Case Explained: UNITED STATES OF AMERICA Plaintiff – v. THOMAS EMMANUEL WILLIAMS Defendant –

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-07-28 The fourth-circuit affirmed Thomas Williams’s convictions for firearm trafficking, possession of machineguns, and using a firearm during a drug trafficking crime, as well as the application of a sentencing enhancement. The court held that sufficient evidence supported the jury’s findings under 18 U.S.C. § 933(a)(1) and § 922(d)(10), ruling that Williams had reasonable cause to believe the firearms were for unlawful disposal based on the confidential informant’s cover story regarding resale to drug dealers, regardless of the informant’s actual government status. The court further determined that Glock switches constituted “machineguns” under federal law because they were designed and intended solely for converting weapons into fully automatic firearms, and found a sufficient nexus between the firearms and drug crimes under § 924(c) because the firearm sales facilitated the drug trafficking relationship. Finally, the court concluded there was no clear error in applying the U.S.S.G. § 2K2.1(b)(5)(C)(i)(III) enhancement for trafficking two or more firearms with reason to believe they would be used or disposed of unlawfully. The judgment of the district court is affirmed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.