RICHMOND, VA, October 17, 2025 — The U.S. Court of Appeals for the Fourth Circuit upheld the 336-month federal prison sentence of Derrick “Red” Simpson, who pleaded guilty to conspiracy to distribute five kilograms or more of cocaine.
Simpson challenged his sentence as procedurally unreasonable, arguing that the district court denied him due process by limiting his ability to dispute witness statements and enhancements, improperly applied a firearm enhancement, and failed to address his request for a downward variance.
The appellate panel, consisting of Judges King, Quattlebaum, and Senior Judge Traxler, rejected each argument. The court found that the district court acted within its discretion in relying on corroborated co-conspirator statements and testimony supporting the enhancement for using a minor. The panel also determined that the evidence sufficiently connected Simpson to a firearm found under his driver’s seat during a drug transaction.
In addition, the Fourth Circuit held that the sentencing court adequately explained its reasoning under 18 U.S.C. § 3553(a), citing Simpson’s leadership role, the large drug quantity, his violent criminal history, and his continued involvement in large-scale trafficking operations despite prior convictions.
The panel concluded that the 28-year sentence was procedurally sound and affirmed the district court’s judgment without oral argument.
