United States v. Ryan McDaniel, No. 22-1448 (8th Cir. 2023)
Annotate this Case
Defendant pleaded guilty to carjacking and brandishing-a-firearm charges and received a 179-month sentence. He now argued that the district court committed procedural and substantive errors in determining his sentence.
The Eighth Circuit affirmed. He first argued that the district court procedurally erred by referring to the JSIN statistics. He claimed that he had a right under Rule 32 of the Federal Rules of Criminal Procedure to have notice of, and therefore time to review, all material information relied on by the district court at sentencing. The court explained that it found that any error made by the district court in interpreting the JSIN statistics “did not substantially influence the outcome of the sentencing proceeding” because the district court focused on Defendant, not the data. If the district court erred in this case, its error was harmless.
Further, Defendant’s 179-month, within-guidelines sentence reflects the district court’s careful weighing of the Section 3553(a) factors. As the district court did not fail to consider or properly weigh any relevant factor or otherwise commit a clear error of judgment, the court concluded that Defendant’s sentence is not substantively unreasonable.
Court Description: [Gruender, Author, with Smith, Chief Judge, and Stras, Circuit Judge] Criminal case - Sentencing. Even assuming that defendant could show the district court erred by not disclosing its intent to rely on the United States Sentencing Commission's Judiciary Sentencing Information (JSIN), this error would not be plain as the court has not held that a district court is obliged to disclose in advance its intent to rely on publicly available JSIN information; assuming without deciding that the district court incorrectly interpreted the JSIN data, remand for resentencing is unnecessary because the district court's alleged error did not prejudice defendant; the court focused on the offense, defendant's history, and other aggravating factors in setting sentence and used the disputed data for comparative purposes as a "data point" and not a controlling factor; the sentence imposed was not substantively unreasonable. Judge Stras, dissenting.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.