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Criminal Law-Drug and Firearm Offenses-Appeal Waiver-Substantive Unreasonableness of Sentence

Staff Report//February 11, 2026//

Criminal Law-Drug and Firearm Offenses-Appeal Waiver-Substantive Unreasonableness of Sentence

Staff Report//February 11, 2026//

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Defendant challenged the substantive reasonableness of the below-Guidelines sentence imposed following his conviction for drug and firearm offenses pursuant to a plea agreement containing an appeal waiver.

Where defendant’s appeal waiver barred his challenges to his conviction and where the district court stated it would have imposed the same sentence regardless of the drug quantity, the court found no abuse of sentencing discretion.

Judgment is affirmed.

U.S. v. Beaty (MLW No. 84314/Case No. 25-1355 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Southern District of Iowa, Ebinger, J.

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