The U.S. Court of Appeals for the Fourth Circuit issued an unpublished per curiam opinion Tuesday vacating and remanding the conviction of John James Taylor, who had pleaded guilty to federal drug and firearms charges in the Eastern District of North Carolina.
The court's decision in *United States v. John James Taylor* (4th Cir. 2026) represents the second time the appellate court has intervened in Taylor's case. The three-judge panel, consisting of Circuit Judges J. Harvie Wilkinson III and Roger Gregory, along with Senior Circuit Judge Barbara Milano Keenan, issued the ruling following oral arguments submitted December 18, 2025.
Taylor originally pleaded guilty to possession with intent to distribute quantities of cocaine and heroin, violations of 21 U.S.C. § 841(a)(1) and (b)(1)(C), as well as being a felon in possession of a firearm under 18 U.S.C. §§ 922(g)(1) and 924(a)(2). The charges stemmed from a 2018 criminal case prosecuted in the Elizabeth City division of the Eastern District of North Carolina under District Judge Louise W. Flanagan.
The case has a complex procedural history. The Fourth Circuit previously vacated Taylor's original sentence and remanded the matter for resentencing in light of *United States v. Rogers*, 961 F.3d 291 (4th Cir. 2020). Following that earlier remand, the district court sentenced Taylor to 164 months' imprisonment and three years of supervised release.
However, the appellate court's latest decision indicates that issues remain with how the case was handled at the district court level. The court's decision to vacate and remand suggests either procedural errors in sentencing or other legal deficiencies that require correction by the trial court.
The *Rogers* decision, which prompted the initial remand, dealt with sentencing guidelines and their application in drug cases. That 2020 Fourth Circuit ruling established important precedent regarding how certain sentencing enhancements should be applied, particularly in cases involving repeat drug offenses. The fact that Taylor's case required a second intervention by the appellate court suggests ongoing complications in applying these sentencing principles.
Taylor was represented by the Federal Public Defender's Office, with G. Alan DuBois serving as the Federal Public Defender and Andrew DeSimone as Assistant Federal Public Defender handling the appeal. The government's case was prosecuted by the U.S. Attorney's Office for the Eastern District of North Carolina, led by U.S. Attorney Michael F. Easley Jr., with Assistant U.S. Attorneys David A. Bragdon and Lucy Partain Brown handling the appellate proceedings.
The opinion was issued as an unpublished decision, which means it carries no binding precedential value for future cases in the Fourth Circuit. Unpublished opinions are typically used for cases that do not establish new legal principles or involve routine applications of existing law. The court specifically noted that "unpublished opinions are not binding precedent in this circuit."
The Fourth Circuit's jurisdiction covers federal appeals from district courts in Maryland, Virginia, West Virginia, North Carolina, and South Carolina. Drug possession and firearms charges like those in Taylor's case represent a significant portion of the federal criminal docket in these states, particularly in areas affected by the opioid crisis.
The vacatur and remand order requires the Eastern District court to reconsider aspects of Taylor's case, though the specific issues that prompted the appellate intervention are not detailed in the available portions of the opinion. Common grounds for such remands include sentencing calculation errors, improper application of guidelines, or procedural defects during plea proceedings or sentencing hearings.
For Taylor, the decision provides another opportunity for potentially more favorable treatment at the district court level. The case will return to Judge Flanagan's court, where prosecutors and defense counsel will need to address whatever deficiencies the Fourth Circuit identified.
The timing of the decision, coming in early January 2026, suggests the court prioritized resolving Taylor's appeal promptly after oral arguments in December. Federal appeals courts typically issue decisions within several months of oral argument, though the timeline can vary based on case complexity and court schedules.
This case illustrates the iterative nature of the federal appeals process, where appellate courts can require multiple remands to ensure proper application of sentencing law. It also demonstrates the ongoing impact of circuit precedents like *Rogers*, which continue to influence how lower courts handle similar cases involving drug trafficking and firearms violations.
The Eastern District of North Carolina will now need to conduct new proceedings consistent with the Fourth Circuit's instructions, potentially leading to a modified sentence or other relief for Taylor depending on the specific legal issues the appellate court identified.