United States of America v. Jonathan Edward Meier

United States Court of Appeals
For the Eighth Circuit
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No. 24-2886
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Jonathan Edward Meier
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Northern District of Iowa - Central
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Submitted: June 13, 2025
Filed: June 18, 2025
[Unpublished]
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Before SMITH, KELLY, and KOBES, Circuit Judges.
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PER CURIAM.
Jonathan Meier appeals the district court’s1 judgment revoking his supervised
release and sentencing him to a within-Guidelines prison term of 12 months and a
1The Honorable Leonard T. Strand, United States District Judge for the
Northern District of Iowa.

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day, to be followed by one year and 364 days of supervision. Having carefully
reviewed Meier’s arguments for reversal, we disagree with his contention that the
revocation judgment violated his constitutional right to a jury trial and that 18 U.S.C.
§ 3583(e)(3) is therefore unconstitutional as applied to him. See United States v.
Childs, 17 F.4th 790, 791 (8th Cir. 2021) (reviewing de novo legality of revocation
sentence, and noting that proceedings under § 3583(e)(3) permit finding of violation
by preponderance of evidence by district court). We also conclude that Meier did not
identify a due process violation, establish that his sentence violated the Eighth
Amendment, establish that the district court failed to give sufficient weight to his
completion of a treatment program, or establish that the district court committed plain
error by imposing a special condition that Meier spend up to 90 days in a residential
reentry center upon his release from custody, an unfulfilled requirement imposed in
a prior order modifying the conditions of supervision with Meier’s consent.
Accordingly, the judgment of the district court is affirmed and Meier’s pending
motion is denied as moot.
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