Case Explained: UNITED STATES OF AMERICA v. DAVID LEE GRAHAM

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-04 The fourth-circuit affirmed David Lee Graham’s conviction for possession of a firearm by a felon but vacated his sentence and remanded for resentencing due to a material discrepancy between the orally pronounced and written conditions of supervised release. The court applied the rule established in *United States v. Rogers*, 961 F.3d 291 (4th Cir. 2020), which prohibits such discrepancies. Specifically, the district court had orally imposed a warrantless search condition limited to Graham’s person and property, but the written judgment expanded this condition to include searches of “any” property, house, residence, vehicle, or effects. The court held that this deviation constituted a *Rogers* error, requiring vacatur and remand for full resentencing as the only available remedy. Additionally, the court denied Graham’s motion to file a pro se supplemental brief because he was represented by counsel. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.