United States v. Edward Jeffus ( 2024 )

USCA4 Appeal: 24-4199 Doc: 18 Filed: 11/26/2024 Pg: 1 of 3
UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 24-4199
UNITED STATES OF AMERICA,
Plaintiff - Appellee,
v.
EDWARD DANE JEFFUS,
Defendant - Appellant.
Appeal from the United States District Court for the Middle District of North Carolina, at
Greensboro. William L. Osteen, Jr., District Judge. (6:92-cr-00184-WO-2)
Submitted: November 18, 2024 Decided: November 26, 2024
Before WILKINSON, NIEMEYER, and KING, Circuit Judges.
Dismissed by unpublished per curiam opinion.
ON BRIEF: George E. Crump, III, Rockingham, North Carolina, for Appellant. Sandra
J. Hairston, United States Attorney, Randall S. Galyon, Assistant United States Attorney,
OFFICE OF THE UNITED STATES ATTORNEY, Greensboro, North Carolina, for
Appellee.
Unpublished opinions are not binding precedent in this circuit.
USCA4 Appeal: 24-4199 Doc: 18 Filed: 11/26/2024 Pg: 2 of 3
PER CURIAM:
Edward Dane Jeffus appeals the district court’s judgment revoking his supervised
release and sentencing him to six months’ imprisonment. During the pendency of this
appeal, Jeffus was released from custody, and he is not serving an additional term of
supervised release. On appeal, Jeffus argues that the district court erred in finding that he
violated the conditions of his supervised release by a preponderance of the evidence.
“We . . . have an independent obligation to determine whether subject-matter
jurisdiction exists, even in the absence of a challenge from any party.” Atkinson v. Godfrey,
100 F.4th 498, 503 n.3 (4th Cir. 2024) (internal quotation marks omitted). “A case becomes
moot—and therefore no longer a ‘Case’ or ‘Controversy’ for purposes of Article III—when
the issues presented are no longer ‘live’ or the parties lack a legally cognizable interest in
the outcome.” United States v. Ketter, 908 F.3d 61, 65 (4th Cir. 2018) (internal quotation
marks omitted). “If an event occurs while a case is pending on appeal that makes it
impossible for the court to grant any effectual relief whatever to a prevailing party, the
appeal must be dismissed . . . .” Incumaa v. Ozmint, 507 F.3d 281, 286 (4th Cir. 2007)
(cleaned up).
Jeffus has already served his prison term for the supervised release revocation, and
the district court did not impose any additional term of supervised release. Jeffus has not
demonstrated any collateral consequences of the revocation judgment, and none are
apparent from the record. Thus, there is no longer a live controversy regarding the
revocation of Jeffus’s supervised release, and his challenge to the revocation judgment is
moot. See United States v. Hardy, 545 F.3d 280, 283-84 (4th Cir. 2008).
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USCA4 Appeal: 24-4199 Doc: 18 Filed: 11/26/2024 Pg: 3 of 3
We therefore dismiss the appeal as moot. 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.
DISMISSED
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