Case Explained: UNITED STATES OF AMERICA v. PRICE JAVON PATTERSON

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-29 The Fourth Circuit affirmed Price Javon Patterson’s conviction and sentence of 188 months’ imprisonment and four years of supervised release for possession with intent to distribute fentanyl. The court rejected Patterson’s ineffective assistance of counsel claim, ruling that because the record did not conclusively establish such deficiency on its face, the issue must be raised in a 28 U.S.C. § 2255 motion rather than on direct appeal. Regarding the substantive and procedural reasonableness of the sentence under 18 U.S.C. § 3553(a), the court applied an abuse-of-discretion standard and found no error. The court held that Patterson’s prior state convictions properly qualified as career offender predicates, clarifying that his Pennsylvania aggravated assault conviction required more than recklessness to satisfy the crime of violence definition under *Borden v. United States*, and that his West Virginia synthetic marijuana conviction remained a controlled substance offense despite *United States v. Campbell*. Additionally, the court determined that the district court correctly applied two-level sentencing enhancements for uncharged conduct involving a dangerous weapon and maintaining a premises for drug distribution, as the government proved this conduct by a preponderance of the evidence. The court also rejected Patterson’s argument regarding the applicable Guidelines version, confirming he was sentenced under the 2021 Guidelines. Following an *Anders v. California* review, the court found no meritorious grounds for appeal and ordered counsel to inform Patterson of his right to petition the Supreme Court for further review. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.