United States v. Charles York Walker, Jr., 922 F.3d 239

Walker was investigated after multiple controlled buys (April–July 2016) and arrested with small amounts of drugs; search of an associate’s apartment recovered two handguns, ammunition, scales, and a cell phone with photos of Walker holding a .45 pistol.
A grand jury indicted Walker on drug distribution counts (heroin and fentanyl) and one count of possession of firearms by a convicted felon (18 U.S.C. § 922(g)(1)).
Walker initially entered a Rule 11 plea agreement (guilty to a single heroin possession-with-intent charge) that the district court accepted tentatively pending the PSR; after reviewing the PSR the court rejected the plea agreement and permitted Walker to withdraw his plea.
Walker later pleaded guilty without an agreement to three drug counts; the firearms count proceeded to trial and a jury convicted Walker of possessing two handguns as a felon.
Walker objected at trial to the prosecution’s peremptory strike of the only African-American venireperson (Batson challenge); the district court accepted a race-neutral explanation and overruled the objection.
At sentencing the PSR applied enhancements (including a 2-level stolen-firearm enhancement based on an NCIC report); the district court adopted the PSR, imposed a Guidelines range of 110–137 months, and sentenced Walker to 120 months (stating it would have imposed the same sentence regardless of the Guidelines range).

Issue	Walker's Argument	Government's Argument	Held
Whether the district court abused its discretion by rejecting Walker’s plea agreement	Court applied a vague, categorical policy disfavouring plea bargains and interfered with prosecutorial prerogatives	Government does not defend the plea; it concedes the court’s rejection was permissible here	No abuse: court grounded rejection in case-specific factors (criminal history, violence, opioid-crisis public interest), not an improper blanket policy
Whether the prosecutor’s peremptory strike of juror No. 22 violated Batson	Strike was pretextual; juror No. 22 was the only African‑American and similar white jurors were seated	Provided race-neutral reasons (marital status, age, children); comparators differed on those factors	No clear error: reasons were facially race-neutral and comparators were not similarly situated, so Walker failed to show pretext
Whether the stolen-firearm (§2K2.1(b)(4)(A)) enhancement was supported by sufficient evidence	NCIC report alone is insufficient to prove the firearm was stolen	NCIC reports are generally reliable; PSR relied on NCIC and defendant offered no evidence to dispute it	No error: NCIC-based PSR was not challenged with contrary evidence, so the court permissibly applied the enhancement

Batson v. Kentucky, 476 U.S. 79 (prohibits race-based peremptory strikes)
United States v. Jackson, 563 F.2d 1145 (district courts have discretion over plea-bargaining practices)
In re Morgan, 506 F.3d 705 (court must consider plea bargains individually; rejection must be case‑specific)
United States v. Dinkins, 691 F.3d 358 (sets out Batson three-step framework and pretext analysis)
United States v. McDowell, 745 F.3d 115 (discusses reliability and routine use of NCIC reports in sentencing)
Gall v. United States, 552 U.S. 38 (sentence review standard; abuse of discretion for sentencing)