United States v. Angel Vause — 4th Cir. (Oct 29, 2026)
The Fourth Circuit considers an eighteen-year sentence for lies told during an FBI investigation into a teenage girl's kidnapping and murder. Angel Vause pleaded guilty to three false-statement counts arising from a single interview. The lies concerned the events surrounding the girl's disappearance, including how she entered a car and what happened to her phone. The three sentences run one after another, rather than at the same time. Vause is challenging whether the interview could support three separate punishments. The rule of lenity favors the defendant when a criminal law remains seriously ambiguous after the usual tools of interpretation have been applied. She also challenges the use of a higher statutory maximum. The false-statements law normally permits up to five years per offense, but allows up to eight for certain specified matters. The court is examining whether a charging defect involving that higher limit requires relief.
United States v. Angel Vause (No. 25-4119) — U.S. Court of Appeals for the Fourth Circuit, argued October 29, 2026.
- 0:00Introduction