The U.S. Court of Appeals for the Fourth Circuit issued a mixed ruling in *United States v. Travis Lamar Smith*, dismissing part of the defendant's appeal while affirming other aspects of his conviction for child exploitation charges. The unpublished per curiam opinion was decided Jan. 26, 2026, just four days after submission.
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), and (e). The U.S. District Court for the Eastern District of North Carolina sentenced him to 151 months in prison.
The case involved two consolidated appeals, numbered 25-4100 and 25-4292, both filed by Smith challenging different aspects of his conviction and sentencing. Chief District Judge Richard E. Myers II presided over the original case in the Eastern District of North Carolina at Raleigh.
On appeal, Smith's counsel filed a brief pursuant to *Anders v. California*, 386 U.S. 738 (1967). An Anders brief is typically filed when defense counsel believes an appeal lacks merit but wants the court to independently review the case to ensure no viable issues exist. This procedural move suggests Smith's attorney found no strong grounds for appeal after reviewing the record.
The three-judge panel consisting of Circuit Judges Agee, Richardson, and Heytens reviewed the consolidated appeals. The court's decision to dismiss part of the appeal while affirming other portions indicates the panel found some arguments without merit while upholding the underlying conviction and sentence.
The charges against Smith fall under federal statutes targeting the sexual exploitation of children. Section 2422(b) of Title 18 criminalizes using interstate commerce, including the internet, to persuade or entice minors to engage in illegal sexual activity. Section 2251 addresses the sexual exploitation of children and carries severe penalties, particularly when the offense involves a minor under 12 years of age.
Federal sentences for child exploitation crimes are typically lengthy, reflecting Congress's intent to deter such conduct and protect vulnerable victims. Smith's 151-month sentence equals approximately 12 and a half years in prison. Federal inmates must serve at least 85% of their sentence under current law, meaning Smith will likely serve more than 10 years before becoming eligible for release.
The court's decision was rendered as an unpublished opinion, which means it will not serve as binding precedent within the Fourth Circuit. Unpublished opinions are typically reserved for cases that do not establish new legal principles or significantly clarify existing law. The designation suggests the court viewed Smith's case as applying settled legal principles rather than breaking new ground.
The rapid turnaround from submission to decision also indicates the case presented relatively straightforward legal issues. Complex appeals involving novel questions of law or conflicting precedent typically require longer deliberation periods. The four-day timeframe suggests the panel quickly determined the merits of Smith's arguments.
Smith was represented on appeal by Ryan M. Prescott of Prescott Law, PLLC, based in Winterville, Georgia. The government was represented by Assistant United States Attorneys Lucy Partain Brown and Kristine L. Fritz from the U.S. Attorney's Office in Raleigh, North Carolina.
The consolidation of two separate appeal numbers suggests Smith may have filed multiple post-conviction motions or appeals addressing different aspects of his case. Courts routinely consolidate related appeals to promote judicial efficiency and ensure consistent outcomes on related issues.
Child exploitation prosecutions have become a priority for federal law enforcement agencies, with the FBI and U.S. Attorney's offices dedicating significant resources to investigating and prosecuting such crimes. These cases often involve sophisticated digital evidence collection and coordination between federal, state, and local authorities.
The Eastern District of North Carolina has been active in prosecuting internet crimes against children, working closely with the North Carolina State Bureau of Investigation and local law enforcement agencies. The district's location and jurisdiction cover areas with significant military and civilian populations, requiring vigilant enforcement of federal child protection statutes.
Smith's case represents the typical progression of a federal child exploitation prosecution: investigation, charges, plea negotiations, sentencing, and appeal. The guilty plea likely reflected the strength of the government's evidence and the defendant's recognition that proceeding to trial carried significant additional risks.
The Fourth Circuit's mixed ruling suggests that while Smith's conviction and sentence will stand, some procedural or technical arguments raised on appeal lacked sufficient merit to warrant reversal. The court's decision provides closure for this case while maintaining the integrity of federal child protection prosecutions in the circuit.