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Workman Affirmed - No Judicial Vindictiveness in Sentencing Increase on Remand

The Fourth Circuit affirmed the district court's 18-month sentence imposed on Mary Elizabeth Workman following remand, rejecting her claim of judicial vindictiveness. The court held that because Workman was resentenced by a different district judge than the original sentencing judge, the presumption of vindictiveness from North Carolina v. Pearce does not apply, and Workman bore the burden to prove actual vindictiveness. The appellate court found the record showed the second judge gave clear, explicit reasons for the three-month sentence increase and additional supervised release conditions.