United States of America v. Brian Darnell Brown

United States Court of Appeals
For the Eighth Circuit
___________________________
No. 25-2958
___________________________
United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Brian Darnell Brown
lllllllllllllllllllllDefendant - Appellant
____________
Appeal from United States District Court
for the Eastern District of Arkansas - Central
____________
Submitted: April 30, 2026
Filed: May 5, 2026
[Unpublished]
____________
Before LOKEN, SMITH, and BENTON, Circuit Judges.
____________
PER CURIAM.
Brian Brown appeals after the district court1 revoked his supervised release and
sentenced him to 10 months in prison and 2 years of supervised release. On appeal,
1The Honorable Brian S. Miller, United States District Judge for the Eastern
District of Arkansas.

-- 1 of 2 --

Brown contends that the district court committed a procedural error and imposed a
substantively unreasonable revocation sentence.
Having carefully reviewed the record and the parties’ arguments on appeal, we
conclude that no significant procedural error occurred, and Brown’s revocation
sentence was not substantively unreasonable. See United States v. Tumea, 103 F.4th
1349, 1352 (8th Cir. 2024) (procedural errors include selecting sentence based on
clearly erroneous facts; unobjected-to procedural sentencing error is reviewed under
plain error standard); United States v. O’Connor, 567 F.3d 395, 397 (8th Cir. 2009)
(substantive reasonableness is reviewed under deferential abuse-of-discretion
standard; sentence may be unreasonable if district court fails to consider relevant
factor, gives significant weight to improper factor, or commits clear error of
judgment); see also United States v. Beckwith, 57 F.4th 630, 632 (8th Cir. 2023) (per
curiam) (revocation sentence within Guidelines range is accorded presumption of
substantive reasonableness on appeal).
Accordingly, we affirm.
______________________________
-2-

-- 2 of 2 --