Case Explained: UNITED STATES OF AMERICA v. RAY COZART, JR

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-23 The Fourth Circuit dismissed in part and affirmed in part Ray Cozart, Jr.’s appeal from his conviction for conspiracy to distribute fentanyl and methamphetamine and his 144-month sentence. The court held that while Cozart’s appellate waiver did not bar a colorable challenge to the validity of his guilty plea, the plea was valid under Federal Rule of Criminal Procedure 11 because it was knowing, voluntary, and supported by an adequate factual basis, reviewed for plain error given the lack of objection at the district court level. The court further determined that Cozart’s appeal waiver was enforceable under a totality-of-the-circumstances standard, finding he knowingly and voluntarily waived his right to appeal based on the Rule 11 colloquy and record evidence. Consequently, the court granted the Government’s motion to dismiss the portion of the appeal challenging the reasonableness of the sentence, as that issue fell squarely within the scope of the valid waiver, and affirmed the conviction and sentence for all other issues after an *Anders* review found no meritorious grounds for appeal outside the waiver. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.