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Criminal Law-Burglary-Crime of Violence-Revocation of Supervised Release
Staff Report//May 20, 2026//
Defendant appealed the sentence imposed following the revocation of his supervised release. Defendant committed first-degree burglary under Iowa law. The district court considered the specifics of defendant’s offense and determined that it was a crime of violence, constituting a grade A violation of defendant’s supervised release. On appeal, defendant argued that the district court should have used the categorical approach in determining whether he had committed a crime of violence.
Where established precedent held that the categorical approach did not apply to calculating the grade level of supervised release violations, the court rejected defendant’s arguments and affirmed his sentence.
Judgment is affirmed.
U.S. v. Grays (MLW No. 84775/Case No. 25-2188 – 5 pages) (U.S. Court of Appeals, 8th Circuit, Grasz, J.) Appealed from U.S. District Court, Northern District of Iowa, Strand, J. (Nova D. Janssen, AFPD, Des Moines, IA for appellant) (John H. Lammers, AUSA, Sioux City, IA for appellee)
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