United States of America v. Joel M. Hale

United States Court of Appeals
For the Eighth Circuit
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No. 24-2510
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United States of America
Plaintiff - Appellee
v.
Joel M. Hale
Defendant - Appellant
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Appeal from United States District Court
for the Western District of Missouri
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Submitted: May 12, 2025
Filed: August 7, 2025
[Unpublished]
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Before BENTON, KELLY, and GRASZ, Circuit Judges.
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PER CURIAM.
The district court1 revoked Joel Hale’s supervised release and sentenced him
to 24 months of imprisonment after Hale violated his conditions of supervised
release by committing a new crime, specifically eluding the police. Hale appeals,
1 The Honorable Gary A. Fenner, United States District Judge for the Western
District of Missouri.

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arguing that his revocation sentence is substantively unreasonable because the
district court failed to give proper weight to mitigating factors. We affirm.
We review the substantive reasonableness of a sentence for abuse of
discretion. United States v. Holmes, 87 F.4th 910, 916 (8th Cir. 2023). “A district
court abuses its discretion when it ‘fails to consider a relevant and significant factor,
gives significant weight to an irrelevant or improper factor, or considers the
appropriate factors but commits a clear error of judgment in weighing those
factors.’” Id. (quoting United States v. Doerr, 42 F.4th 914, 918 (8th Cir. 2022)). A
district court is not required to specifically address each relevant sentencing factor
or mitigation argument raised by defense counsel. United States v. Ruiz-Salazar,
785 F.3d 1270, 1273 (8th Cir. 2015). When, as here, a defendant receives a sentence
within the advisory sentencing range, we presume the sentence is substantively
reasonable. See id. at 1272.
Hale does not overcome this presumption of reasonableness. Hale contends
the district court should have imposed a shorter sentence than the statutory maximum
because this was his first revocation, he conceded the violation, and he committed a
Grade “B” violation, rather than a Grade “A” violation. But Hale’s belief that the
district court should “have afforded more weight to the mitigating circumstances in
this case” is insufficient to show an abuse of discretion. See Holmes, 87 F.4th at
917. The district court explained Hale’s conduct constituting the violation — twice
fleeing from law enforcement at high speeds in a residential neighborhood and
“recklessly endanger[ing] innocent people on the street.” It then noted it considered
all of the relevant statutory factors and concluded 24 months of imprisonment was
an appropriate sentence. While the district court’s explanation of the sentence was
brief, it did not fail to consider a relevant factor or Hale’s mitigation arguments.
Under these circumstances, we conclude Hale’s sentence is not substantively
unreasonable. See Ruiz-Salazar, 785 F.3d at 1272–73.
We therefore affirm the judgment of the district court.
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