United States of America v. Sonia Campos

United States Court of Appeals
For the Eighth Circuit
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No. 22-3454
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United States of America
Plaintiff - Appellee
v.
Sonia Campos
Defendant - Appellant
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Appeal from United States District Court
for the Western District of Arkansas - Fayetteville
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Submitted: May 8, 2023
Filed: June 1, 2023
[Unpublished]
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Before SHEPHERD, STRAS, and KOBES, Circuit Judges.
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PER CURIAM.
Sonia Campos’s supervised release was revoked after she tested positive for
methamphetamine six times. She appeals both the revocation of her supervised
release and the substantive reasonableness of her resulting sentence. We affirm.

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We review the district court’s1 decision to revoke Campos’s supervised
release and the reasonableness of her resulting sentence for an abuse of discretion.
United States v. Miller, 557 F.3d 910, 914–16 (8th Cir. 2009). We may presume
that Campos’s within-Guidelines sentence is reasonable. United States v. Feemster,
572 F.3d 455, 461 (8th Cir. 2009) (en banc).
Campos argues that the district court should have given her another chance at
drug treatment and imposed a term of home confinement instead of revoking her
supervised release. She acknowledges that 18 U.S.C. § 3583(g)(4) requires a
person’s supervised release to be revoked when they have had more than three
positive drug tests within one year. Nonetheless, she argues that the district court
should have considered whether the availability of substance abuse treatment
warrants an exception to § 3583(g)(4)’s mandatory revocation. See 18 U.S.C.
§ 3583(d).
The district court determined that home confinement with drug treatment
would not be appropriate for Campos. It explained that Campos was given several
chances, as well as opportunities for drug treatment, but continued to test positive
for meth. In terms of home confinement, the district court felt that Campos would
be willing to do anything for drugs, and that GPS tracking would not prevent others
from bringing drugs into her home. The record demonstrates that the district court
was aware that there were alternatives to prison for Campos and did not abuse its
discretion. See United States v. Kaniss, 150 F.3d 967, 969 (8th Cir. 1998).
In the same vein, Campos argues that her eight-month prison sentence is
substantively unreasonable because the district court should have sentenced her to
home confinement so she could participate in drug treatment with the support of her
family. See United States v. Jones, 507 F.3d 657, 659 (8th Cir. 2007) (“A district
court abuses its discretion by . . . committing a clear error of judgment in weighing
1 The Honorable Timothy L. Brooks, United States District Judge for the
Western District of Arkansas.

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the relevant factors by arriving at a sentence outside the range of choice dictated by
the facts of the case.”). But the record demonstrates that the district court considered
this and determined that incarceration was the best option for preventing Campos
from getting drugs. Last, Campos argues her two year and four-month term of
supervised release is substantively unreasonable. We disagree. Campos tested
positive for meth six times within ten months of beginning a four-year term of
supervised release. In light of this history, it was reasonable for the district court to
sentence her to over two years of supervised release.
The district court did not abuse its discretion, and we affirm.
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