10th Cir.

United States v. Jackson

June 11, 2026 ·25-6159 ·Panel Decision ·Carolyn B. McHugh · By James Taylor

The Tenth Circuit affirmed a 156-month prison sentence for a defendant convicted of child sex trafficking conspiracy. The court found the district court's upward variance from the sentencing guidelines was not substantively unreasonable given the defendant's history of violence and obstruction of justice.

Background

In February 2025, Antwon Montrell Jackson was charged with conspiracy to commit child sex trafficking and related offenses. He pleaded guilty to conspiracy in violation of Section 18 United States Code 1594 subsection C. The district court calculated an advisory sentencing guidelines range of 70 to 87 months but imposed a 156-month sentence after finding the defendant’s history of violence and obstruction of justice warranted an upward variance.

The court’s reasoning

The court reviewed the sentence for abuse of discretion, applying the standard that a sentence is reasonable if it falls within the range of rationally available choices supported by the facts and law. The panel found no indication that the district court improperly considered the defendant’s race or that the sentence was based on considerations already embodied in the guidelines. The court emphasized that it does not reweigh sentencing factors but only determines if the district court’s balance was arbitrary or manifestly unreasonable.

we discern nothing substantively unreasonable about Mr. Jackson’s sentence, and so we affirm.

Order and Judgment, United States v. Jackson, No. 25-6159 (10th Cir. June 11, 2026)

What it means going forward

The decision reinforces the broad discretion of district courts to impose sentences outside the guidelines range when justified by a defendant’s history of violence and obstruction of justice, even in cases involving significant variances.