Case Explained: UNITED STATES OF AMERICA Plaintiff – v. SHRONDA COVINGTON Defendant –

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-02

The Fourth Circuit affirmed the defendants’ convictions for making false statements to federal investigators under 18 U.S.C. § 1001 but vacated Shronda Covington’s conviction for violating a prisoner’s constitutional rights under 18 U.S.C. § 242 and remanded both defendants for resentencing. Regarding the § 242 conviction, the court held that the statutory phrase “bodily injury… results from” a violation requires proof of both but-for causation and proximate cause, aligning with the interpretation applied to the closely related statute 18 U.S.C. § 241. While the evidence was sufficient to support a finding that Covington’s conduct caused bodily injury under this standard, the district court committed reversible error by refusing to instruct the jury on the proximate-cause requirement. The government failed to demonstrate that this instructional error was harmless beyond a reasonable doubt because the record contained evidence that could rationally lead a jury to find that the injuries were not foreseeable to Covington after she left the facility. Consequently, Covington’s § 242 conviction is vacated and remanded for further proceedings. Regarding sentencing, the court vacated Tonya Farley’s sentence because the district court erred in calculating her offense level under the United States Sentencing Guidelines. The district court improperly considered conduct from January 9, 2021, as “relevant conduct” to enhance her sentence for a false statement conviction committed in April 2023. The court clarified that under U.S.S.G. § 1B1.3(a)(1), relevant conduct must occur during the commission of the offense, in preparation for it, or in the course of attempting to avoid detection. Because the district court failed to apply this temporal requirement and did not explain how the January 9 conduct fit within the statutory definition, the sentence was procedurally unreasonable. The case is remanded for resentencing with instructions to properly determine whether the prior conduct qualifies as relevant conduct under the Guidelines.

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