UNPUBLISHED

UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

No. 16-4414

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

ADEDEJI AJALA,

Defendant - Appellant.

Appeal from the United States District Court for the District of Maryland, at Baltimore. 

Richard D. Bennett, District Judge. (1:14-cr-00441-RDB-1)

Submitted: May 30, 2017 Decided: July 6, 2017

Before WILKINSON, DUNCAN, and DIAZ, Circuit Judges.

Affirmed by unpublished per curiam opinion.

Michael Lawlor, LAWLOR & ENGLERT, LLC, Greenbelt, Maryland, for Appellant. Rod 

J. Rosenstein, United States Attorney, Christopher J. Romano, Assistant United States 

Attorneys, Baltimore, Maryland, for Appellee.

Unpublished opinions are not binding precedent in this circuit.
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PER CURIAM:

Adedeji Ajala was convicted after a jury trial of conspiracy to import heroin into the 

United States, in violation of 21 U.S.C. §§ 952, 963 (2012), and was sentenced to 84 

months in prison. On appeal, Ajala argues that insufficient evidence supported his 

conviction, that the district court impermissibly burdened his ability to represent himself 

by restricting access to discovery, and that the court erred in calculating the drug amount 

attributable to him. We affirm.

We review de novo the district court’s denial of Ajala’s Fed. R. Crim. P. 29 motion 

for judgment of acquittal on the basis of insufficient evidence. United States v. Reed, 780 

F.3d 260, 269 (4th Cir. 2015). “A defendant challenging the sufficiency of the evidence 

bears a heavy burden.” United States v. Cornell, 780 F.3d 616, 630 (4th Cir. 2015) (internal 

quotation marks omitted). “We will uphold a defendant’s conviction if, viewing the 

evidence in the light most favorable to the government, there is substantial evidence in the 

record to support the verdict.” Id. (internal quotation marks omitted). Substantial evidence 

means “evidence that a reasonable finder of fact could accept as adequate and sufficient to 

support a conclusion of a defendant’s guilt beyond a reasonable doubt.” Id. (internal 

quotation marks omitted). “Reversal for insufficient evidence is reserved for the rare case 

where the prosecution’s failure is clear.” United States v. Ashley, 606 F.3d 135, 138 (4th 

Cir. 2010) (internal quotation marks omitted).

We conclude Ajala’s insufficiency argument is meritless. Construing all reasonable 

inferences in the Government’s favor, evidence adduced at trial revealed that, on more than 

one occasion, Ajala coordinated with one or more individuals to receive packages 
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containing large amounts of heroin mailed to Baltimore from abroad. Accordingly, we 

reject Ajala’s sufficiency challenge.

Ajala next contends that the district court impermissibly interfered with his right to 

represent himself by prohibiting him from taking any discovery materials—including his 

handwritten trial notes—with him to the detention facility where he was being held. We 

review for abuse of discretion a district court’s discovery decisions. Bresler v. Wilmington 

Trust Co., 855 F.3d 178, 189 (4th Cir. 2017); United States v. Galloway, 749 F.3d 238, 242 

(4th Cir. 2014). A defendant must demonstrate that he was prejudiced by the court’s 

discovery rulings. See Galloway, 749 F.3d at 242; United States v. Bisong, 645 F.3d 384, 

396 (D.C. Cir. 2011) (providing that, “[e]ven assuming that pro se defendants have a Sixth 

Amendment right to discovery in preparing their defense,” defendant asserting such claim 

“must demonstrate prejudice in order to prevail”).

The record establishes that Ajala was given access to discovery prior to the 

commencement of trial. Although the discovery arrangements during trial might have been 

inconvenient, Ajala has failed to show that they were unreasonable. See Galloway, 749 

F.3d at 242; United States v. Sarno, 73 F.3d 1470, 1492 (9th Cir. 1995) (concluding that, 

while pro se defendant’s “access to discovery materials was hardly optimal, . . . the 

limitations imposed on him were reasonable”). Additionally, Ajala has not shown how his 

lack of access to discovery in his cell affected his ability to represent himself at trial. 

Accordingly, we conclude this claim lacks merit.

Finally, Ajala asserts the district court erred in calculating the drug amount 

attributable to him, specifically challenging the inclusion of the drugs intercepted by airport 
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customs officials in Germany. “We review the district court’s calculation of the quantity 

of drugs attributable to a defendant for sentencing purposes for clear error.” United States 

v. Slade, 631 F.3d 185, 188 (4th Cir. 2011) (internal quotation marks omitted). Under such 

standard, the district court’s finding is reversed “only if we are left with the definite and 

firm conviction that a mistake has been committed.” United States v. Crawford, 734 F.3d 

339, 342 (4th Cir. 2013) (internal quotation marks omitted).

A “defendant is responsible not only for his own acts, but also for all reasonably 

foreseeable acts of his co-conspirators in furtherance of the joint criminal activity.” Slade, 

631 F.3d at 188 (internal quotation marks omitted); see U.S. Sentencing Guidelines Manual

§ 1B1.3(a)(1) (2015). In determining drug quantities, courts may “‘consider relevant 

information without regard to its admissibility under the rules of evidence applicable at 

trial, provided that the information has sufficient indicia of reliability to support its 

probable accuracy.’” Crawford, 734 F.3d at 342 (quoting USSG § 6A1.3(a), p.s.). 

Additionally, “[a] district court’s approximation of the amount of drugs is not clearly 

erroneous if supported by competent evidence in the record.” United States v. Randall, 

171 F.3d 195, 210 (4th Cir. 1999). Ajala “bears the burden of establishing that the 

information relied upon by the district court . . . is erroneous.” Slade, 631 F.3d at 188.

Ajala has not satisfied his burden. A preponderance of the evidence established 

Ajala’s connection to the package intercepted by customs officials in Germany, and it thus 

was reasonable to attribute the heroin contained therein to him. Therefore, Ajala has not 

shown clear error in the court’s drug quantity calculation.
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Accordingly, we affirm the district court’s judgment and deny Ajala’s pro se motion 

to compel discovery and audio. We dispense with oral argument because the facts and 

legal contentions are adequately presented in the materials before this court and argument 

would not aid the decisional process.

AFFIRMED