Case Explained: UNITED STATES OF AMERICA v. ANDREW FLESHMAN

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-29 The Fourth Circuit affirmed the district court’s judgment of conviction and sentence, rejecting Andrew Fleshman’s claim that the court committed reversible error under *United States v. Rogers* by failing to orally pronounce or properly incorporate the standard and discretionary conditions of his supervised release. The court applied the standard that a *Rogers* error occurs only when a material discrepancy exists between the written judgment and the oral pronouncement, noting that a district court may satisfy its obligation through express incorporation of conditions from a Presentence Report (PSR) or standing orders into the oral sentence. The court found no reversible error because the district court adopted the PSR recommendations regarding supervised release conditions, those terms matched the written judgment word-for-word, and defense counsel explicitly requested that the conditions be incorporated by reference rather than recited individually. Consequently, the conviction and the sentence of 100 months’ imprisonment followed by three years of supervised release remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.