Law360 (May 28, 2026, 7:07 PM EDT) -- The Fourth Circuit vacated a North Carolina man's seven-year prison sentence for a firearm conviction, finding there was not an adequate factual connection between his gun possession and an underlying state homicide charge.

The three-judge panel ruled Wednesday in a published opinion that Jonathan Revels should not have been sentenced under a special federal guidelines provision for possessing a firearm during an underlying crime because of how a district court structured its legal conclusions.

"We do not conclusively resolve whether that provision applies to Revels," U.S. Circuit Judge A. Marvin Quattlebaum Jr. wrote for the panel. "Instead, 'mindful that we are a court of review, not of first view,' we vacate and remand for resentencing because the district court's 'actual findings were legally insufficient to support its application" of the relevant provision.'"

Revels was accused of shooting and killing Jason Hunt with a revolver during what the opinion describes as a four-person altercation in September 2016. The incident was captured on video, which showed Revel possessed three guns, the revolver and two shotguns, the opinion said.

A grand jury charged Revels with one count of violating a federal statute prohibiting the possession of a firearm after being convicted of a qualifying offense. The federal indictment made reference to Revel's possession of the shotguns during the incident but not the revolver, the opinion said.

Revels was found guilty of the federal charge, and a court sentenced him to 120 months in federal prison. The Fourth Circuit later reversed the sentence but affirmed the conviction, finding that the government had "misrepresented a material fact" at sentencing, the opinion said.

While the initial appeal was pending, a North Carolina state court convicted Revels of voluntary manslaughter for his role in Hunt's killing. A federal trial court then recalculated Revels' sentence using a federal sentencing guideline specification for voluntary manslaughter, and it issued a new 84-month sentence.

Revels again appealed, claiming the application of the manslaughter guideline was inappropriate because the court could not connect the killing to the indictment. Prosecutors specifically listed the shotguns, which were not used in the homicide, but failed to mention the revolver in the indictment, the opinion said.

The appeal also claimed that the sentence was unreasonable because the trial court failed to fully explain its reasoning for imposing the sentence. Revels specifically claimed that the court failed to explain its reasoning for the sentencing despite the lack of connection between the gun used and the underlying state crime, the opinion said.

The Fourth Circuit ruled Wednesday that Revels was correct that the court failed to sufficiently explain its legal reasoning with respect to the guns. The panel said the trial court relied on "possession of the revolver" as evidence of a connection, despite no proof in the federal indictment that the gun was involved in the killing.

Even after the case was remanded for resentencing, an updated sentencing recommendation only referenced a "homicide cross reference," without specifying the firearm used. The panel found that because the sentencing decision lacked specificity about the gun's connection to the underlying crime, it should be reversed.

Importantly, the opinion clarified that it was not ruling on whether Revels was eligible to be sentenced under the law. The panel only went so far as to say that the legal reasoning to support the sentence was too bare bones and needs to be more fully fleshed out.

An attorney representing Revels and a spokesperson for the U.S. Attorney's Office for the Eastern District of North Carolina did not respond to requests for comment.

U.S. Circuit Judges Pamela Harris, A. Marvin Quattlebaum Jr. and Toby J. Heytens sat on the panel for the Fourth Circuit.

The government is represented by Jake Pugh and Lucy Partain Brown of the U.S. Attorney's Office for the Eastern District of North Carolina.

Revels is represented by Paul K. Sun and Kelly Margolis Dagger of Ellis & Winters LLP.

The case is USA v. Revels, case number 23-4688, in the U.S. Court of Appeals for the Fourth Circuit.

--Editing by Haylee Pearl.

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