United States v. Stanley Partman, 568 F. App'x 205

Stanley Partman was a Columbia, SC drug trafficker (1996–2011) indicted in 2011 on multiple drug counts and a § 924(c) charge for possession of a firearm in furtherance of drug trafficking.
FBI wiretap of a coconspirator recorded calls in which Partman admitted possessing firearms and said he intended to find and shoot Rondeal Woods over bad cocaine; no firearm was recovered and no witness saw him armed during the charged events.
At jury selection Partman appeared wearing detention-issued pants and slippers (he wore a civilian shirt provided by counsel); he did not object at that time and moved to disqualify the jury nearly a month later on the eve of trial.
During trial Partman repeatedly interrupted and addressed the jury despite warnings, was removed from the courtroom, and was convicted on all counts, including § 924(c).
Post-conviction, Partman refused to cooperate with a competency reassessment; the court found him competent and applied a two-level obstruction-of-justice enhancement at sentencing.
The district court imposed a 396‑month sentence (including a mandatory consecutive 60 months under § 924(c)); Partman appealed denial of a new trial, denial of acquittal, and the obstruction enhancement.

Issue	Partman’s Argument	Government’s Argument	Held
Whether jury must be disqualified because Partman appeared in jail clothing at voir dire	Clothing prejudiced jurors; one juror recalled attire specifically and should have been excused	Partman waived objection by not objecting at voir dire; no state compulsion to wear jail clothes so no Estelle violation	District court did not abuse discretion; no error in denying new trial
Sufficiency of evidence for § 924(c) possession-in-furtherance conviction	Evidence insufficient because no firearm was recovered, no eyewitness of possession, and Lomax factors were not established	Admissions, wiretaps, and coconspirator testimony showed possession and a nexus to violent conduct advancing drug trafficking	Evidence sufficient under Jackson standard; conviction affirmed
Whether Lomax factors are required when firearm not recovered	Argues failure to prove Lomax factors defeats nexus showing	Lomax factors are illustrative, not exhaustive; possession can be proved circumstantially without seizure	Court held Lomax factors need not be shown in every case; conviction may rest on admissions and recordings
Appropriateness of two-level obstruction enhancement at sentencing	Enhancement unwarranted because disruptions were minor and not willful malingering	Facts supported enhancement; any procedural error is harmless because court said it would impose same sentence absent enhancement	Even assuming error, it was harmless; sentence upheld as reasonable

Estelle v. Williams, 425 U.S. 501 (1976) (prohibits compelled trial in jail attire; burden on defendant to object when represented)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
Lomax v. United States, 293 F.3d 701 (4th Cir. 2002) (non-exhaustive factors for determining nexus between firearm possession and drug trafficking)
Jeffers v. United States, 570 F.3d 557 (4th Cir. 2009) (possession conviction may be sustained without recovery of the firearm)
Bonner v. United States, 648 F.3d 209 (4th Cir. 2011) (circumstantial evidence and credibility determinations for § 924(c) convictions)
Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion standard for reviewing sentence reasonableness)
United States v. Hargrove, 701 F.3d 156 (4th Cir. 2012) (harmlessness review of sentencing errors)