US v. Bisheem Jones

Circuit 4Jul 21, 2026

Split Score

SplitScore: 33/100

Case Summary

Disposition

Affirmed in Part

The Fourth Circuit vacated Bisheem Jones’s conviction for conspiracy to commit promotional money laundering, finding the Government failed to prove an agreement to reinvest illicit proceeds, but it affirmed the firearm-trafficking–related convictions and most sentencing enhancements. The panel therefore affirmed in part, vacated in part, and remanded for resentencing on the remaining counts.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether Sentencing Guideline § 2K2.1(b)(4)(B) applies when a firearm’s serial number is only partially obliterated or ‘less legible,’ rather than completely illegible.

Circuit Positions

Circuit 4(this circuit)

§ 2K2.1(b)(4)(B) applies when the serial number is partially obliterated or simply less legible.

Circuit 2

§ 2K2.1(b)(4)(B) applies only when the serial number is completely illegible or unrecognizable.

Conflict Summary

The Fourth Circuit (pre-2024) interpreted the enhancement to cover firearms whose serial numbers were merely less legible or partially obliterated, while the Second Circuit limited the enhancement to situations where the serial number is totally illegible or unrecognizable to the unaided eye.

Parties & Counsel

Parties

Appellant:Bisheem Jones
Appellee:United States of America

Legal Counsel

Appellant:Office of the Federal Public Defender (Jenny R. Thoma); Holroyd & Yost (Brian D. Yost)
Appellee:Office of the United States Attorney, S.D. W. Va. (Lesley S. Shamblin; William S. Thompson; William E. Longwell)