United States of America v. Alexander Laurel-Olea

United States Court of Appeals
For the Eighth Circuit
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No. 24-2479
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United States of America,
lllllllllllllllllllllPlaintiff - Appellee,
v.
Alexander Laurel-Olea,
lllllllllllllllllllllDefendant - Appellant.
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Appeal from United States District Court
for the Northern District of Iowa - Western
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Submitted: March 17, 2025
Filed: July 16, 2025
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Before COLLOTON, Chief Judge, ERICKSON and GRASZ, Circuit Judges.
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COLLOTON, Chief Judge.
Alexander Laurel-Olea pleaded guilty to unlawful possession of a firearm as
an unlawful user of a controlled substance. See 18 U.S.C. § 922(g)(3). The district

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court* sentenced Laurel-Olea to twenty-four months’ imprisonment and thirty-six
months of supervised release.
Laurel-Olea served his sentence and began his term of supervised release on
August 30, 2022. In June 2024, Laurel-Olea was arrested by the United States
Marshals Service after committing fifty-four violations of his conditions of
supervised release. The district court sentenced Laurel-Olea to fourteen months’
imprisonment and a one-year term of supervised release. On appeal, Laurel-Olea
argues his revocation sentence is unreasonable under 18 U.S.C. § 3583(e).
We review the reasonableness of a revocation sentence under a deferential
abuse-of-discretion standard. United States v. Michels, 49 F.4th 1146, 1148 (8th Cir.
2022). A district court abuses its discretion when it fails to consider a relevant factor
that should have received significant weight, gives significant weight to an improper
or irrelevant factor, or considers only the appropriate factors but in weighing them
commits a clear error of judgment. United States v. Fitzpatrick, 943 F.3d 838, 840
(8th Cir. 2019). “[I]t will be the unusual case when we reverse a district court
sentence—whether within, above, or below the applicable Guidelines range—as
substantively unreasonable.” United States v. Feemster, 572 F.3d 455, 464 (8th Cir.
2009) (en banc).
Laurel-Olea argues that the district court abused its discretion by imposing a
sentence above the advisory guideline range that was “not proportionate to the
offense” and that “did not sufficiently account for Mr. Laurel-Olea’s mental health
issues, his background, and his potential for successful reintegration into society.”
*The Honorable Leonard T. Strand, United States District Judge for the
Northern District of Iowa.
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At the revocation hearing, the district court determined that the grade of
violation and Laurel-Olea’s criminal history resulted in an advisory guideline range
of three to nine months’ imprisonment. The court then considered aggravating and
mitigating factors.
In mitigation, the court cited Laurel-Olea’s age of twenty-four years old, his
lack of an adult criminal history, his mental health and substance abuse issues, and
his acceptance of responsibility. The court also considered aggravating factors:
Laurel-Olea’s underlying offense conduct involved formulating a plan that resulted
in a dangerous shooting of a home in Sioux City. Laurel-Olea committed fifty-four
violations of his conditions of release, including twenty-four skipped drug tests. He
became a fugitive from justice, and his whereabouts were unknown for roughly six
weeks until he was located by the Marshals Service. Laurel-Olea also made no
efforts to meet his restitution obligation of $38,000.
The district court concluded that an upward variance from nine months to
fourteen months’ imprisonment was appropriate. The court explained that it would
have selected a term of eighteen months, but wanted to give Laurel-Olea some credit
for accepting responsibility. Given the several aggravating factors involved and the
deference afforded to the sentencing court, the district court did not abuse its
discretion in imposing a term of fourteen months.
The judgment of the district court is affirmed.
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