United States of America v. Ronald Allen Patala, Jr.

24-3255Court of Appeals for the Eighth Circuit30 giu 2026

Testo completo

United States Court of Appeals
For the Eighth Circuit
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No. 25-1613
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United States of America
Plaintiff - Appellee
v.
Ronald Allen Patala, Jr.
Defendant - Appellant
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Appeal from United States District Court
for the Eastern District of Missouri - Cape Girardeau
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Submitted: May 15, 2026
Filed: June 24, 2026
[Unpublished]
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Before COLLOTON, Chief Judge, SHEPHERD and KOBES, Circuit Judges.
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PER CURIAM.
Ronald Allen Patala, Jr., appeals the above-Guidelines-range sentence the
district court1 imposed after he pled guilty to possessing a stolen firearm and being
a felon in possession of a firearm. Without objection by Patala, the district court
1 The Honorable Stephen N. Limbaugh, Jr., United States District Judge for
the Eastern District of Missouri.

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determined the Guidelines sentencing range to be 63 to 78 months’ imprisonment.
However, the district court varied upward and imposed a sentence of 120 months’
imprisonment on each of the two counts of conviction, to run concurrently, followed
by a 3-year term of supervised release. On appeal, Patala contends that the district
court gave too much weight to his criminal history and imposed a substantively
unreasonable sentence. After carefully reviewing the sentencing record and having
jurisdiction under 28 U.S.C. § 1291, we affirm.
“When we review the imposition of sentences, whether inside or outside the
Guidelines range, we apply a deferential abuse-of-discretion standard.” United
States v. Anwar, 880 F.3d 958, 973 (8th Cir. 2018) (citation omitted). A district
court abuses its discretion and imposes a substantively unreasonable sentence when
it: “(1) fails to consider a relevant factor that should have received significant weight;
(2) gives significant weight to an improper or irrelevant factor; or (3) considers only
the appropriate factors but in weighing those factors commits a clear error of
judgment.” United States v. Jones, 89 F.4th 681, 685-86 (8th Cir. 2023) (citation
omitted). Here, the district court expressly stated that it had closely read and
considered all of Patala’s personal information and the presentence report. The
district court further stated that it was considering Patala’s mitigating factors of a
“pretty tough upbringing,” his sister’s death, and his “terrible substance abuse
problem.” However, the district court was entitled to give significant weight to
Patala’s extensive criminal history which includes: a string of vehicle thefts and
possession of a stolen vehicle; misdemeanor child abuse; assault on a peace officer
with a deadly weapon; and, evading a peace officer with wanton disregard for safety.
See United States v. Petersen, 22 F.4th 805, 808 (8th Cir. 2022) (“[C]ourts may vary
upward based on factors already considered under the Guidelines if they determine
‘the weight the Guidelines assigned to a particular factor was insufficient[.]’”
(alteration in original) (citation omitted)).
In short, we find no indication that the district court improperly considered or
weighed the factors. While Patala disagrees with the weight the district court gave
to his criminal record, “[t]he mere fact that a court could have weighed the

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sentencing factors differently does not amount to an abuse of discretion.” United
States v. Campbell, 976 F.3d 775, 778 (8th Cir. 2020) (per curiam) (citation
omitted).
For the foregoing reasons, we affirm the district court.
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