United States of America v. Karom Bol

United States Court of Appeals
For the Eighth Circuit
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No. 24-2529
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Karom Bol
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Northern District of Iowa - Western
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Submitted: February 13, 2025
Filed: March 12, 2025
[Unpublished]
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Before GRUENDER, KELLY, and STRAS, Circuit Judges.
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PER CURIAM.
Karom Bol appeals the sentence the district court1 imposed after he pled guilty
to drug and firearms offenses. His counsel has moved for leave to withdraw, and has
1The Honorable Leonard T. Strand, United States District Judge for the
Northern District of Iowa.

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filed a brief under Anders v. California, 386 U.S. 738 (1967), challenging the
constitutionality of the federal firearms statute. Bol has filed a supplemental pro se
brief, challenging the factual basis underlying his conviction.
We conclude the federal firearms statute prohibiting possession of firearms in
furtherance of drug trafficking crimes is facially constitutional. See United States v.
Howell, 552 F.3d 709, 712 (8th Cir. 2009) (reviewing the constitutionality of federal
statutes de novo); United States v. Rahimi, 602 U.S. 680, 693 (2024) (holding that the
Second Amendment permits disarmament of individuals who pose a credible threat
to the physical safety of others). As to Bol’s arguments regarding the factual basis
for his conviction, we conclude that his statements under oath, the undisputed facts
set forth in the presentence investigation report, and his guilty plea are sufficient to
support his conviction. See United States v. Belmont, 831 F.3d 1098, 1102-03 (8th
Cir. 2016) (reviewing a challenge to the legal sufficiency of an undisputed factual
basis de novo); United States v. Christenson, 653 F.3d 697, 700 (8th Cir. 2011)
(noting that appellate review of the factual basis for a guilty plea is limited to whether
there was sufficient evidence before the district court to reasonably determine that the
defendant likely committed the offense, which may include the colloquy between the
defendant and the court, stipulated facts, and the facts set forth in a presentence
report); Nguyen v. United States, 114 F.3d 699, 703 (8th Cir. 1997) (emphasizing that
a defendant’s statements made during a plea hearing carry a strong presumption of
verity).
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. Accordingly, we
grant counsel’s motion to withdraw and affirm.
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