United States of America v. Alaya Rahm

United States Court of Appeals
For the Eighth Circuit
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No. 24-3625
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Alaya Rahm
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Western District of Arkansas - Fayetteville
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Submitted: June 9, 2026
Filed: June 12, 2026
[Unpublished]
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Before SMITH, ERICKSON, and STRAS, Circuit Judges.
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PER CURIAM.

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Alaya Rahm appeals the sentence the district court1 imposed after he pleaded
guilty to a drug offense. He challenges a drug-premises enhancement and argues his
sentence is substantively unreasonable.
Upon careful review, we conclude the district court did not clearly err by
concluding that Rahm maintained a drug premises. See United States v. Clark, 135
F.4th 622, 625 (8th Cir. 2025); United States v. Miller, 698 F.3d 699, 706-07 (8th Cir.
2012). We also conclude the sentence is substantively reasonable. See United States
v. Feemster, 572 F.3d 455, 461-62 (8th Cir. 2009) (en banc) (reviewing sentence
under deferential abuse-of-discretion standard; discussing substantive
reasonableness); United States v. McCauley, 715 F.3d 1119, 1127 (8th Cir. 2013)
(noting when district court has varied below Guidelines range, it is “nearly
inconceivable” that court abused its discretion by not varying downward further).
Accordingly, we affirm.
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1The Honorable Timothy L. Brooks, Chief Judge, United States District Court
for the Western District of Arkansas.
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