US v. Bisheem Jones
Split Score
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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.
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
§ 2K2.1(b)(4)(B) applies when the serial number is partially obliterated or simply less legible.
§ 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.