The U.S. Court of Appeals for the Fourth Circuit issued an unpublished per curiam opinion on Jan. 26, 2026, dismissing in part and affirming in part the conviction of Michael Joseph Knox, also known as Melo or Mello, in a federal criminal case involving carjacking and conspiracy charges.
Knox pled guilty pursuant to a written plea agreement to conspiracy to commit offenses against the United States in violation of 18 U.S.C. § 371. He also pled guilty to carjacking in violation of 18 U.S.C. §§ 2, 2119, and three counts of interfering with federally protected activities in violation of 18 U.S.C. §§ 2, 245(b)(2)(F). Additionally, Knox pled guilty to two counts of brandishing a firearm in furtherance of a crime of violence in violation of 18 U.S.C. §§ 2, 924(c)(1)(A)(ii).
The U.S. District Court for the District of South Carolina at Columbia, presided over by District Judge Sherri A. Lydon, sentenced Knox to 303 months' imprisonment. The original case was filed as 3:23-cr-00484-SAL-2, indicating the charges were brought in 2023.
The Fourth Circuit appeal was submitted on Jan. 22, 2026, and decided just four days later on Jan. 26, 2026. The three-judge panel consisted of Circuit Judges Agee, Richardson, and Heytens. The expedited timeline suggests the appeal may have involved routine procedural matters or issues that did not require extensive deliberation.
Knox's counsel, Mario A. Pacella of the Strom Law Firm in Columbia, South Carolina, filed a brief pursuant to Anders v. California, a 1967 Supreme Court case that established procedures for court-appointed counsel who believe an appeal lacks merit. Under Anders, counsel must file a brief identifying any potentially arguable issues while stating that the appeal appears to be frivolous. The court then independently reviews the case to determine whether any non-frivolous issues exist.
The government was represented by Assistant United States Attorney Benjamin Neale Garner from the Office of the United States Attorney in Columbia, South Carolina. The case demonstrates federal prosecutors' continued focus on violent crimes involving firearms and interference with federally protected activities.
The charges Knox faced carry significant penalties under federal law. Conspiracy to commit federal offenses under 18 U.S.C. § 371 carries a maximum penalty of five years imprisonment. Carjacking under 18 U.S.C. § 2119 is punishable by up to 15 years imprisonment, or up to 25 years if serious bodily injury results. The interference with federally protected activities charges under 18 U.S.C. § 245(b)(2)(F) can result in up to 10 years imprisonment.
Most significantly, the firearm charges under 18 U.S.C. § 924(c)(1)(A)(ii) for brandishing a firearm in furtherance of a crime of violence carry a mandatory minimum sentence of seven years imprisonment for each count, to be served consecutively to any other sentence. With two such counts, Knox faced at least 14 years in prison for the firearm charges alone, which helps explain the substantial 303-month (approximately 25-year) total sentence.
The Fourth Circuit's decision was issued as an unpublished per curiam opinion, meaning it was decided unanimously by the panel without a single judge taking primary authorship. Unpublished opinions do not serve as binding precedent within the Fourth Circuit, though they may have persuasive value in similar cases.
The partial dismissal and partial affirmance suggests that while some aspects of Knox's appeal may have had merit, the core conviction and sentence were upheld. Without access to the full opinion text, the specific grounds for the partial dismissal remain unclear, but such outcomes often involve procedural issues, jurisdictional questions, or challenges to specific aspects of sentencing while the underlying conviction stands.
The case reflects federal law enforcement's ongoing efforts to prosecute violent crimes that cross state lines or involve federal jurisdictions. Carjacking cases often fall under federal jurisdiction when they affect interstate commerce or involve vehicles that have crossed state lines. The interference with federally protected activities charges suggest the crimes may have involved civil rights violations or targeted individuals based on protected characteristics.
The rapid resolution of Knox's appeal, combined with the Anders brief filing, indicates that his counsel likely concluded after reviewing the record that no substantial arguments existed for overturning the conviction or significantly reducing the sentence. Federal guilty pleas typically waive most appellate rights except for challenges to the voluntariness of the plea or the legality of the sentence.
This case demonstrates the severe consequences defendants face when charged with multiple federal violent crimes, particularly when firearms are involved. The 303-month sentence reflects both the seriousness of the charges and the enhanced penalties that apply when firearms are used in furtherance of federal crimes of violence.