The U.S. Court of Appeals for the Third Circuit affirmed the firearms conviction and sentence of Terell Crump in a non-precedential decision filed January 21, 2026. The appeals court found that Crump's appellate waiver provisions blocked two of his arguments challenging the sentence and determined that the imposed punishment was reasonable.
The case arose from incidents in a densely populated Philadelphia neighborhood where Crump and Edward Rivera were captured on social media firing guns from a window of a home during daytime hours. According to court documents, Rivera posted photos and live-streamed video on social media showing himself and Crump discharging firearms from the residence.
The video evidence proved particularly damaging to Crump's case. Still images from Rivera's social media posts captured Crump handling and placing in his waistband a firearm that belonged to Rivera. According to Rivera's statements to authorities, the weapon had an obliterated serial number, adding another layer of federal firearms violations to the incident.
The timing of Crump's actions made his legal situation more serious. Court records show that Crump engaged in this firearms-related conduct while on parole for Pennsylvania robbery and aggravated assault convictions. This status as a previously convicted felon made his possession of any firearm a federal crime under 18 U.S.C. § 922(g)(1), which prohibits convicted felons from possessing firearms or ammunition.
Crump was charged with being a felon in possession of a firearm and ultimately pleaded guilty to the federal charge. His plea agreement included an appellate waiver, a common provision in federal plea deals that limits a defendant's ability to challenge certain aspects of their conviction or sentence on appeal.
Despite the appellate waiver, Crump attempted to challenge his sentence through the Third Circuit Court of Appeals. The three-judge panel hearing the case consisted of Circuit Judges Shwartz, Chung, and Ambro. Judge Shwartz authored the opinion for the panel.
The appeals court's analysis focused on two main issues: the validity of Crump's appellate waiver and the reasonableness of his sentence. The court found that the appellate waiver provisions in Crump's plea agreement effectively barred two of his arguments challenging the sentence imposed by the U.S. District Court for the Eastern District of Pennsylvania.
Appellate waivers have become increasingly common in federal criminal cases as a way for prosecutors to limit post-conviction challenges while providing defendants with the certainty of plea agreements. These waivers typically prevent defendants from appealing their sentences except in limited circumstances, such as claims of ineffective assistance of counsel or sentences that exceed statutory maximums.
The Third Circuit's decision to enforce Crump's appellate waiver reflects the general judicial approach of honoring these agreements when they are knowingly and voluntarily entered. Federal courts have consistently held that appellate waivers are enforceable when defendants understand the rights they are giving up and receive adequate consideration in return, typically in the form of reduced charges or sentencing recommendations.
Beyond the appellate waiver issue, the court also examined whether Crump's sentence was reasonable under federal sentencing guidelines. The panel concluded that the sentence imposed by District Judge Paul S. Diamond was appropriate given the circumstances of the case and Crump's criminal history.
Federal sentencing in felon-in-possession cases typically considers factors such as the defendant's prior criminal record, the circumstances surrounding the current offense, and the potential danger to the community. Crump's status as a parolee who engaged in reckless firearms conduct in a populated area likely influenced the court's sentencing decision.
The Third Circuit designated its decision as non-precedential, meaning it will not serve as binding authority in future cases. This classification is common for routine appeals that do not raise novel legal issues or require extended analysis of complex legal principles.
The case originated in the U.S. District Court for the Eastern District of Pennsylvania under case number 2:17-cr-00150-001, indicating that the underlying criminal conduct occurred in 2017. The lengthy timeline from initial charges to final appellate resolution reflects the typical progression of federal criminal cases through the court system.
The Third Circuit's affirmation of Crump's conviction and sentence reinforces federal enforcement priorities regarding illegal firearm possession, particularly by individuals with prior felony convictions. The case also demonstrates how social media evidence can play a crucial role in federal prosecutions, as Rivera's posts provided clear documentation of the criminal conduct.
This decision adds to the body of Third Circuit jurisprudence on felon-in-possession cases and appellate waiver enforcement, though its non-precedential status limits its broader legal impact. The ruling stands as another example of federal courts' willingness to uphold firearms convictions when supported by clear evidence and proper legal procedures.
