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

United States v. Anthony Madison

United States v. Anthony Madison
U.S. Court of Appeals for the Eighth Circuit · Decided February 6, 2026
United States v. Anthony Madison

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1740 ___________________________ United States of America Plaintiff - Appellee v. Anthony Madison Defendant - Appellant ____________ Appeal from United States District Court for the Eastern District of Missouri - St. Louis ____________ Submitted: January 12, 2026 Filed: February 6, 2026 [Unpublished] ____________ Before SMITH, ERICKSON, and KOBES, Circuit Judges. ____________ PER CURIAM.

While serving a term of supervised release, Anthony Madison was arrested for harassment in the first degree, Mo. Rev. Stat. § 565.090, and nonconsensual dissemination of private sexual images, Mo. Rev. Stat. § 573.110, though the state grand jury later returned a no true bill, see Mo. Rev. Stat. § 540.260. The U.S. Probation Office petitioned to revoke his supervised release based on the alleged new law violations. The district court 1 denied Madison’s request for a jury trial.

After a hearing, it found by a preponderance of the evidence that he committed both crimes, so it revoked his supervision and imposed a revocation sentence. See 18 U.S.C. § 3583(e)(3) (a court may “revoke a term of supervised release . . . if the court . . . finds by a preponderance of the evidence that the defendant violated a condition of supervised release”).

Madison argues that his revocation sentence violates his Sixth Amendment right to have a jury determine his guilt beyond a reasonable doubt. He acknowledges his claim is foreclosed by United States v. Eagle Chasing, 965 F.3d 647, 650–51 (8th Cir. 2020).

Affirmed. ______________________________

The Honorable Sarah E. Pitlyk, United States District Judge for the Eastern District of Missouri. -2-

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