United States of America v. Jesse L. Donegan

United States Court of Appeals
For the Eighth Circuit
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No. 25-1994
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Jesse L. Donegan
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Eastern District of Missouri - St. Louis
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Submitted: November 19, 2025
Filed: November 24, 2025
[Unpublished]
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Before LOKEN, KELLY, and ERICKSON, Circuit Judges.
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PER CURIAM.
Jesse Donegan appeals after the district court1 revoked his supervised release
and sentenced him to a prison term within the advisory Guidelines range. On appeal,
1The Honorable Stephen R. Clark, Chief Judge, United States District Court for
the Eastern District of Missouri.

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counsel has moved to withdraw, and filed a brief arguing that the district court plainly
erred in relying upon a sentencing factor listed in 18 U.S.C. § 3553(a)(2)(A).
We conclude Donegan has not established he is entitled to plain-error relief.
See United States v. Jokhoo, 141 F.4th 967, 970 (8th Cir. 2025) (standard of review).
The record shows that the district court clarified it was considering only permissible
sentencing factors in imposing the revocation sentence, and it was not plainly
erroneous for the court to consider the conduct triggering Donegan’s supervised
release violations. See 18 U.S.C. § 3583(e)(3); Esteras v. United States, 606 U.S. 185
(2025) (in revocation proceeding, district court may not consider underlying offense
of conviction for purposes of retribution; taking “no position” on whether court may,
in imposing revocation sentence, consider retribution for failing to abide by
conditions of supervised release).
The judgment is affirmed. Counsel’s motion to withdraw is granted.
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