United States v. Christopher Wigfall, 18-4611

Christopher Wigfall was convicted by a jury of two counts of distributing heroin and one count of possession with intent to distribute in violation of 21 U.S.C. § 841.
The district court designated Wigfall a career offender under U.S.S.G. § 4B1.1 based on prior Maryland felony convictions and sentenced him to 210 months’ imprisonment (bottom of the Guidelines range).
Appellate counsel filed an Anders brief asserting no meritorious issues but raising three questions: a Batson challenge to a government peremptory strike, career-offender designation, and reasonableness of the sentence.
The challenged juror was an African-American NAACP local president who had met with the U.S. Attorney’s Office regarding a police shooting and whose son had been convicted in the same district; the Government cited those two facts as nondiscriminatory reasons to strike him.
The district court credited the Government’s explanations and denied the Batson challenge; it also calculated the Guidelines and explained its sentence, finding the within-Guidelines term reasonable.

Issue	Plaintiff's Argument (Wigfall)	Defendant's Argument (Government)	Held
Batson challenge to peremptory strike	Strike was racially motivated because juror was African-American	Strike was for nondiscriminatory reasons: juror’s NAACP role/contact with US Attorney’s Office and son’s conviction in same court	Denied—district court’s finding that reasons were nondiscriminatory not clearly erroneous
Career-offender designation under U.S.S.G. § 4B1.1	Prior Maryland convictions should not qualify to raise him to career-offender status	Prior convictions qualified; Guidelines application was correct	Affirmed—court properly calculated Guidelines
Reasonableness of sentence	210 months is substantively unreasonable given mitigation and rehabilitation efforts	Sentence is within properly calculated Guidelines and was adequately explained	Affirmed—within-Guidelines sentence is presumptively reasonable
Anders procedure / appellate review	Counsel filed Anders brief but raised issues; Wigfall submitted pro se supplemental brief	Government urged affirmance; court reviewed record	Affirmed—court conducted full Anders review and found no meritorious claims

Anders v. California, 386 U.S. 738 (1967) (procedures for counsel to withdraw when appeal is frivolous)
Batson v. Kentucky, 476 U.S. 79 (1986) (establishes framework for challenging peremptory strikes as racially motivated)
United States v. Walker, 922 F.3d 239 (4th Cir. 2019) (standard of review and Batson burdens)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of reasonableness for within-Guidelines sentences)