Case Explained: United States of America v. Dymond Rene Hayden

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-07-06

The Eighth Circuit affirmed the district court’s sentence, rejecting Dymond Hayden’s argument that his prior Minnesota third-degree murder conviction did not qualify as a “crime of violence” under U.S.S.G. § 4B1.2(a). The court applied de novo review to the district court’s application of the Sentencing Guidelines and its determination of whether the prior conviction constituted a crime of violence. The court held that Minnesota third-degree murder falls within the enumerated offenses clause of the Guidelines because it substantially corresponds to “generic” murder. In adopting the definition of generic murder established by the Third Circuit in *United States v. Marrero*, the Eighth Circuit defined generic murder as causing death intentionally, during a dangerous felony, or through conduct evincing reckless and depraved indifference to serious dangers posed to human life. The court found that Minnesota’s statute, which criminalizes causing death by an act eminently dangerous to others while evincing a depraved mind without regard for human life, aligns with this definition of “depraved heart murder.” Consequently, the district court correctly applied the sentencing enhancement based on this prior conviction. As a result of this ruling, the judgment of the district court is affirmed, and Hayden’s sentence stands as imposed.

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