United States of America v. Jaisaun Antonio Holt

United States Court of Appeals
For the Eighth Circuit
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No. 24-2346
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United States of America
Plaintiff - Appellee
v.
Jaisaun Antonio Holt
Defendant - Appellant
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Appeal from United States District Court
for the District of North Dakota - Western
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Submitted: May 7, 2026
Filed: May 12, 2026
[Unpublished]
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Before BENTON, GRASZ, and STRAS, Circuit Judges.
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PER CURIAM.
Jaisaun Holt appeals the sentence imposed by the district court1 after he pled
guilty to drug offenses. Having jurisdiction under 28 U.S.C. § 1291, this court
affirms.
1 The Honorable Daniel L. Hovland, United States District Judge for the
District of North Dakota.

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-2-
Holt argues the district court erred in treating his prior assault conviction as a
career-offender predicate because he received the conviction pursuant to a nolo
contendere plea. Holt’s argument is foreclosed by this court’s precedent. See United
States v. Harris, 36 F.4th 827, 830 (8th Cir. 2022) (per curiam) (standard of review);
United States v. Grimes, 702 F.3d 460, 470 (8th Cir. 2012) (conviction pursuant to
plea of nolo contendere qualified as conviction for purpose of determining whether
defendant was career offender under U.S.S.G. § 4B1.1). Further, the district court
correctly determined that it need not address Holt’s objections to various
enhancements, because his career-offender status controlled his applicable offense
level. See Fed. R. Crim. P. 32(i)(3)(B).
The judgment is affirmed.
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