that he was erroneously sentenced as an armed career criminal. For the reasons that follow, we affirm. I Anderson first asserts that his conviction is infirm because, following New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022), § 922(g)(1) is unconstitutional, both facially and as applied to him. 1 Anderson does not assert that the convictions that prohibit 1 The Government asserts that because Anderson failed to preserve this issue below, our review is for plain error only. Anderson contends that we should consider the issue de novo because he had “good cause” for failing to timely raise the objection—namely, Bruen had not been decided when he entered his guilty plea in 2021. Because Anderson’s claims fail under either standard, we “assume—solely for the sake of argument—that the plain- error standard does not apply here and that we review [Anderson’s] constitutional claims de novo.” See United States v. Hunt, 123 F.4th 697, 702 (4th Cir.) (discussing similar dispute and noting unresolved “questions about the proper relationship between [Fed. R. Crim. P.] 12 and [Fed. R. Crim. P.] 52”), cert. denied, 145 S. Ct. 2756 (2024). 2 USCA4 Appeal: 23-4096 Doc: 49 Filed: 05/12/2026 Pg: 3 of 6 his possession of firearms “[are] pardoned or [that] the law defining the crime[s] of conviction [has been] found unconstitutional or otherwise unlawful.” Hunt, 123 F.4th at 700 (citati