May 28, 2026·25-2393·Panel Decision·By James Taylor
The Eighth Circuit affirmed the district court's decision to revoke supervised release and impose sentences in two consolidated cases. The court rejected the defendant's claims of ineffective assistance of counsel and substantive unreasonableness.
Adrian Rogers appealed sentences imposed by the United States District Court for the Southern District of Iowa after his supervised release was revoked in two cases. His counsel moved to withdraw, arguing the sentences were substantively unreasonable, while Rogers filed a pro se brief claiming the sentences were excessive and that he received ineffective assistance of counsel.
The court’s reasoning
The court concluded that the district court did not abuse its discretion in imposing the sentences. The court declined to consider the ineffective-assistance-of-counsel claims on direct appeal, citing established precedent.
What it means going forward
The decision affirms the revocation of supervised release and the resulting sentences, while directing that counsel may need to advise the defendant of the option to seek Supreme Court review.
