United States v. Hawkins
United States Court of Appeals for the Fourth Circuit
776 F.3d 200 (2015)
Collin Hawkins (defendant), a convicted felon, was identified by the victim as a participant in a carjacking. Weeks later, police arrested him in connection with a separate matter and found a different firearm on him. The government charged Hawkins with carjacking and brandishing a firearm during the carjacking (Counts I and II) and with being a felon in possession of a firearm based on the gun found at his arrest (Count III). Hawkins moved to sever Counts I and II from Count III as improperly joined or unduly prejudicial; the district court denied the motion, and a jury convicted him on all three counts.
Whether joinder of a felon-in-possession charge with carjacking and firearm-brandishing charges is proper under the same-or-similar-character standard merely because all three charges are gun-related and occurred close in time.