Background
Del Martinez Evans, Jr. was convicted of multiple bank robberies and sentenced as a career offender. He appealed the sentence, arguing against the career-offender designation.
The court’s reasoning
The court found that any error in applying the career-offender enhancement was harmless because the district court stated the sentence would be the same regardless. The district court considered Evans’s criminal history and disciplinary violations, determining that a 188-month sentence was necessary for deterrence and public protection.
Any error here became harmless the moment the district court made clear that the sentence would be the same, with or without the career-offender enhancement.
United States v. Mejia, 172 F.4th 601, 606 (8th Cir. 2026)
What it means going forward
The decision affirms the district court’s sentence, emphasizing the importance of considering a defendant’s criminal history and potential for reoffending.