United States v. Brian Brown

• Court: Court of Appeals for the Eighth Circuit
• Decided: May 5, 2026
• Docket: 25-2958
• Status: Unpublished

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________

No. 25-2958 ___________________________

United States of America

lllllllllllllllllllllPlaintiff - Appellee

v.

Brian Darnell Brown

lllllllllllllllllllllDefendant - Appellant ____________

Appeal from United States District Court for the Eastern District of Arkansas - Central ____________

Submitted: April 30, 2026 Filed: May 5, 2026 [Unpublished] ____________

Before LOKEN, SMITH, and BENTON, Circuit Judges. ____________

PER CURIAM.

Brian Brown appeals after the district court1 revoked his supervised release and sentenced him to 10 months in prison and 2 years of supervised release. On appeal,

1 The Honorable Brian S. Miller, United States District Judge for the Eastern District of Arkansas. Brown contends that the district court committed a procedural error and imposed a substantively unreasonable revocation sentence.

Having carefully reviewed the record and the parties’ arguments on appeal, we conclude that no significant procedural error occurred, and Brown’s revocation sentence was not substantively unreasonable. See United States v. Tumea, 103 F.4th 1349, 1352 (8th Cir. 2024) (procedural errors include selecting sentence based on clearly erroneous facts; unobjected-to procedural sentencing error is reviewed under plain error standard); United States v. O’Connor, 567 F.3d 395, 397 (8th Cir. 2009) (substantive reasonableness is reviewed under deferential abuse-of-discretion standard; sentence may be unreasonable if district court fails to consider relevant factor, gives significant weight to improper factor, or commits clear error of judgment); see also United States v. Beckwith, 57 F.4th 630, 632 (8th Cir. 2023) (per curiam) (revocation sentence within Guidelines range is accorded presumption of substantive reasonableness on appeal).

Accordingly, we affirm. ______________________________

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