The U.S. Court of Appeals for the 8th Circuit decided U.S. v. Steven Bruhn, U.S. Court of Appeals Case No: 25-1342.
Steven Bruhn was initially charged with conspiracy to distribute and possess with intent to distribute controlled substances. After cooperating with the government and showing improvement during his time in rehabilitation, the district court deferred acceptance of his plea to support further rehabilitation. Eventually, the court sentenced him to time served and imposed five years of supervised release, warning him to avoid drug-related activities due to his history of substance abuse.
Approximately a year into his supervised release, the government petitioned for revocation, alleging that Bruhn had relapsed into drug use and had been terminated from a treatment program. The magistrate judge first detained Bruhn, but later allowed his release to the North Dakota Adult and Teen Challenge rehabilitation program under strict conditions. After only two days, Bruhn was expelled from Teen Challenge for nonparticipation, and he failed to surrender to authorities as required. At the final revocation hearing, the United States District Court for the District of North Dakota found that Bruhn had not engaged with the rehabilitation opportunities provided and sentenced him to 20 months’ imprisonment, an upward variance from the calculated Guidelines range of 5 to 11 months.
Bruhn appealed to the United States Court of Appeals for the Eighth Circuit, arguing that the district court imposed the sentence based on speculation and unsupported inferences, particularly regarding his intentions at Teen Challenge. The Eighth Circuit found no plain error, holding that the district court’s findings were supported by the record, including the unobjected-to violation report and statements from Bruhn’s probation officer. The appellate court affirmed that the district court adequately considered the relevant sentencing factors and provided sufficient justification for the upward variance. Therefore, the Eighth Circuit affirmed the district court’s judgment. (Opinion Source: https://law.justia.com/cases/federal/appellate-courts/ca8/25-1342/25-1342-2026-06-17.html?utm_source=summary-newsletters&utm_medium=email&utm_campaign=2026-06-18-u-s-court-of-appeals-for-the-eighth-circuit-f4b79798e5&utm_content=text-case-title-1)
