United States of America v. Jennifer Lynn Haxton

United States Court of Appeals
For the Eighth Circuit
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No. 24-2574
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United States of America
Plaintiff - Appellee
v.
Jennifer Lynn Haxton
Defendant - Appellant
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Appeal from United States District Court
for the Northern District of Iowa - Central
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Submitted: February 14, 2025
Filed: March 13, 2025
[Unpublished]
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Before COLLOTON, Chief Judge, ERICKSON and GRASZ, Circuit Judges.
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PER CURIAM.
In October 2019, Jennifer Lynn Haxton was released to supervision after
completing a term of imprisonment for conspiracy to distribute methamphetamine,
in violation of 21 U.S.C. §§ 841(b)(1)(B) and 846. Her initial term of supervised
release was revoked in September 2023, and she was sentenced to an additional term
of imprisonment and supervised release. After she violated the conditions of her

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second term of supervised release, the district court1 revoked supervision and
imposed an 8-month imprisonment term with no additional supervision. Haxton
appeals contending her sentence is substantively unreasonable. We affirm.
While on supervision, Haxton struggled to maintain sobriety and comply with
drug testing requirements. After admitting at her most recent revocation hearing that
she continued to use drugs while on supervision, that she failed to comply with drug
testing, and that she had associated with felons, Haxton asked the court to place her
back on supervision with stricter conditions, including home detention. Haxton
explained that she had an infant son, and a custodial sentence could affect her
parental rights. She noted her struggles with addiction and postpartum depression
and had found treatment providers that would allow her to reside with her child.
The district court acknowledged the mitigating factors but concluded
revocation was mandatory under 18 U.S.C. § 3583(g)(4) because Haxton had
repeatedly tested positive for illegal controlled substances. The court explained that
Huxton did not qualify for an exception to the revocation requirement due to her
history of repeated failure to comply with drug testing and treatment. See 18 U.S.C.
§ 3583(d) (requiring courts to consider “whether the availability of appropriate
substance abuse treatment programs, or an individual’s current or past participation
in such programs, warrants an exception” from the mandatory revocation and
imprisonment under § 3583(g)). The court calculated an advisory Sentencing
Guidelines range of 6 to 12 months’ imprisonment and decided to impose a sentence
of 8 months with no supervision to follow.
We review revocation sentences for abuse of discretion. United States v.
Scherer, 114 F.4th 987, 990 (8th Cir. 2024). A district court abuses its discretion if
it (1) fails to consider a relevant sentencing factor; (2) gives significant weight to an
improper or irrelevant factor; or (3) commits a clear error of judgment in weighing
1 The Honorable Leonard T. Strand, United States District Judge for the
Northern District of Iowa.

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the appropriate factors. United States v. Ali, 799 F.3d 1008, 1033 (8th Cir. 2015).
When imposing a revocation sentence, the district court must consider the factors set
forth in 18 U.S.C. § 3553(a), as identified in § 3583(e). United States v. Clark, 998
F.3d 363, 368 (8th Cir. 2021). We presume a within-Guidelines sentence is
reasonable. United States v. Goodale, 738 F.3d 917, 926 (8th Cir. 2013). The
defendant bears the burden of rebutting that presumption. Id.
The record reflects the district court did consider Haxton’s arguments
regarding supervised release with stricter conditions, parental responsibilities, and
treatment options. See United States v. Keating, 579 F.3d 891, 893 (8th Cir. 2009)
(explaining we may presume the district court considered arguments raised before it
when it imposed a sentence). After weighing the applicable factors, the district court
found that Haxton’s history and characteristics—particularly her repeated failures to
complete drug treatment and association with felons—warranted greater weight. A
district court’s decision to emphasize certain factors supporting a sentence, rather
than those that might have justified a more lenient sentence, is within its broad
discretion. See United States v. Wilkins, 909 F.3d 915 (8th Cir. 2018). To establish
substantive unreasonableness, Haxton “must show more than the fact that the district
court disagreed with [her] view of what weight ought to be accorded certain
sentencing factors.” United States v. Townsend, 617 F.3d 991, 995 (8th Cir. 2010)
(per curiam). Haxton’s mere disagreement with the sentence imposed does not merit
reversal. See United States v. Isler, 983 F.3d 335, 344 (8th Cir. 2020).
The district court’s judgment is affirmed.
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