United States v. Daniel Mace, 19-4587

Daniel Roy Mace was convicted after a jury trial of 12 counts of receipt of child pornography, 1 count of distribution, 1 count of possession of child pornography, and 1 count of witness tampering.
Appellate counsel filed an Anders brief asserting no meritorious appeal issues but questioned whether the district court erred in denying severance of the witness tampering count; Mace did not file a pro se brief.
The government argued joinder was proper because the tampering count was logically related to the child‑pornography counts; district court denied severance.
Legal standards applied: Federal Rule of Criminal Procedure 8(a) permits broad joinder where offenses are logically related; Rule 14 permits severance only upon a strong showing of prejudice that would impair a specific trial right or jury reliability.
Mace argued he might wish to testify on the tampering count but not the child‑pornography counts, but he never proffered what his testimony would be or why it was necessary.
The Fourth Circuit held joinder was proper and affirmed the denial of severance because Mace failed to make the required strong showing of prejudice; the court reviewed the record under Anders and found no meritorious grounds for appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by denying Mace's motion to sever the witness‑tampering count from the child‑pornography counts	Joinder proper; tampering logically related to other counts; no prejudice	Severance required because Mace might want to testify on tampering but not on other counts, risking prejudice	Denial affirmed: Rule 8 joinder permissible; under Rule 14 Mace failed to show strong prejudice or to proffer the limiting testimony he claimed; speculative desire to testify insufficient

United States v. Cannady, 924 F.3d 94 (4th Cir. 2019) (Rule 8 permits broad joinder at pleading stage)
United States v. Mouzone, 687 F.3d 207 (4th Cir. 2012) (joined offenses need a logical relationship)
United States v. Campbell, 963 F.3d 309 (4th Cir. 2020) (defendant bears burden to show strong prejudice to obtain severance)
United States v. Qazah, 810 F.3d 879 (4th Cir. 2015) (severance warranted only if joint trial would compromise specific trial right or jury reliability)
United States v. Zelaya, 908 F.3d 920 (4th Cir. 2018) (abuse of discretion standard for reviewing severance denials)
United States v. Monteiro, 871 F.3d 99 (1st Cir. 2017) (to justify severance for limited testimony, defendant must show important testimony on one count and strong need to refrain on others)
Anders v. California, 386 U.S. 738 (1967) (procedures for counsel to follow when concluding an appeal is frivolous)