United States v. Yuri Chachanko

CourtCourt of Appeals for the Eighth Circuit
DecidedDecember 18, 2025
Docket24-2440
StatusPublished

This text of United States v. Yuri Chachanko (United States v. Yuri Chachanko) 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. Yuri Chachanko, (8th Cir. 2025).

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________

No. 24-2440 ___________________________

United States of America

Plaintiff - Appellee

v.

Yuri Chachanko

Defendant - Appellant ____________

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

Submitted: May 16, 2025 Filed: December 17, 2025 ____________

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

STRAS, Circuit Judge.

Definite articles like “the” can make a difference. For Yuri Chachanko, it means he is not yet eligible for a sentence reduction. The word “the” in the phrase “the term of imprisonment” required him to serve at least 10 years of the sentence he wanted the district court 1 to reduce. See 18 U.S.C. § 3582(c)(1)(A); U.S.S.G. § 1B1.13(b)(6). Given that he has not done so, we affirm the judgment denying his request.

I.

Twenty-one years ago, Chachanko and an accomplice went on a crime spree across the Great Plains. It started with an armed robbery of a casino in Rapid City, South Dakota, followed by four more in Sioux Falls and Watertown. Next came two crimes in Montana, both stickups at bars. By then, officers were hot on their trail. After a high-speed car chase and a brief foot pursuit, their crime spree came to an end.

Chachanko faced federal charges in both states. In reverse order of the crimes he committed, the Montana prosecution came first, which resulted in a 219-month prison sentence for two Hobbs Act crimes, see 18 U.S.C. §§ 2, 1951, and use of a firearm during a crime of violence, see id. § 924(c)(1)(A).

More prison time, however, was on its way. Once the District of Montana finished with him, he had to face prosecution in South Dakota. He pleaded guilty to using a firearm during another crime of violence. See id. §§ 2, 924(c)(1). But this time, he received an even longer sentence, 300 months, set to start after he finished serving the Montana one. See id. § 924(c)(1)(C)(i) (2006) (imposing a 25-year mandatory-minimum sentence for any “second or subsequent conviction” of the crime); id. § 924(c)(1)(D)(ii) (requiring a consecutive sentence).

Fast forward to the present. Due to legislative changes in the First Step Act, Chachanko requested a sentence reduction in the South Dakota case. See Pub. L. No. 115-391, § 603(b), 132 Stat. 5194, 5239 (2018) (amending 18 U.S.C. § 3582);

1 The Honorable Karen E. Schreier, United States District Judge for the District of South Dakota. -2- U.S.S.G. § 1B1.13. As relevant here, he thought he deserved one because his 300-month sentence was “unusually long,” U.S.S.G. § 1B1.13(b)(6), and he had a head injury, depression, and bipolar disorder, see id. § 1B1.13(b)(1)(B)–(C). Instead of making an immediate decision, the district court ordered briefing on whether he had served “at least 10 years of the term of imprisonment.” Id. § 1B1.13(b)(6) (requiring it for “unusually long sentence[s]”). When it concluded he had not and that “routine . . . monitoring” would take care of his medical conditions, it denied the motion.

II.

Before 2018, only the Bureau of Prisons could seek a sentence reduction on a prisoner’s behalf in these circumstances. See 18 U.S.C. § 3582(c)(1)(A) (2017) (providing that it was by “motion of the Director of the Bureau of Prisons”); United States v. Rodd, 966 F.3d 740, 746 n.6 (8th Cir. 2020). Now, thanks to the First Step Act, prisoners can request them on their own, once they have “fully exhausted” their administrative remedies. 18 U.S.C. § 3582(c)(1)(A) (2018); see Rodd, 966 F.3d at 744–45 (describing how the First Step Act changed the procedures). Any relief, however, is still at the discretion of the district court, which “may reduce the” sentence. 18 U.S.C. § 3582(c)(1)(A) (emphasis added); see Rodd, 966 F.3d at 747–48.

A prisoner seeking a sentence reduction must get past the eligibility requirements: “extraordinary and compelling reasons warrant[ing]” a reduction and “consisten[cy] with applicable policy statements issued by the Sentencing Commission.” 18 U.S.C. § 3582(c)(1)(A). What qualifies as an “extraordinary and compelling reason” is up to the Sentencing Commission, although its policy statements must be “consistent with all pertinent provisions of any Federal statute.” 28 U.S.C. § 994(a)(2)(C), (t). For those who are eligible, a court may then exercise its discretion by considering the “factors set forth in section 3553(a) to the extent that they are applicable.” 18 U.S.C. § 3582(c)(1)(A).

-3- With this framework in mind, Chachanko argues that the district court made three errors when it denied a sentence reduction. First, it did not add his Montana and South Dakota sentences together in evaluating his eligibility for relief from an “unusually long sentence.” U.S.S.G. § 1B1.13(b)(6). Second, it applied the “[e]xtraordinary and compelling reasons” requirement too strictly when it found that his medical conditions were not serious enough to count. Id. § 1B1.13(b)(1). And finally, it never addressed whether they qualified under a catch-all provision. See id. § 1B1.13(b)(5) (accepting “any . . . circumstance or combination of circumstances . . . similar in gravity” to a listed reason, other than an “unusually long sentence”).

A.

Chachanko’s months-long crime spree resulted in two federal sentences, one in Montana and the other in South Dakota. Although he singles out the South Dakota sentence as “unusually long,” he wants us to treat the two sentences as one in calculating whether he has “served at least 10 years of the term of imprisonment.” Id. § 1B1.13(b)(6) (emphasis added). Only then would he be eligible for a sentence reduction. See id.; see also United States v. Gamble, 572 F.3d 472, 474–75 (8th Cir. 2009).

The district court explained why. Although Chachanko had served 17 years in prison by the time he filed his motion, the sentences were consecutive and he had only just started serving his South Dakota sentence, which is the one he wanted reduced. If he were serving them in reverse order, South Dakota then Montana, the court suggested it might have granted the motion. But with each term of imprisonment treated separately, rather than in the “aggregate,” he had yet to become eligible because he had not “served at least 10 years” of the South Dakota sentence.

-4- U.S.S.G. § 1B1.13(b)(6). The question for us is whether those 17 years should have counted. 2

The answer comes down to what the phrase “the term of imprisonment” means. One interpretation is that it refers to the total time Chachanko will spend in prison. This reading bunches the sentences together, allowing service on one to count toward the other. Another is the meaning the district court gave it, which treats each sentence on its own.

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United States v. Yuri Chachanko, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-yuri-chachanko-ca8-2025.