United States of America v. Philip Anthony Maheia

United States Court of Appeals
For the Eighth Circuit
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No. 25-1108
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Philip Anthony Maheia
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Southern District of Iowa - Central
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Submitted: April 30, 2026
Filed: May 5, 2026
[Unpublished]
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Before SHEPHERD, ERICKSON, and KOBES, Circuit Judges
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PER CURIAM.
Philip Maheia appeals the 120-month mandatory minimum sentence the district
court1 imposed after he pleaded guilty to a drug offense. He argues that the court
1The Honorable Stephanie M. Rose, Chief Judge, United States District Court
for the Southern District of Iowa.

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erred in applying a 2-level aggravating-role enhancement, and as a result, he qualifies
for safety-valve relief under 18 U.S.C. § 3553(f).
Upon careful review, we conclude that the district court did not err in applying
the enhancement. See United States v. Turner, 781 F.3d 374, 393 (8th Cir. 2015)
(standard of review); United States v. Irlmeier, 750 F.3d 759, 764 (8th Cir. 2014)
(defendants are subject to role enhancement even when they manage or supervise
only one other participant in the conspiracy in a single transaction); United States v.
Brown Bull, 138 F.4th 1083, 1090 (8th Cir. 2025) (although fronting, without more,
is not sufficient to support an aggravating-role enhancement, fronting “tends to refute
the notion the defendant is merely participating in a typical buyer-seller relationship,”
as defendant “retained the financial risk of distribution” and “overstepped a mere
seller’s role”). Therefore, Maheia’s safety-valve argument is foreclosed. See 18
U.S.C. § 3553(f)(4) (defendant qualifies for safety-valve application if, among other
things, he was not an organizer, leader, manager, or supervisor of others in the
offense).
Accordingly, we affirm.
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