United States of America v. Joe L. Franklin

United States Court of Appeals
For the Eighth Circuit
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No. 25-2788
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Joe L. Franklin
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Eastern District of Arkansas - Central
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Submitted: February 19, 2026
Filed: February 24, 2026
[Unpublished]
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Before LOKEN, SMITH, and GRASZ, Circuit Judges.
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PER CURIAM.
Joe Franklin appeals after the district court1 revoked his supervised release and
sentenced him to 36 months in prison with 2 years of additional supervised release.
1The Honorable Kristine G. Baker, Chief Judge, United States District Court
for the Eastern District of Arkansas.

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His counsel, who has moved to withdraw, has filed a brief challenging the
reasonableness of the sentence and the imposition of a special condition of release,
and identifying an apparent clerical error with the written judgment.
After careful review, we conclude the district court did not commit plain
procedural error when addressing the statutory sentencing factors, as it was not
required to mechanically list the factors, see 18 U.S.C. §§ 3553(a); 3583(e), (c);
United States v. McGhee, 869 F.3d 703, 705, 706 (8th Cir. 2017) (per curiam); it
presumably considered the parties’ arguments on relevant factors, see United States
v. Beckwith, 57 F.4th 630, 633 (8th Cir. 2023) (per curiam); and a fair reading of the
record reflects that the court limited its analysis to consideration of relevant factors,
see Esteras v. United States, 606 U.S. 185, 202-03 (2025) (explaining the standard
of review); United States v. Pratt, 142 F.4th 1090, 1095 (8th Cir. 2025) (concluding
the district court did not plainly err by considering defendant’s noncompliance while
on supervision).
We further conclude the district court did not plainly err by reimposing a
special condition of release requiring Franklin to “comply with any referral deemed
appropriate by the United States Probation Office for in-patient or out-patient
evaluation, treatment, counseling, or testing for substance abuse, including urinalysis
for testing purposes.” Franklin did not contest that condition when it was originally
imposed, see, e.g., United States v. Lincoln, 876 F.3d 1137, 1140-41 (8th Cir. 2017),
and, regardless, the court did not impermissibly delegate its authority, see United
States v. Conelly, 451 F.3d 942, 944-45 (8th Cir. 2006) (reviewing improper-
delegation challenge for plain error when defendant did not object in district court,
and finding no such error because the district court “made no statements indicating
it relinquished authority over the conditions of [defendant’s] supervised release”).
Accordingly, we affirm the judgment, and we grant counsel’s motion to
withdraw.
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