June 11, 2026·25-2114·Panel Decision·By James Taylor
The Eighth Circuit affirmed a district court sentence below the United States Sentencing Guidelines range. The court found no abuse of discretion and identified no non-frivolous issues for appeal.
Lasandra Kaye Kearney pled guilty to conspiring to distribute a controlled substance and possessing a firearm as a felon. She appealed after the district court imposed a sentence below the United States Sentencing Guidelines range.
The court’s reasoning
The court concluded the district court did not abuse its discretion in sentencing Kearney. It found the district court properly considered the factors under Section thirty-five fifty-three and did not overlook relevant factors or commit clear errors of judgment. Upon independent review, the court found no non-frivolous issues for appeal.
What it means going forward
The affirmation reinforces the deferential abuse-of-discretion standard applied when district courts sentence below the Guidelines range.
