Case Explained: UNITED STATES OF AMERICA v. CHARAY LAMONT TRENT

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-02

The Fourth Circuit affirmed Charay Lamont Trent’s convictions and 87-month sentence for conspiracy to distribute cocaine and marijuana, distributing cocaine, possessing cocaine with intent to distribute, and possessing a firearm in furtherance of a drug trafficking crime. The court applied the plain error standard to Trent’s constitutional challenge under the Second Amendment regarding his conviction under 18 U.S.C. § 924(c), noting that he failed to raise this argument in the district court. The court held that Trent could not demonstrate an error that is plain and affects his substantial rights, citing precedent establishing that § 924(c) does not prohibit conduct within the Second Amendment’s scope and that restrictions on firearm possession by non-law-abiding citizens are presumptively lawful. Regarding sufficiency of the evidence for the firearm count, the court applied de novo review and found that viewing the evidence in the light most favorable to the prosecution, a reasonable factfinder could conclude there was a sufficiently close nexus between the handgun and the drug trafficking crime based on factors including the weapon’s proximity to drugs, its loaded status, and Trent’s admission that he kept it for protection against theft of his drugs. The court also denied Trent’s pro se motions for new counsel, digital media, and extensions to file evidence, while granting a limited extension for his pro se brief. As part of the *Anders v. California* procedure, the court found no meritorious grounds for appeal after a thorough record review and ordered appointed counsel to inform Trent of his right to petition the Supreme Court for further review.

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