United States v. Jaisaun Holt

• Court: Court of Appeals for the Eighth Circuit
• Decided: May 12, 2026
• Docket: 24-2346
• Status: Unpublished

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________

No. 24-2346 ___________________________

United States of America

Plaintiff - Appellee

v.

Jaisaun Antonio Holt

Defendant - Appellant ____________

Appeal from United States District Court for the District of North Dakota - Western ____________

Submitted: May 7, 2026 Filed: May 12, 2026 [Unpublished] ____________

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

PER CURIAM.

Jaisaun Holt appeals the sentence imposed by the district court 1 after he pled guilty to drug offenses. Having jurisdiction under 28 U.S.C. § 1291, this court affirms.

1 The Honorable Daniel L. Hovland, United States District Judge for the District of North Dakota. Holt argues the district court erred in treating his prior assault conviction as a career-offender predicate because he received the conviction pursuant to a nolo contendere plea. Holt’s argument is foreclosed by this court’s precedent. See United States v. Harris, 36 F.4th 827, 830 (8th Cir. 2022) (per curiam) (standard of review); United States v. Grimes, 702 F.3d 460, 470 (8th Cir. 2012) (conviction pursuant to plea of nolo contendere qualified as conviction for purpose of determining whether defendant was career offender under U.S.S.G. § 4B1.1). Further, the district court correctly determined that it need not address Holt’s objections to various enhancements, because his career-offender status controlled his applicable offense level. See Fed. R. Crim. P. 32(i)(3)(B).

The judgment is affirmed. ______________________________

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