US v. Weldon Jackson

4th CircuitSep 3, 2025

Split Score

SplitScore: 40/100

Case Summary

Disposition

Affirmed

The Fourth Circuit affirmed the district court’s denial of Weldon Motic Jackson’s motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The court held that any sentencing disparity caused by a difference between Fourth and Second Circuit law on career-offender predicates did not amount to an extraordinary and compelling reason warranting sentence reduction.

Circuit Split Identified

Legal Issue

Whether the defendant’s prior conviction qualifies as a predicate offense that triggers the career-offender enhancement under U.S.S.G. § 4B1.1.

Circuit Positions

4th Circuit(this circuit)

Prior conviction qualifies as a career-offender predicate under U.S.S.G. § 4B1.1.

2nd Circuit

Prior conviction does not qualify as a career-offender predicate under U.S.S.G. § 4B1.1.

Conflict Summary

The Fourth Circuit treats the prior conviction at issue as a qualifying predicate for the Sentencing Guidelines’ career-offender enhancement, whereas the Second Circuit holds that the same conviction does not qualify, leading to disparate sentencing outcomes.

Parties & Counsel

Parties

Appellant:Weldon Motic Jackson
Appellee:United States of America

Legal Counsel

Appellant:Pro se

Opinion Document