USCA4 Appeal: 24-4597 Doc: 29 Filed: 10/17/2025 Pg: 1 of 4

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-4597

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

RICHARD BRIAN WALKER,

Defendant - Appellant.

Appeal from the United States District Court for the District of South Carolina, at Spartanburg. Donald C. Coggins, Jr., District Judge. (7:24-cr-00031-DCC-1)

Submitted: October 6, 2025 Decided: October 17, 2025

Before KING, RICHARDSON, and QUATTLEBAUM, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Adam S. Ruffin, RUFFIN LAW FIRM, LLC, Columbia, South Carolina, for Appellant. Bryan P. Stirling, United States Attorney, Andrea G. Hoffman, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, South Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-4597 Doc: 29 Filed: 10/17/2025 Pg: 2 of 4

PER CURIAM:

Richard Brian Walker appeals his conviction following his guilty plea to several

drug trafficking and firearms offenses, including one count of possessing a firearm in

furtherance of a drug trafficking offense, in violation of

(c)(1)(A). On

appeal, Walker argues that his plea of guilty to possession of a firearm in furtherance of a

drug trafficking crime was not supported by an adequate factual basis because the majority

of the drugs discovered on his property were found in a locked safe separate from the

firearms. We affirm.

Because Walker did not challenge the factual basis for his guilty plea in the district

court, we review the district court’s determination that a factual basis existed for the plea

only for plain error. See United States v. Stitz,

(4th Cir. 2017). To

establish plain error, Walker must show that (1) the district court erred, (2) the error was

plain, and (3) the error affected his substantial rights. United States v. Olano,

(1993). An error is “plain” if it is “clear or obvious” under the “settled law of the

Supreme Court or this circuit.” United States v. Carthorne,

(4th Cir.

2013) (citation modified).

The district court must ensure that there is a factual basis for the plea. Fed. R. Crim.

P. 11(b)(3); United States v. Taylor-Sanders,

(4th Cir. 2023). “The

district court possesses wide discretion in finding a factual basis, and it need only be

subjectively satisfied that there is a sufficient factual basis for a conclusion that the

defendant committed all of the elements of the offense.” Stitz,

(citation

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modified). The district court may reach this conclusion based on “anything that appears

on the record.”

(citation modified).

To convict a defendant of possessing a firearm in furtherance of a drug trafficking

crime under

(c)(1)(A), the Government must establish that the defendant

“(1) committed a drug trafficking offense and (2) possessed a firearm (3) in furtherance of

that drug offense.” United States v. Moody,

(4th Cir. 2021). We conclude

that the Government’s factual proffer at Walker’s guilty plea hearing sufficiently

established that he possessed a firearm in furtherance of a drug trafficking crime. The

Government proffered that Walker conspired with others to both possess and distribute

controlled substances and that coconspirators had picked up and delivered

methamphetamine to Walker at his home. The Government further proffered that, when

law enforcement officers searched Walker’s residence and property, they found large

quantities of drugs and multiple firearms, including a loaded firearm without a serial

number hidden under Walker’s bed and two rifles located in a shed together with a large

amount of methamphetamine. The Government maintained that an officer would have

testified at trial that, based on the officer’s training and experience, Walker possessed the

firearms in furtherance of a drug trafficking offense. See

(discussing factors relevant to

determining whether firearm furthered drug trafficking crime). Accordingly, we discern

no plain error in the district court’s acceptance of Walker’s plea. The Government’s factual

proffer established a sufficient factual basis for the § 924(c) offense.

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We therefore affirm the criminal judgment. We dispense with oral argument

because the facts and legal contentions are adequately presented in the materials before this

court and argument would not aid the decisional process.

AFFIRMED

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