June 1, 2026·25-3399·Panel Decision·By James Taylor
The Eighth Circuit affirmed a revocation sentence for supervised release, finding no abuse of discretion in the district court's application of sentencing factors. The court also granted the defendant's counsel's motion to withdraw from the appeal.
Background
Maurice Cowan appealed a revocation sentence imposed after the district court revoked his supervised release for two separate convictions. His counsel filed a brief challenging the substantive reasonableness of the sentence before moving to withdraw.
The court’s reasoning
The court concluded that the sentence was not unreasonable. It found no indication that the district court failed to consider the factors under Section thirty-five fifty-three of Title eighteen of the United States Code, gave significant weight to an improper factor, or committed a clear error of judgment.
What it means going forward
The decision reinforces the standard of review for supervised release revocations, confirming that sentences within the Guidelines range are presumed reasonable absent clear error in the district court’s weighing of factors.
