United States of America v. Napoleon Alexander Jackson

United States Court of Appeals
For the Eighth Circuit
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No. 25-1249
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Napoleon Alexander Jackson
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Southern District of Iowa - Eastern
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Submitted: August 26, 2025
Filed: August 29, 2025
[Unpublished]
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Before SMITH, SHEPHERD, and ERICKSON, Circuit Judges.
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PER CURIAM.
Napoleon Jackson appeals after the district court1 revoked his supervised
release for the second time. His counsel has moved to withdraw and has filed a brief
1The Honorable Rebecca Goodgame Ebinger, United States District Judge for
the Southern District of Iowa.

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challenging the substantive reasonableness of the sentence. In a pro se filing, Jackson
raises procedural challenges and contests the reasonableness of the sentence.
Having carefully reviewed the record, we conclude that the district court did
not plainly err when calculating the revocation Guidelines range. See, e.g., United
States v. Cotton, 108 F.4th 987, 988-91 (7th Cir. 2024), cert. denied, 145 S. Ct. 1214
(2025). We further conclude that the sentence is not substantively unreasonable, as
the court sufficiently considered the applicable statutory sentencing factors and did
not overlook a relevant factor, give significant weight to an improper or irrelevant
factor, or commit a clear error of judgment in weighing relevant factors. See 18
U.S.C. §§ 3553(a), 3583(e)(3); United States v. Miller, 557 F.3d 910, 917 (8th Cir.
2009) (reviewing revocation sentence under deferential abuse-of-discretion standard).
The court considered Jackson’s mitigating factors, see United States v. Timberlake,
679 F.3d 1008, 1012 (8th Cir. 2012), and did not abuse its wide discretion by giving
greater weight to aggravating factors, see United States v. Pratt, 142 F.4th 1090,
1094-95 (8th Cir. 2025), or by declining to impose a lower sentence due to changes
in the law, see United States v. Mays, 967 F.3d 748, 754 (8th Cir. 2020).
Finally, Jackson suffered no prejudice relating to the character letters that the
court read and considered at the revocation hearing, see Miller, 557 F.3d at 916; he
cannot use the revocation proceedings to collaterally attack his state convictions, see
28 U.S.C. § 2254; the court acted within its discretion by running his revocation
prison sentence consecutively to his state court sentence, see 18 U.S.C. § 3584(a)-(b);
United States v. Johnson, 827 F.3d 740, 745 (8th Cir. 2016); and the new supervised-
release term was not an additional punishment, see United States v. Watters, 947 F.3d
493, 496-97 (8th Cir. 2020).
Accordingly, we affirm the judgment and grant counsel’s motion to withdraw.
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