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Criminal Law: Drug Conspiracy-Drug Debt-Downward Variance

Staff Report//June 17, 2026//

Criminal Law: Drug Conspiracy-Drug Debt-Downward Variance

Staff Report//June 17, 2026//

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Defendant appealed the sentence imposed following her conviction for conspiracy to distribute drugs. At sentencing, the district court considered defendant’s attempt to collect a drug debt. On appeal, defendant argued that the district court should have varied downward because law enforcement only seized marijuana from her.

Where the debt was owed by one of defendant’s methamphetamine customers, the district court did not err in concluding that the debt was drug-related, and defendant had admitted to distributing methamphetamine.

Judgment is affirmed.

U.S. v. Thein (MLW No. 84939/Case No. 25-1551 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Northern District of Iowa, Williams, J.

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