Kevin Adams appealed his criminal sentence following a district court ruling that revoked his supervised release. The district court sentenced him to 22 months in prison and one year of supervised release with special conditions. Adams's counsel challenged the substantive reasonableness of the sentence, arguing that the district court's decision was flawed.
The Eighth Circuit, in a per curiam opinion, reviewed the record to determine if the district court abused its discretion. The court applied the standard that a sentence is unreasonable only if the district court fails to consider relevant factors, gives significant weight to an improper or irrelevant factor, or commits a clear error of judgment. The court noted that revocation sentences within the Guidelines range are accorded a presumption of substantive reasonableness. Upon review, the court concluded that Adams's sentences were not unreasonable because there was no indication that the district court failed to consider relevant factors or committed a clear error of judgment.
The decision affirms the 22-month prison sentence and the revocation of supervised release. It reinforces the principle that sentences within the Guidelines range are presumed reasonable, making it difficult for appellants to overturn such sentences absent a clear showing that the district court ignored relevant factors or made a clear error of judgment. The case is remanded to the district court for enforcement of the sentence.