United States v. Jonathan Meier

United States Court of Appeals

For the Eighth Circuit ___________________________ No. 24-2886 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Jonathan Edward Meier lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Northern District of Iowa - Central ____________ Submitted: June 13, 2025 Filed: June 18, 2025 [Unpublished] ____________

Before SMITH, KELLY, and KOBES, Circuit Judges.

____________ PER CURIAM.

Jonathan Meier appeals the district court’s1 judgment revoking his supervised release and sentencing him to a within-Guidelines prison term of 12 months and a day, to be followed by one year and 364 days of supervision. Having carefully reviewed Meier’s arguments for reversal, we disagree with his contention that the revocation judgment violated his constitutional right to a jury trial and that 18 U.S.C. § 3583(e)(3) is therefore unconstitutional as applied to him. See United States v. Childs, 17 F.4th 790, 791 (8th Cir. 2021) (reviewing de novo legality of revocation sentence, and noting that proceedings under § 3583(e)(3) permit finding of violation by preponderance of evidence by district court). We also conclude that Meier did not identify a due process violation, establish that his sentence violated the Eighth Amendment, establish that the district court failed to give sufficient weight to his completion of a treatment program, or establish that the district court committed plain error by imposing a special condition that Meier spend up to 90 days in a residential reentry center upon his release from custody, an unfulfilled requirement imposed in a prior order modifying the conditions of supervision with Meier’s consent.

Accordingly, the judgment of the district court is affirmed and Meier’s pending motion is denied as moot.

______________________________