The U.S. Court of Appeals for the Fourth Circuit affirmed the conviction of Jack F. Gibbins III for possession with intent to distribute methamphetamine, rejecting his appeal challenging the admissibility of drug evidence discovered at a hospital.
In an unpublished per curiam opinion filed Jan. 21, 2026, a three-judge panel consisting of Circuit Judges King, Richardson, and Benjamin upheld the lower court's ruling in *United States v. Gibbins* (4th Cir. 2026). The case originated from the U.S. District Court for the Northern District of West Virginia in Clarksburg, where Chief District Judge Thomas S. Kleeh presided.
Gibbins entered a conditional guilty plea to one count of possession with intent to distribute methamphetamine under 21 U.S.C. §§ 841(a)(1) and (b)(1)(C). The conditional nature of the plea allowed him to preserve his right to appeal the district court's denial of his motion to suppress evidence.
The central issue in the case involved drug evidence discovered in Gibbins' pants while he was receiving medical treatment at a hospital following an attempted traffic stop. Gibbins sought to suppress this evidence, arguing it was obtained in violation of his Fourth Amendment rights, which protect against unreasonable searches and seizures.
The district court initially referred the suppression motion to a magistrate judge for review and recommendation. After considering the evidence and testimony, the magistrate judge concluded that the drug evidence should be admitted under the inevitable discovery doctrine. This legal principle allows evidence to be used at trial if prosecutors can demonstrate they would have inevitably discovered it through lawful means, even if it was initially obtained illegally.
Chief Judge Kleeh accepted the magistrate judge's recommendation and denied Gibbins' suppression motion. The inevitable discovery doctrine served as the basis for allowing the evidence to be presented at trial, despite Gibbins' constitutional challenges.
On appeal, Gibbins raised a procedural argument regarding how the district court handled witness credibility determinations. He contended that the district court erred by making independent findings about witness credibility that differed from those made by the magistrate judge, without conducting a separate evidentiary hearing.
This procedural challenge highlighted an important aspect of federal court practice. When district judges review magistrate judge recommendations on dispositive motions like suppression motions, they must conduct de novo review. However, questions arise about how courts should handle situations where credibility assessments differ between the magistrate judge who heard live testimony and the district judge reviewing the written record.
Gibbins argued that when a district judge disagrees with a magistrate judge's credibility findings, due process requires holding a new evidentiary hearing where the district judge can directly observe witness testimony and demeanor. This ensures that credibility determinations are based on firsthand observation rather than cold record review.
The Fourth Circuit panel rejected this argument and affirmed the conviction. The appeals court found no error in the district court's handling of the suppression motion or its adoption of the inevitable discovery analysis. The opinion does not elaborate on the specific factual circumstances surrounding the hospital search or the traffic stop that preceded it.
Elizabeth B. Gross of the Federal Public Defender's Office in Clarksburg represented Gibbins on appeal. The government was represented by Acting U.S. Attorney Randolph J. Bernard and Assistant U.S. Attorney Maximillian F. Nogay from the U.S. Attorney's Office in Wheeling, West Virginia.
The case was submitted to the Fourth Circuit on Nov. 13, 2025, and decided approximately two months later. The relatively quick turnaround reflects the straightforward nature of the legal issues presented.
As an unpublished opinion, the decision does not establish binding precedent within the Fourth Circuit. However, it demonstrates the continued application of the inevitable discovery doctrine in drug cases and addresses procedural questions about magistrate judge recommendations in suppression contexts.
The inevitable discovery doctrine remains a significant tool for prosecutors in cases where evidence may have been obtained through questionable means. Courts applying this doctrine must determine whether law enforcement would have found the evidence through legitimate investigative methods, regardless of any constitutional violations that may have occurred.
This case also illustrates the strategic value of conditional guilty pleas in federal criminal practice. By entering such a plea, defendants can resolve their cases while preserving specific legal challenges for appellate review. This approach allows defendants to avoid the risks of trial while maintaining the ability to challenge adverse rulings on constitutional grounds.
The affirmance means Gibbins' conviction and sentence remain in effect, and his constitutional challenge to the search and seizure has been definitively rejected by the federal appellate court.