United States v. Antonio Evans

CourtCourt of Appeals for the Eighth Circuit
DecidedMay 12, 2026
Docket25-1181
StatusPublished

This text of United States v. Antonio Evans (United States v. Antonio Evans) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Antonio Evans, (8th Cir. 2026).

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________

No. 25-1181 ___________________________

United States of America

Plaintiff - Appellant

v.

Antonio Rayshaun Evans

Defendant - Appellee ____________

Appeal from United States District Court for the Northern District of Iowa - Eastern ____________

Submitted: November 20, 2025 Filed: May 12, 2026 ____________

Before BENTON, GRASZ, and STRAS, Circuit Judges. ____________

GRASZ, Circuit Judge.

Antonio Evans was convicted of two offenses that can carry enhanced mandatory minimums under 21 U.S.C. § 841(b)(1)(A). The district court 1 decided not to apply the enhancement because, in its view, it could not do so without

1 The Honorable C.J. Williams, Chief United States District Judge for the Northern District of Iowa. violating either Evans’s Sixth Amendment rights or 21 U.S.C. § 851. The government appeals, and we affirm.

I. Background

Evans was indicted on six counts, including conspiracy to distribute a controlled substance and distribution of a controlled substance in violation of § 841(a)(1). These counts can both carry an enhanced mandatory minimum sentence when a defendant has previously been convicted of a “serious drug felony.” § 841(b)(1)(A).

A “serious drug felony” is “an offense under State law, involving manufacturing, distributing, or possessing with intent to manufacture or distribute, a controlled substance . . . , for which a maximum term of imprisonment of ten years or more is prescribed by law,” 18 U.S.C. § 924(e)(2)(A)(ii), and “for which — (A) the offender served a term of imprisonment of more than 12 months; and (B) the offender’s release from any term of imprisonment was within 15 years of the commencement of the instant offense.” 21 U.S.C. § 802(58). Evans was previously convicted of possession with intent to deliver cocaine in violation of Iowa Code § 124.401(1)(c), and this offense carries a 10-year maximum sentence. See Iowa Code § 902.9(1)(d). So if the government proves the two “incarceration- related facts” — i.e., that Evans served more than 12 months in prison and was released within 15 years of commencing his instant offense conduct — an enhanced mandatory minimum may apply.

Congress outlined the procedure for applying this enhancement in § 851. First, “the United States attorney [must] file[] an information . . . stating in writing the previous convictions to be relied upon.” § 851(a)(1). Second, “the court shall after conviction but before pronouncement of sentence inquire of the person with respect to whom the information was filed whether he affirms or denies that he has been previously convicted as alleged . . . .” Id. § 851(b). Third, “[i]f the person denies any allegation of the information of prior conviction, . . . he shall file a written -2- response . . . .” Id. § 851(c)(1). Fourth, “[t]he court shall hold a hearing to determine any issues raised by the response which would except the person from increased punishment.” Id. This “hearing shall be before the court without a jury,” and “[a]t the request of either party, the court shall enter findings of fact and conclusions of law.” Id. And fifth, “if the court determines, after [the] hearing, that the person is subject to increased punishment by reason of prior convictions, the court shall proceed to impose sentence upon him . . . .” Id. § 851(d)(1).

Here, the government filed an information before Evans’s trial giving notice it would seek the enhanced mandatory minimum based on his prior conviction. The government and Evans both proposed jury instructions asking the district court to submit the incarceration-related facts to the jury during his trial, but it did not do so. After Evans’s conviction, but before his sentencing, the Supreme Court decided Erlinger v. United States, which makes plain that a jury, rather than the court, must find the incarceration-related facts. See 602 U.S. 821, 838 (2024). Evans then objected to the application of the enhanced mandatory minimum under § 851(c)(1), arguing the enhancement could not be applied to him because a jury had not found the incarceration-related facts.

The district court agreed, and it initially entered an order stating it would schedule a trial so a jury could resolve whether Evans’s prior conviction satisfied the incarceration-related facts. However, it vacated its order and scheduled this case for sentencing without the enhanced mandatory minimum because, in its view, the unique procedural posture of this case presented a catch-22. If the court applied the enhanced mandatory minimum to Evans without a jury having found the incarceration-related facts, Evans’s Sixth Amendment rights would be violated. But if the court empaneled a jury to resolve these facts, it would violate § 851, since Evans already objected to the enhanced mandatory minimum and the statute required the court to resolve his objection “without a jury . . . .” § 851(c)(1). The government appeals the district court’s decision to schedule this case for sentencing without applying the enhanced mandatory minimum.

-3- II. Analysis

We have jurisdiction under § 851(d)(2), and we review the district court’s legal conclusion that it cannot apply the enhanced mandatory minimum to Evans de novo. See New v. United States, 652 F.3d 949, 952 (8th Cir. 2011). Because we agree that the incarceration-related facts cannot be found in this instance without running afoul of either Evans’s Sixth Amendment rights or § 851(c)(1), we affirm the district court’s decision to sentence Evans without applying the enhanced mandatory minimum.

To start, the government concedes the Sixth Amendment requires a jury to find the incarceration-related facts before the enhanced mandatory minimum can be applied. This was warranted. In Apprendi v. New Jersey, the Supreme Court held that, “[o]ther than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt.” 530 U.S. 466, 490 (2000). This seems clear, but some confusion existed after Apprendi regarding how broadly “the fact of a prior conviction” should be interpreted. For instance, we initially cited Almendarez-Torres v. United States, 523 U.S. 224 (1998), to support a broad reading, allowing courts to find facts relating to defendants’ past offenses when recidivism enhancements were at issue. See, e.g., United States v. Williams, 976 F.3d 781, 787 (8th Cir. 2020), vacated, 142 S. Ct. 1439 (2022). We now know that this was wrong. See Erlinger, 602 U.S. at 836–39 (rejecting this interpretation of Almendarez-Torres). “[A] judge may ‘do no more, consistent with the Sixth Amendment, than determine what crime, with what elements, the defendant was convicted of.’” Id. at 838 (quoting Mathis v. United States, 579 U.S. 500, 511–12 (2016)).

This appeal therefore turns on whether a jury can find the incarceration-related facts at this stage in these proceedings. In our view, it cannot.

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United States v. Antonio Evans, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-antonio-evans-ca8-2026.