PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 23-4431

UNITED STATES OF AMERICA,

Plaintiff – Appellee,

v.

TREVOR RAEKWON SEWARD,

Defendant – Appellant.

Appeal from the United States District Court for the District of South Carolina, at Florence. Donald C. Coggins, Jr., District Judge. (4:20-cr-00512-DCC-1)

Argued: January 31, 2025 Decided: April 25, 2025

Before WILKINSON, HEYTENS, and BENJAMIN, Circuit Judges.

Affirmed by published opinion. Judge Heytens wrote the opinion, which Judge Wilkinson and Judge Benjamin joined.

ARGUED: Joshua Snow Kendrick, KENDRICK & LEONARD, P.C., Greenville, South Carolina, for Appellant. Robert Nicholas Bianchi, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, South Carolina, for Appellee. ON BRIEF: Adair F. Boroughs, United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Columbia, South Carolina, for Appellee. USCA4 Appeal: 23-4431 Doc: 70 Filed: 04/25/2025 Pg: 2 of 14

TOBY HEYTENS, Circuit Judge:

A jury found Trevor Seward guilty of murdering a rural mail carrier. On appeal,

Seward raises two challenges under the Federal Rules of Evidence and one under the Sixth

Amendment’s Confrontation Clause. We conclude both evidentiary challenges fail on the

merits. And although the district court admitted testimony that may have violated the

Confrontation Clause as construed in the Supreme Court’s post-trial decision in Smith v.

Arizona, 602 U.S. 779 (2024), we conclude any such error was harmless. We thus affirm.

I.

In 2019, Irene Pressley’s body was found falling out of her still-running car on the

side of a dirt road in Andrews, South Carolina. Pressley had been shot several times, and

investigators found an assault rifle near the body as well as 21 bullet casings at an

intersection two miles down the road. Near that intersection, a witness found a package

containing two pounds of marijuana addressed to Seward’s residence. The package had

Pressley’s blood on it.

Investigators found significant evidence implicating Seward in Pressley’s death.

Before she died, Pressley had been delivering mail along her route. When she reached

Seward’s residence, Pressley did not deliver the package of marijuana to the house but

placed a slip in the mailbox saying it could be picked up at the post office. Video from

Seward’s home security system showed that immediately after Pressley failed to deliver

the package, Seward exited the house, got into his car, and drove off in the same direction

Pressley had gone, before returning home minutes later. Eleven minutes after returning,

Seward left again, this time carrying an assault rifle and wearing a sweatshirt with the hood

2 USCA4 Appeal: 23-4431 Doc: 70 Filed: 04/25/2025 Pg: 3 of 14

cinched tightly over his face even though the temperature was above 80 degrees. About an

hour later, a witness saw Seward driving Pressley’s car going “[b]etween 80 and 90 miles

per hour.” JA 539. Testing revealed Seward’s fingerprints and palm prints on the car and

several packages inside it, including a palm print in Pressley’s blood.

Seward was charged with murdering a federal employee engaged in official duties,

using a firearm during a crime of violence constituting murder, Hobbs Act robbery,

possessing a fire

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