United States of America v. James Marcus Dyett

United States Court of Appeals
For the Eighth Circuit
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No. 26-1474
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
James Marcus Dyett
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Eastern District of Missouri - St. Louis
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Submitted: August 6, 2026
Filed: August 11, 2026
[Unpublished]
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Before KELLY, KOBES, and JUSTIN D. SMITH, Circuit Judges.
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PER CURIAM.
James Dyett appeals the sentence the district court1 imposed after he pleaded
guilty to a money laundering offense pursuant to a written plea agreement containing
1The Honorable John A. Ross, United States District Judge for the Eastern
District of Missouri.

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a limited appeal waiver. His counsel has moved for leave to withdraw and has filed
a brief under Anders v. California, 386 U.S. 738 (1967), arguing that the district court
erred by denying a minor-role reduction and imposing a special condition of
supervised release authorizing searches of Dyett’s person and property; and that the
sentence was substantively unreasonable.
Setting aside whether Dyett waived the minor-role reduction argument at
sentencing, we conclude that the district court did not clearly err in declining to apply
a minor-role reduction, as the facts indicate that Dyett participated in an illegal money
laundering scheme by making fraudulent representations and moving large sums of
money. See United States v. Mitchell, 613 F.3d 862, 870 (8th Cir. 2010) (standard
of review; fact that defendant was less culpable than his friend in money laundering
conspiracy did not make his role minor); United States v. Rodamaker, 56 F.3d 898,
904 (8th Cir. 1995) (defendant was fairly on notice that district court may sua sponte
deny minor-role reduction; court did not clearly err in denying minor-role reduction
because, although defendant may have been less culpable, she played major and
important role in scheme); see also United States v. Wilson, 102 F.3d 968, 973 (8th
Cir. 1996) (defendant who is concededly less culpable than co-defendants is not
entitled to minor-participant reduction if defendant was “deeply involved” in criminal
acts). We enforce the appeal waiver as to counsel’s arguments challenging the
reasonableness of the sentence and the search condition. See United States v. Scott,
627 F.3d 702, 704 (8th Cir. 2010); United States v Andis, 333 F.3d 886, 889-92 (8th
Cir. 2003) (en banc).
We have also independently reviewed the record under Penson v. Ohio, 488
U.S. 75 (1988), and have found no non-frivolous issues for appeal outside the scope
of the appeal waiver. Accordingly, we affirm the district court’s denial of a minor-
role reduction, dismiss the remainder of the appeal, and grant counsel’s motion to
withdraw.
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