Case Explained: UNITED STATES OF AMERICA v. TEVON O’SHEA VANHORN

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-06 The Fourth Circuit affirmed Tevon O’Shea Vanhorn’s conviction and sentence for conspiracy to distribute methamphetamine and fentanyl in violation of 21 U.S.C. § 846. The court applied the “plain error” standard of review because Vanhorn failed to move to withdraw his guilty plea or challenge the factual basis in the district court, requiring him to demonstrate an error that was plain, affected substantial rights, and seriously affected the fairness or integrity of judicial proceedings. Regarding the guilty plea, the court held that the district court did not err in finding a sufficient factual basis under Rule 11(b)(3), as the record supported Vanhorn’s knowing participation in the conspiracy through his admissions, intercepted communications, and evidence of drug seizures. Concerning the sentencing, the court reviewed the application of the two-level “premises enhancement” under U.S.S.G. § 2D1.1(b)(12) for clear error and legal conclusions de novo, concluding that the district court’s finding that Vanhorn stored narcotics and directed transactions at a mobile home was supported by sufficient evidence from the Pre-Sentence Investigation Report, surveillance, and intercepted calls. Consequently, the appellate court rejected all of Vanhorn’s claims and affirmed the judgment without oral argument. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.