Case Explained: UNITED STATES OF AMERICA v. MICHAEL WINDOM

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-17 The Fourth Circuit affirmed Michael Windom’s sentence of 63 months’ imprisonment and three years of supervised release in part and dismissed his appeal in part regarding challenges to the procedural reasonableness of that sentence. The court held that Windom’s valid, knowing, and voluntary appellate waiver, established through a proper Rule 11 colloquy, precluded review of his argument that the district court procedurally erred by rejecting a below-Guidelines recommendation without an individualized explanation; under Fourth Circuit precedent, such challenges to procedural reasonableness fall squarely within the scope of such waivers. Regarding Windom’s second claim that the judgment contained a *United States v. Rogers* error due to a discrepancy between the oral and written sentences, the court applied de novo review to compare the two documents. The court found that while the oral sentence incorporated Maryland Standard Conditions requiring reporting based on where the defendant was “authorized to reside,” and the written judgment included language regarding where he was “released” alongside the residence requirement, this inconsistency was not material under *United States v. Aborisade*. Consequently, the court determined that full resentencing was not warranted for the discrepancy and affirmed the remainder of the judgment. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.