June 12, 2026·24-3625·Panel Decision·By James Taylor
The United States Court of Appeals for the Eighth Circuit affirmed the sentence imposed on Alaya Rahm for a drug offense. The court found no clear error in the district court's application of a drug-premises enhancement and determined the sentence was substantively reasonable.
Alaya Rahm appealed his sentence following a guilty plea to a drug offense. He challenged a drug-premises enhancement and argued that his sentence was substantively unreasonable.
The court’s reasoning
The court concluded that the district court did not clearly err in finding that Rahm maintained a drug premises, citing United States v. Clark and United States v. Miller. The court further determined the sentence was substantively reasonable, applying the deferential abuse-of-discretion standard and noting that it is nearly inconceivable for a court to abuse its discretion by not varying downward further when the district court has already varied below the Guidelines range.
What it means going forward
This decision reinforces the Eighth Circuit’s deferential review of district court sentencing determinations in drug cases, particularly regarding drug-premises enhancements and substantive reasonableness.
