Case Explained: UNITED STATES OF AMERICA v. BOOKER TYRELL HENLEY

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-02

The Fourth Circuit affirmed Booker Tyrell Henley’s convictions for possessing a firearm as a convicted felon (18 U.S.C. § 922(g)(1)), possessing marijuana with intent to distribute (21 U.S.C. § 841(a)(1)), and using/carrying a firearm in relation to a drug trafficking crime (18 U.S.C. § 924(c)(1)(A)(i)), as well as his sentence. The court held that the jury instruction regarding the felon-in-possession count was consistent with *Rehaif v. United States*, and rejected Henley’s duplicity challenge to the firearm charge because he failed to show good cause or plain error for raising the issue for the first time on appeal. Regarding sufficiency of the evidence, the court applied the standard that a verdict must be sustained if any rational trier of fact could have found the essential elements beyond a reasonable doubt, concluding the record supported the jury’s findings. The court further determined the district court did not abuse its discretion in admitting social media evidence under Federal Rules of Evidence 401, 402, 403, 404, and 901, nor did it err in imposing a sentence within the Guidelines range, which is presumptively reasonable. Consequently, Henley’s conviction and sentence remain in effect, and he will serve the imposed term of imprisonment.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.