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United States v. Holley - Sentence Affirmed on Grouping and Consecutive Sentencing Challenges

The Fourth Circuit affirmed Xavier Holley's 480-month sentence for attempted Hobbs Act robbery and conspiracy, rejecting his challenges to the district court's grouping of counts and its authority to impose consecutive sentences. The appellate court held that any grouping error was harmless because the offense level remained at 45 regardless of grouping, and that consecutive sentences for conspiracy and attempted robbery are permissible under 18 U.S.C. § 3584(a) per this circuit's precedent in United States v. Oliver.