United States v. Amin Harris, 708 F. App'x 764

Amin Jamaal Harris was convicted by a jury of drug and firearm offenses: conspiracy to distribute marijuana and cocaine, distribution/possession with intent for marijuana and cocaine, and being a felon in possession of firearms/ammunition; acquitted of witness tampering.
The district court sentenced Harris to 360 months’ imprisonment; Harris appealed challenging pretrial rulings and sufficiency of evidence on two counts.
Harris moved to dismiss Counts 1–4 and to suppress certain statements; the district court denied those motions after evidentiary hearing.
Harris moved to sever the firearm counts (Counts 4 and 8), arguing his felony status would prejudice the jury on the drug charges; the court denied severance after a stipulation and limiting instruction.
On sufficiency review Harris argued witness credibility and contested counts: (1) that the cocaine conspiracy did not involve 500+ grams, and (2) that Count 8 failed because the firearm’s operability was not shown.
The Fourth Circuit affirmed: pretrial rulings upheld, joinder and denial of severance proper, and evidence sufficient on both Count 2 (500+ grams) and Count 8 (operability not required for § 922(g)(1)).

Issue	Plaintiff's Argument (Harris)	Defendant's Argument (Government)	Held
Whether district court erred in denying motion to dismiss Counts 1–4 and suppress statements	Suppression and dismissal warranted based on factual/legal defects	District court’s findings and legal conclusions support denial	Denial affirmed; factual findings not clearly erroneous; legal rulings reviewed de novo and upheld
Whether firearm counts should be severed from drug counts	Joinder prejudicial because felony-status element unfairly exposed jury to prior convictions	Offenses logically related; evidence colocated and tied to same transactions; stipulation and limiting instruction mitigate prejudice	Joinder proper under Rule 8(a); denial of severance not an abuse of discretion
Sufficiency of evidence that drug conspiracy involved 500+ grams of cocaine (Count 2)	Jury testimony unreliable; evidence insufficient to prove quantity threshold	Evidence supports jury’s finding beyond reasonable doubt	Affirmed; evidence viewed favorably to government meets threshold
Sufficiency of evidence for felon-in-possession conviction (Count 8)	Government failed to prove firearm operable	§ 922(g)(1) does not require firearm operability; possession established	Affirmed; operability not required to convict under § 922(g)(1)

United States v. Hosford, 843 F.3d 161 (4th Cir.) (standard of review for motions to dismiss indictments)
United States v. Hill, 852 F.3d 377 (4th Cir.) (standard of review for suppression rulings)
United States v. Palmer, 820 F.3d 640 (4th Cir.) (deference to credibility findings at suppression hearings)
United States v. Cardwell, 433 F.3d 378 (4th Cir.) (Rule 8(a) joinder requires logical relationship)
United States v. Hawkins, 776 F.3d 200 (4th Cir.) (joinder is the rule; related offenses often tried together)
United States v. Hornsby, 666 F.3d 296 (4th Cir.) (severance is rare when joinder proper)
United States v. Blair, 661 F.3d 755 (4th Cir.) (standard for demonstrating prejudice under Rule 14)
United States v. Engle, 676 F.3d 405 (4th Cir.) (standard of review for sufficiency of the evidence)
United States v. Sterling, 860 F.3d 233 (4th Cir.) (burden on defendant challenging sufficiency)
United States v. Adams, 814 F.3d 178 (4th Cir.) (elements of § 922(g)(1) possession offense)
United States v. Williams, 445 F.3d 724 (4th Cir.) (§ 922(g)(1) does not require firearm operability)