United States v. Christopher Evans, No. 22-1287 (8th Cir. 2023)
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Defendant pled guilty to being a felon in possession of a firearm in violation of 18 U.S.C. Sections 922(g)(1) and 924(a)(2). The district court sentenced him to 110 months in prison. He appealed his sentence. Defendant argued the district court erred in determining he had a “controlled substance offense” under U.S.S.G. Sections 2K2.1(a)(4)(A) and 4B1.2(b).
The Eighth Circuit affirmed. The court explained that there is no equal protection violation “if there is any reasonably conceivable state of facts that could provide a rational basis” for the application of United States v. Henderson. Because Henderson was neither unexpected nor indefensible, its interpretation of the guidelines had a rational basis. The district court did not plainly err in not sua sponte finding that applying Henderson violated Defendant’s equal protection rights. Moreover, the court wrote that the district court considered Section 3553(a) factors and thoroughly explained its decision. It did not abuse its discretion.
Court Description: [Benton, Author, with Gruender and Shepherd, Circuit Judges] Criminal case - Sentencing. Defendant's Illinois conviction for manufacture or delivery of cocaine was a controlled substance offense for sentencing purposes, and application of this court's decision in U.S. v. Henderson, 11 F.4th 713 (8th Cir. 2021) does not violate defendant's due process or equal protection rights; defendant's within-guidelines range sentence was not substantively unreasonable.
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