UNITED STATES v. COMBS

No. 21-4064.

36 F.4th 502 (2022)

UNITED STATES of America, Plaintiff-Appellee, v. Thomas COMBS, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: June 7, 2022.


Attorney(s) appearing for the Case

ARGUED: Cullen Oakes Macbeth , OFFICE OF THE FEDERAL PUBLIC DEFENDER, Greenbelt, Maryland, for Appellant. Matthew Paul Phelps , OFFICE OF THE UNITED STATES ATTORNEY, Baltimore, Maryland, for Appellee. ON BRIEF: James Wyda , Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Baltimore, Maryland, for Appellant. Jonathan F. Lenzner , Acting United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Baltimore, Maryland, for Appellee.

Affirmed by published opinion. Judge Motz wrote the opinion, in which Judge Quattlebaum and Judge Heytens joined.


In the hearing to determine whether to revoke Thomas Combs' supervised release and sentence him to additional time in prison, the district court twice referred to out-of-court statements by Combs' ex-wife. The court neither disclosed these statements to Combs' counsel prior to the revocation hearing nor gave counsel...

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