United States of America v. Lorenzio Reshaud Simmons

Memorandum cited 'United States v. Hazel, 696 F.3d 473, 478 (4th Cir. 2012)' — court found no such Fourth Circuit case (citation appears fabricated).

Memorandum cited 'United States v. Angel, 102 F.3d 1066 (4th Cir. 1996)' for a quoted rule; court found no such Fourth Circuit decision or matching quoted language.

Memorandum cited 'United States v. Edwards, 188 F.3d 230, 232 (4th Cir. 1999)' and quoted that packaging weight should not be included; court found Edwards does not contain that quoted language (false quotation).

Memorandum cited 'United States v. Brehm, 442 F.3d 1291, 1293 (4th Cir. 2006)' and attributed the quote 'any uncertainty should be resolved in the defendant's favor.' The court noted the cited Brehm reference is to a different circuit and does not contain that quoted language.

Memorandum cited 'United States v. Nealy, 232 F.3d 825, 829 (4th Cir. 2000)' for language about burdens the government cannot meet; court found the citation is to a different circuit and does not contain the asserted language.

Memorandum cited 'United States v. Harrision, 918 F.2d 469, 473 (4th Cir. 1990)' for a statement that laboratory testing is more precise; court noted the correct case is in a different circuit (Fifth) and does not contain that quoted text.