U.S. Court of Appeals for the Eighth Circuit, 2026

United States v. Jessica Peters

United States v. Jessica Peters
U.S. Court of Appeals for the Eighth Circuit · Decided January 27, 2026
United States v. Jessica Peters

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1958 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Jessica Rochelle Peters lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Southern District of Iowa - Eastern ____________ Submitted: January 20, 2026 Filed: January 27, 2026 [Unpublished] ____________ Before SMITH, SHEPHERD, and ERICKSON, Circuit Judges. ____________ PER CURIAM.

Jessica Peters appeals the below-Guidelines sentence the district court1 imposed after she pleaded guilty to child pornography offenses. Her counsel has The Honorable Rebecca Goodgame Ebinger, United States District Judge for the Southern District of Iowa. moved for leave to withdraw, and has filed a brief under Anders v. California, 386 U.S. 738 (1967), challenging the substantive reasonableness of the sentence. Peters has moved for appointment of new counsel.

Upon careful review, we conclude that the district court did not impose a substantively unreasonable sentence. See United States v. Feemster, 572 F.3d 455, 461-62 (8th Cir. 2009) (en banc) (reviewing sentence under deferential abuse-of- discretion standard; discussing substantive reasonableness); United States v. McCauley, 715 F.3d 1119, 1127 (8th Cir. 2013) (noting when a district court has varied below the Guidelines range, it is “nearly inconceivable” that the court abused its discretion by not varying downward further). In addition, having independently reviewed the record pursuant to Penson v. Ohio, 488 U.S. 75 (1988), we find no non- frivolous issues for appeal. Accordingly, we affirm the judgment, grant counsel’s motion to withdraw, deny Peters’s motion for new counsel, and deny any further extension of time to file a supplemental brief. ______________________________

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