The U.S. Court of Appeals for the Fourth Circuit has issued a split decision in United States v. Travis Smith, dismissing part of the criminal defendant's appeal while affirming other portions in an unpublished per curiam opinion filed Jan. 26, 2026.
Travis Lamar Smith pleaded guilty pursuant to a written plea agreement to coercion and enticement of a minor to engage in criminal sexual activity, in violation of 18 U.S.C. §§ 2422(b), 2251(a), (e). The U.S. District Court for the Eastern District of North Carolina sentenced Smith to 151 months imprisonment.
The case involved two consolidated appeals, numbered 25-4100 and 25-4292, both arising from the same underlying criminal case in the Eastern District of North Carolina. Chief District Judge Richard E. Myers II presided over the original proceedings in case number 5:23-cr-00369-M-RJ-1.
On appeal, Smith's counsel filed a brief pursuant to Anders v. California, 386 U.S. 738 (1967). The Anders procedure allows defense counsel to withdraw from a case when they believe an appeal lacks merit, but requires the attorney to file a brief identifying any potentially arguable issues and requesting court permission to withdraw.
The Fourth Circuit panel consisting of Circuit Judges Agee, Richardson, and Heytens rendered their decision just four days after the case was submitted on Jan. 22, 2026. This rapid turnaround suggests the court found the legal issues relatively straightforward.
The court's ruling was "dismissed in part and affirmed in part," indicating that while some aspects of Smith's appeal were found to lack merit and were dismissed, other portions of the lower court's judgment were affirmed on their merits. The specific grounds for the dismissal and affirmance were not detailed in the available excerpt of the opinion.
Smith was represented on appeal by Ryan M. Prescott of Prescott Law, PLLC, based in Winterville, Georgia. The government was represented by Assistant U.S. Attorneys Lucy Partain Brown and Kristine L. Fritz from the U.S. Attorney's Office in Raleigh, North Carolina.
The charges against Smith involved serious federal crimes related to the exploitation of minors. Section 2422(b) of Title 18 criminalizes using interstate commerce to persuade, induce, entice, or coerce a minor to engage in criminal sexual activity. The related provisions under Section 2251 address the sexual exploitation of children and carry severe penalties including lengthy prison sentences.
The case originated in the Eastern District of North Carolina's Raleigh division, which covers the central and eastern portions of the state. Federal prosecutors in this district regularly handle cases involving crimes against children and online exploitation.
The Fourth Circuit's decision was issued as an unpublished per curiam opinion, meaning it was decided by the full panel without a single judge authoring the opinion. Unpublished opinions do not carry precedential weight in the Fourth Circuit, as noted in the court's standard disclaimer that "unpublished opinions are not binding precedent in this circuit."
Per curiam opinions are typically used for cases that present straightforward legal issues or where the court wishes to dispose of matters without extensive legal analysis. The brevity of the timeline from submission to decision further suggests this case did not present novel or complex legal questions requiring extended deliberation.
The mixed nature of the ruling - dismissing some issues while affirming others - indicates the appeals court found merit in the government's position on most matters while potentially identifying procedural or jurisdictional issues that warranted dismissal rather than substantive review.
Smith's 151-month sentence, equivalent to approximately 12.5 years, reflects the serious nature of federal crimes involving the exploitation of minors. Federal sentencing guidelines for such offenses typically result in substantial prison terms, particularly when they involve interstate commerce elements that bring cases under federal jurisdiction.
The case demonstrates the federal court system's handling of appeals in criminal cases involving sensitive crimes against children. The Anders procedure utilized by defense counsel provides a mechanism for attorneys to withdraw from appeals they believe lack merit while ensuring defendants' appellate rights are protected through court review of potential issues.
The Fourth Circuit Court of Appeals has jurisdiction over federal appeals from district courts in Maryland, North Carolina, South Carolina, Virginia, and West Virginia. The court regularly addresses criminal appeals involving federal crimes against children, making this case part of ongoing federal law enforcement efforts to combat online exploitation and related offenses.