United States v. Martin Anderson

── United States v. Martin Anderson ── Court: Court of Appeals for the Fourth Circuit Date: May 18, 2026 Category: General USCA4 Appeal: 25-4043 Doc: 56 Filed: 05/18/2026 Pg: 1 of 4 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-4043 UNITED STATES OF AMERICA, Plaintiff - Appellee, v. MARTIN THOMAS ANDERSON, a/k/a Martin McNeil, Defendant - Appellant. Appeal from the United States District Court for the Northern District of West Virginia, at Wheeling. John Preston Bailey, District Judge. (5:23-cr-00031-JPB-JPM-1) Submitted: March 19, 2026 Decided: May 18, 2026 Before WILKINSON, RUSHING, and BENJAMIN, Circuit Judges. Affirmed by unpublished per curiam opinion. ON BRIEF: Frank C. Walker II, FRANK WALKER LAW, Clairton, Pennsylvania, for Appellant. Matthew L. Harvey, United States Attorney, Clayton J. Reid, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Wheeling, West Virginia, for Appellee. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-4043 Doc: 56 Filed: 05/18/2026 Pg: 2 of 4 PER CURIAM: Martin Thomas Anderson appeals the 151-month sentence imposed following his guilty plea to possession with intent to distribute methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1), (b)(1)(C). As relevant to this appeal, in calculating Anderson’s advisory Sentencing Guidelines range, the district court assessed a base offense level of 30 based on a finding that the offense involved at least 50 grams but less than 150 grams of “Ice,” see U.S. Sentencing Guidelines Manual § 2D1.1(c)(5) (2023), and applied a two- level enhancement because the offense involved the use of a firearm, see USSG 2D1.1(b)(1). Both the drug evidence and the firearm relevant to these determinations had been recovered from a backpack found by Anderson’s crashed vehicle after an attempted traffic stop. On appeal, Anderson argues that the district court clearly erred in finding that the backpack and its contents were attributable to him for sentencing purposes. We affirm. We “review[] all sentences—whether inside, just outside, or significantly outside the Guidelines range—under a deferential abuse-of-discretion standard.” United States v. Claybrooks, 90 F.4th 248, 257 (4th Cir. 2024) (internal quotation marks omitted). In performing this review, we first “evaluate procedural reasonableness, determining whether the district court committed any procedural error, such as improperly calculating the Guidelines range, failing to consider the § 3553(a) factors, or failing to adequately explain the chosen sentence.” United States v. Nance, 957 F.3d 204, 212 (4th Cir. 2020). Only if “the district court has not committed procedural error,” do we then assess the substantive reasonableness of the sentence. Id. 2 USCA4 Appeal: 25-4043 Doc: 56 Filed: 05/18/2026 Pg: 3 of 4 “When determining whether the district court properly applied the advisory Sentencing Guidelines, [we] review[] the district court’s legal conclusions de novo and its factual findings for clear error.” Claybrooks, 90 F.4th at 253 (internal quotation marks omitted). “‘Under the clear error standard, we will only reverse if left with the definite and firm conviction that a mistake has been committed.’” Id. (internal quotation marks omitted). “It is well settled that we review the district court’s calculation of