United States of America v. Andrew Kenneth Woock-Shelton
March 11, 2026·25-2302·Panel Decision·By James Taylor
The Eighth Circuit affirmed the sentence imposed on a defendant convicted of being a felon in possession of a firearm. The court granted counsel's motion to withdraw after finding no non-frivolous issues for appeal.
Andrew Woock-Shelton appealed his sentence following a guilty plea to being a felon in possession of a firearm. His counsel moved to withdraw, filing a brief under Anders v. California and arguing the district court erred in applying a cross-reference to the Guidelines provision for attempted murder.
The court’s reasoning
The court concluded the district court did not err in calculating the Guidelines range using the cross-reference. The court reviewed the record independently under Penson v. Ohio and found no non-frivolous issues for appeal.
What it means going forward
The sentence stands, and appellate counsel is permitted to withdraw from the case.
