United States v. Jarvis Jackson, 127 F.4th 448

Jarvis Mikel Jackson pled guilty to possession of a firearm as a felon under 18 U.S.C. § 922(g)(1).
At sentencing, the district court used two prior South Carolina drug distribution convictions to enhance Jackson’s base offense level, classifying them as "controlled substance offenses" under the federal Sentencing Guidelines.
Jackson previously appealed the use of these convictions based on arguments grounded in United States v. Campbell, which limited what state offenses qualify as predicate controlled substance offenses.
The Fourth Circuit initially sided with Jackson, but after remand, new published opinions (Groves and Davis) clarified that South Carolina’s law does qualify as a controlled substance offense for Guidelines purposes.
Upon resentencing, the district court again sentenced Jackson to 115 months but provided only minimal explanation for the sentencing decision and did not individually address Jackson's request for a lower sentence based on his rehabilitation.
Jackson appealed again, arguing both the Guidelines calculation and lack of sentencing explanation were in error.

Issue	Jackson's Argument	Government's Argument	Held
Whether prior South Carolina drug distribution convictions are "controlled substance offenses" under the Guidelines	South Carolina law is materially indistinguishable from West Virginia law in Campbell, so convictions should not enhance Guidelines range	Davis controls, holding the South Carolina statute is materially different from Campbell and does count as a Guidelines predicate	Davis controls; convictions qualify as predicates
Whether the district court provided an adequate explanation for the sentence and addressed arguments for a downward variance	Court failed to address individualized arguments (rehabilitation, post-sentencing conduct) and did not sufficiently explain sentence	Court heard arguments and incorporated record, which was sufficient	Explanation was inadequate; procedural error found

United States v. Campbell, 22 F.4th 438 (4th Cir. 2022) (initially held broad state drug laws not qualifying under Guidelines' controlled substance offense definition)
United States v. Groves, 65 F.4th 166 (4th Cir. 2023) (clarified federal definition of “attempted transfer” in controlled substances law)
United States v. Davis, 75 F.4th 428 (4th Cir. 2023) (held South Carolina drug distribution conviction is a controlled substance offense per Guidelines)
United States v. Ross, 912 F.3d 740 (4th Cir. 2019) (legal standard for procedural reasonableness of sentencing)
Gall v. United States, 552 U.S. 38 (2007) (standard for review of sentencing; requires individualized assessment and explanation)