United States v. Talametrius Spruill

── United States v. Talametrius Spruill ── Court: Court of Appeals for the Fourth Circuit Date: June 01, 2026 Category: General USCA4 Appeal: 24-4673 Doc: 39 Filed: 06/01/2026 Pg: 1 of 3 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 24-4673 UNITED STATES OF AMERICA, Plaintiff - Appellee, v. TALAMETRIUS KENYON SPRUILL, Defendant - Appellant. Appeal from the United States District Court for the Eastern District of North Carolina, at Greenville. Richard E. Myers, II, Chief District Judge. (4:23-cr-00041-M-BM-1) Submitted: May 28, 2026 Decided: June 1, 2026 Before WYNN, QUATTLEBAUM, and HEYTENS Circuit Judges. Affirmed by unpublished per curiam opinion. ON BRIEF: G. Alan Dubois, Federal Public Defender, Jennifer C. Leisten, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Raleigh, North Carolina, for Appellant. W. Ellis Boyle, United States Attorney, David A. Bragdon, Assistant United States Attorney, Katherine Englander, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellee. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-4673 Doc: 39 Filed: 06/01/2026 Pg: 2 of 3 PER CURIAM: Talametrius Kenyon Spruill appeals the 180-month sentence imposed after a federal jury found him guilty of possession of ammunition by a felon, in violation of 18 U.S.C. §§ 922(g)(1), 924. On appeal, Spruill challenges the district court’s application of a cross- reference for attempted first-degree murder in calculating Spruill’s base offense level under the Sentencing Guidelines. See U.S. Sentencing Guidelines Manual §§ 2A2.1(a), 2K2.1(c) (2023). Using the base offense level derived from application of the cross-reference, the Guidelines range was 292 to 365 months, capped at 180 months by the statutory maximum sentence; if the cross-reference did not apply, Spruill contends that the Guidelines range would have been 57 to 71 months’ imprisonment. For the following reasons, we affirm. A Guidelines error is harmless—and, thus, does not warrant reversal—if “(1) the district court would have reached the same result even if it had decided the Guidelines issue the other way, and (2) the sentence would be reasonable even if the Guidelines issue had been decided in the defendant’s favor.” United States v. Mills, 917 F.3d 324, 330 (4th Cir. 2019) (citation modified). Here, the district court explicitly stated that a 180-month sentence was warranted under the relevant 18 U.S.C. § 3553(a) factors and that it would impose the same sentence as a variance even if it had miscalculated the Guidelines range based upon the factors the court discussed at the sentencing hearing. Because the “court made it abundantly clear that it would have imposed the same sentence . . . regardless of the advice of the Guidelines,” United States v. Gomez-Jimenez, 750 F.3d 370, 382 (4th Cir. 2014), we conclude that the first prong of the assumed error harmlessness inquiry is satisfied. 2 USCA4 Appeal: 24-4673 Doc: 39 Filed: 06/01/2026 Pg: 3 of 3 Turning to the second prong, we consider whether the sentence is substantively reasonable, taking into account the Guidelines range that would have applied absent the assumed error. Mills, 917 F.3d at 331. To be substantively reasonable, a sentence must be “sufficient, but not greater than ne