United States v. Brandon Branigan

CourtCourt of Appeals for the Eighth Circuit
DecidedMarch 11, 2026
Docket24-2461
StatusUnpublished

This text of United States v. Brandon Branigan (United States v. Brandon Branigan) 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. Brandon Branigan, (8th Cir. 2026).

Opinion

United States Court of Appeals For the Eighth Circuit _______________________

No. 24-2461 _______________________

United States of America

Plaintiff - Appellee

v.

Brandon Deshane Branigan, also known as B

Defendant - Appellant ____________

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

Submitted: October 20, 2025 Filed: March 11, 2026 [Unpublished] ____________

Before SMITH, KELLY, and GRASZ, Circuit Judges. ____________

PER CURIAM.

Brandon Branigan appeals his 226-month sentence. After careful review, we affirm. I.

On March 28, 2024, Branigan pleaded guilty to one count of Racketeering Conspiracy under 18 U.S.C. § 1962(d). Pursuant to a plea agreement, the government agreed to dismiss a separate indictment against him in the Southern District of Iowa, and Branigan stipulated to his involvement in a shooting in May 2021, in which he attempted to shoot a man he believed to be a rival gang member but instead shot his own passenger several times. Based on this conduct, the Presentence Investigation Report (PSR) recommended applying a cross reference under the Guidelines to attempted murder.

Branigan raised several objections to the PSR, including that the facts of the shooting, while undisputed, did not support the cross reference. At sentencing, he also moved for a downward variance to reflect his decision to plead guilty rather than go to trial. The district court 1 overruled the objection to the cross reference, denied the motion for variance, and sentenced Branigan to 226 months of imprisonment. 2

Branigan raises two challenges to his sentence on appeal: first, that the district court erred in applying an attempted murder cross reference under USSG §§ 2E1.1(a)(2) and 2A2.1; and second, that the sentence was substantively unreasonable because the district court failed to give sufficient consideration to his decision to plead guilty. We address each in turn.

1 The Honorable Stephen H. Locher, United States District Judge for the Southern District of Iowa. 2 The district court initially imposed a term of imprisonment of 240 months but, on the parties’ joint request, reduced it to 226 months to account for the 14 months Branigan had served in state custody for which he would not otherwise receive credit against his federal sentence.

-2- II.

“[W]e review a district court’s sentence in two steps: first, we review for significant procedural error; and second, if there is no significant procedural error, we review for substantive reasonableness.” United States v. Jones, 89 F.4th 681, 684 (8th Cir. 2023) (quoting United States v. Godfrey, 863 F.3d 1088, 1094 (8th Cir. 2017)). “We review the district court’s application of the Guidelines and imposition of sentencing enhancements de novo.” United States v. Foard, 108 F.4th 729, 736 (8th Cir. 2024) (quoting United States v. Norwood, 774 F.3d 476, 479 (8th Cir. 2014) (per curiam)). “We review factual findings at sentencing for clear error.” Id. (citing Norwood, 774 F.3d at 479). The government bears the burden of showing a sentence enhancement was warranted by a preponderance of the evidence. Id. (first citing Norwood, 774 F.3d at 479; and then citing United States v. Thomas, 630 F.3d 1055, 1057 (8th Cir. 2011) (per curiam)).

A.

Under the Guidelines, the base level for a racketeering offense is level 19 or “the offense level applicable to the underlying racketeering activity,” whichever is greater. USSG § 2E1.1(a). Here, the PSR recommended applying the offense level applicable to attempted murder under USSG § 2A2.1. See United States v. Nichols, 76 F.4th 1046, 1055 (8th Cir. 2023) (“Attempted murder is an underlying ‘racketeering activity[.]’” (quoting 18 U.S.C. § 1961(1))). This cross reference applies “if the object of the offense would have constituted first degree murder” under 18 U.S.C. § 1111. USSG § 2A2.1(a)(1); id. § 2A2.1, comment. (n.1).

First degree murder, as relevant here, requires both that the defendant acted with malice aforethought and that the killing was premeditated. Eighth Circuit Model Jury Inst. 6.18.1111A n.6; 18 U.S.C. § 1111(a). “[P]roof of premeditation [does] not require the government to show that the defendant deliberated for any particular length of time.” United States v. Greer, 57 F.4th 626, 629 (8th Cir. 2023)

-3- (alterations in original) (quoting United States v. Slader, 791 F.2d 655, 657 (8th Cir. 1986)).

The facts surrounding the shooting are uncontested, but Branigan argues they do not rise to the level of attempted murder. According to Branigan, because he was “blindly shooting,” the district court could not permissibly infer he acted with malice aforethought or premeditation as to either his passenger or the man who approached the car. As a result, the proper cross reference was to assault, not attempted murder.

The district court rejected this argument:

I think from the very first shot there was at a minimum a reckless and wanton conduct and a gross deviation from the standard of care, but certainly by the fifth, sixth, eighth, tenth shot—

And it doesn’t matter to me which way Mr. Branigan was looking. When he’s firing horizontally in the direction of someone who has just walked up to the car and hasn’t, at least by my review of the video, done anything threatening to Mr. Branigan — no indication of a gunshot being fired into the car first before Mr. Branigan fires back. Instead, all the shooting is in one direction, by Mr. Branigan, a horizontal level, 10 shots. That is enough to establish malice aforethought[.]

“[Branigan’s] intent is a finding of fact we review for clear error.” United States v. Williams, 41 F.4th 979, 985–86 (8th Cir. 2022) (quoting United States v. Grauer, 701 F.3d 318, 325 (8th Cir. 2012)). The district court’s findings as to malice aforethought are fully supported by the record. See Janis v. United States, 73 F.4th 628, 631–32 (8th Cir. 2023) (“This court defines ‘malice aforethought’ as the ‘intent, at the time of a killing, willfully to take the life of a human being, or an intent willfully to act in callous and wanton disregard of the consequences to human life.” (emphases omitted) (quoting United States v. Comly, 998 F.3d 340, 343 (8th Cir. 2021))). And regardless of whether Branigan intended to harm his passenger, his undisputed actions evinced an intent to kill the unknown man who approached the car.

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Related

United States v. Thomas
630 F.3d 1055 (Eighth Circuit, 2011)
United States v. Milford Eugene Slader
791 F.2d 655 (Eighth Circuit, 1986)
United States v. Ted Grauer
701 F.3d 318 (Eighth Circuit, 2012)
United States v. Feemster
572 F.3d 455 (Eighth Circuit, 2009)
United States v. Kenvis Norwood
774 F.3d 476 (Eighth Circuit, 2014)
United States v. Cowan Godfrey
863 F.3d 1088 (Eighth Circuit, 2017)
United States v. Randall Comly
998 F.3d 340 (Eighth Circuit, 2021)
United States v. Ceeron Williams
41 F.4th 979 (Eighth Circuit, 2022)
United States v. Jaterrius Greer
57 F.4th 626 (Eighth Circuit, 2023)
Tiffany Janis v. United States
73 F.4th 628 (Eighth Circuit, 2023)
United States v. Austin Nichols
76 F.4th 1046 (Eighth Circuit, 2023)
United States v. Daryl Jones, III
89 F.4th 681 (Eighth Circuit, 2023)
United States v. Leonard Haskins
101 F.4th 997 (Eighth Circuit, 2024)
United States v. Dalonte Foard
108 F.4th 729 (Eighth Circuit, 2024)
United States v. Colton Bagola
108 F.4th 722 (Eighth Circuit, 2024)
United States v. Mar Maluoth
121 F.4th 1158 (Eighth Circuit, 2024)

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United States v. Brandon Branigan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-brandon-branigan-ca8-2026.