United States v. Charles Eagle Pipe

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to domestic assault by an habitual offender. The court held that defendant's sentence was not procedurally unreasonable, because the district court sufficiently explained that its decision to depart upward because defendant's criminal history category substantially underrepresented the seriousness of his criminal history. Furthermore, there was no error, much less plain error, in the district court's comments lamenting the prevalence of domestic violence on the Standing Rock reservation and surmising that defendant may have committed other acts of domestic violence where such crimes often go unreported. Finally, defendant's sentence was not substantively unreasonable where the district court imposed a well-supported, fully explained USSG 4A1.3 upward departure and then varied slightly downward from the revised advisory guidelines. View "United States v. Charles Eagle Pipe" on Justia Law