United States v. Rodney Lewis, 20-4530

Rodney Latrell Lewis pleaded guilty to distribution of 50+ grams of methamphetamine and to possessing a firearm in furtherance of a drug-trafficking offense.
The district court sentenced Lewis to 195 months’ imprisonment and 5 years’ supervised release.
The written judgment included several discretionary supervised-release conditions that were not announced at the sentencing hearing; two disputed conditions related to Lewis’ finances.
Lewis appealed, challenging (1) an offense-level obstruction-of-justice enhancement under the Sentencing Guidelines and (2) the inclusion of unpronounced supervised-release conditions in the written judgment.
The Government moved to remand in part and dismiss in part, conceding the supervised-release pronouncement error but arguing Lewis’ appellate waiver bars his Guidelines challenge.
The Fourth Circuit concluded the district court failed to orally pronounce nonmandatory supervised-release conditions (and did not incorporate them at sentencing), vacated the sentence, and remanded for resentencing without deciding the waiver issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether discretionary supervised-release conditions included in the written judgment but not pronounced at sentencing are valid	Lewis: conditions were not pronounced or incorporated by reference and therefore invalid	Government: conceded the court failed to properly pronounce conditions (moved to remand)	Court: vacated sentence and remanded for resentencing because nonmandatory conditions must be pronounced in open court
Whether Lewis’ appellate waiver bars his challenge to the Guidelines obstruction enhancement	Lewis: challenges the obstruction enhancement	Government: argues the plea waiver bars this challenge and asked dismissal of that claim	Court: declined to reach waiver issue because the supervisory-release error required vacatur and remand

United States v. Singletary, 984 F.3d 341 (4th Cir. 2021) (requires oral pronouncement in open court for nonmandatory supervised-release conditions; vacatur and remand if omitted)
United States v. Rogers, 961 F.3d 291 (4th Cir. 2020) (district court may incorporate conditions by reference at sentencing, but incorporation must occur on the record)