United States v. Hakeem Boyum, No. 22-2092 (8th Cir. 2022)
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Defendant walked away from the Fort Des Moines Residential Reentry Center (RRC), where he had been placed during the supervised release portion of his sentence for a firearms violation. He was later arrested and charged with escape. At his revocation sentencing hearing, the district court sentenced him to 12 months and 1 day for the escape, to be served consecutively with his existing sentence. He appealed both the length of the sentence and its consecutive imposition.
The Eighth Circuit affirmed. The court explained that here, the district court correctly calculated Defendant’s Guidelines range for his offense and criminal history as 8 to 14 months. It also considered the Section 3553(a) factors and stated, “I recognize the defendant’s—those same factors here, relative youth and lack of youthful guidance and childhood trauma, are present in the defendant's history as well, and the Court considers that in determining the appropriate sentence to impose.” Further, Section 3553(a) factors were adequately considered, and the district court provided a reasonable explanation for imposing the sentence consecutively. The district court did not abuse its discretion by imposing a consecutive sentence.
Court Description: [Smith, Author, with Benton and Shepherd, Circuit Judges] Criminal case - Sentencing. The district court did not abuse its discretion by making defendant's revocation sentence and his sentence for his new escape conviction consecutive; the revocation sentence was not substantively unreasonable.
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