United States v. Jeffrey Dixon, No. 22-1267 (8th Cir. 2022)
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Defendant began supervision in November 2020. He struggled reacclimating to society. Although he started a business and, for a time, underwent substance-abuse and mental-health treatment, he never stopped using meth. In ten months, he violated his probation no less than 15 times, never lasting more than a month without testing positive for meth. He was arrested on October 13, 2021 for driving without a license. While in custody, he threatened to kill two United States Marshals if they did not release him to care for his sick mother. The district court revoked his probation on January 20, 2022.
The government urged a top-of-the-guidelines sentence. The court imposed a bottom-of-the-guidelines 21-month sentence. Defendant appealed, claiming the court both committed procedural error by failing to consider the letter he sent before his original sentencing and also imposed a substantively unreasonable sentence.
The Eighth Circuit affirmed. The court concluded that the revocation court did not commit plain error by failing to read Defendant’s letter. Defendant did not ask the revocation court to consider it. He did not provide the information contained in the letter. He did not even mention its existence. He now argues that the district court erred by not learning of and hunting down the letter sua sponte. This court disagrees. The district court did not plainly err by failing to discover and consider the letter. Further, here, the district court did not fail to consider a relevant factor. Moreover, the court’s within-guidelines sentence is presumptively reasonable.
Court Description: [Benton, Author, with Loken and Arnold, Circuit Judges] Criminal case - Sentencing. The district court was familiar with the record, including defendant's sentencing letter, and the court's level of familiarity with the record did not constitute plain error; the revocation sentence imposed was not substantively unreasonable.
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