Case Explained: UNITED STATES OF AMERICA v. ANTONIO LAMONT SMITH

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-29 The Fourth Circuit affirmed the conviction and sentence of Antonio Lamont Smith for possessing ammunition as a felon in violation of 18 U.S.C. § 922(g), including the Armed Career Criminal Act (ACCA) enhancement under 18 U.S.C. § 924(e). The court held that while the district court committed constitutional error by failing to submit the ACCA “occasions” inquiry to the jury, as required by *Erlinger v. United States*, 144 S. Ct. 1852 (2024), this error was harmless beyond a reasonable doubt. Applying the standard from *Chapman v. California*, 386 U.S. 18 (1967), and *United States v. Brown*, 136 F.4th 87 (4th Cir. 2025), the court determined that no reasonable jury could have found otherwise given the undisputed facts: Smith had four prior armed robbery convictions involving different victims, weapons, and locations, with each offense separated by at least six days. Under the multi-factor test established in *Wooden v. United States*, 142 S. Ct. 1063 (2022), these factors confirmed that the offenses occurred on “occasions different from one another,” meaning a jury would have unanimously found the requisite three prior violent felonies. Consequently, Smith’s conviction and 300-month sentence remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.