United States of America v. Michael Lee Brunson, also known as Michael Brunson

United States Court of Appeals
For the Eighth Circuit
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No. 24-2356
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Michael Lee Brunson, also known as Michael Brunson
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Northern District of Iowa - Cedar Rapids
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Submitted: August 5, 2026
Filed: August 10, 2026
[Unpublished]
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Before GRUENDER, SHEPHERD, and JUSTIN D. SMITH, Circuit Judges.
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PER CURIAM.
Michael Brunson, who was counseled below but is now proceeding pro se,
appeals after a jury convicted him of drug offenses and the district court1 sentenced
him to life in prison. On appeal, Brunson challenges his conviction and his sentence.
1The Honorable C.J. Williams, Chief Judge, United States District Court for the
Northern District of Iowa.

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Upon careful review, we conclude that the district court did not plainly err by
not sua sponte instructing the jury to disregard a witness’s statement about Brunson
robbing people, by admitting evidence obtained from the cooperation of a co-
conspirator, or by admitting expert testimony about drug trafficking. See United
States v. Sledge, 108 F.4th 659, 666-68 (8th Cir. 2024) (reviewing unobjected-to
error for plain error; to prevail under plain-error review, defendant must show that the
district court committed an error, the error is clear or obvious, and the error affected
his substantial rights). We also conclude that the district court did not abuse its
discretion by admitting evidence from a search of Brunson’s hotel room that took
place outside the time frame of the charged conspiracy. See United States v. Emmert,
825 F.3d 906, 909 (8th Cir. 2016) (reviewing evidentiary rulings for abuse of
discretion).
We further conclude that Brunson did not show the government engaged in
prosecutorial misconduct and that the district court did not abuse its discretion in
denying his motion for a mistrial. See United States v. Wilkens, 742 F.3d 354, 361
(8th Cir. 2014) (to show reversible prosecutorial misconduct, the prosecutor’s
conduct must in fact have been improper, and conduct must have prejudicially
affected the defendant’s substantial rights so as to deprive the defendant of a fair
trial); United States v. Urqhart, 469 F.3d 745, 748-49 (8th Cir. 2006) (denial of
motion for mistrial is reviewed for abuse of discretion).
As to Brunson’s challenges to his sentence, we conclude that the district court
correctly applied the Guidelines; and that the drug quantity and firearm, criminal
livelihood, role, and obstruction enhancements were supported by the evidence
presented at trial. See United States v. Turner, 781 F.3d 374, 393 (8th Cir. 2015)
(construction and application of Guidelines are reviewed de novo; factual findings
are reviewed for clear error). Finally, we conclude that the district court did not
impose a substantively unreasonable sentence. See United States v. Feemster, 572
F.3d 455, 461-62 (8th Cir. 2009) (en banc) (sentences are reviewed for substantive
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reasonableness under deferential abuse of discretion standard; abuse of discretion
occurs when court fails to consider relevant factor, gives significant weight to
improper or irrelevant factor, or commits clear error of judgment in weighing
appropriate factors). The record establishes that the district court adequately
considered the sentencing factors listed in 18 U.S.C. § 3553(a). See United States v.
Callaway, 762 F.3d 754, 760 (8th Cir. 2014) (on appeal, within-Guidelines-range
sentence may be presumed reasonable).
Accordingly, we affirm.
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