Background
Darius Stackhouse appealed after he pleaded guilty to drug and firearm offenses and the district court sentenced him to 300 months in prison. The appeal came from the U.S. District Court for the Northern District of Iowa, Central Division, where the Honorable Leonard T. Strand presided. Stackhouse challenged both his conviction and his sentence.
The Eighth Circuit’s opinion contains an unresolved procedural inconsistency: although it says Stackhouse pleaded guilty, its sufficiency analysis refers to “evidence presented at trial,” the “verdict,” and a “jury verdict.” The opinion does not explain that discrepancy. This summary therefore preserves the opinion’s wording rather than treating the case as involving both a guilty plea and a trial conviction.
The case was submitted on November 3, 2026, and decided on November 6, 2026. The three-judge panel issued an unpublished per curiam opinion.
The Court’s Holding
The court affirmed. It concluded that the evidence was sufficient to support Stackhouse’s conviction, including the conviction for possessing a firearm in furtherance of a drug trafficking crime. The opinion identified a cooperating coconspirator’s testimony that Stackhouse carried a handgun while delivering methamphetamine; discovery of a handgun near a large quantity of cash and a digital scale, with methamphetamine elsewhere in the house; and expert testimony concerning drug dealers’ use of firearms.
Citing United States v. Timlick, 481 F.3d 1080, 1082 (8th Cir. 2007), and United States v. Spears, 454 F.3d 830, 832 (8th Cir. 2006), the court stated that sufficiency review is de novo, that it does not weigh evidence or assess witness credibility, and that it views the evidence in the light most favorable to the verdict and accepts reasonable inferences supporting it. Reversal is warranted only if no reasonable jury could have found the defendant guilty beyond a reasonable doubt. The court applied that standard in rejecting Stackhouse’s challenge.
The court also held that the 300-month sentence was not substantively unreasonable. It found that the district court properly considered the 18 U.S.C. § 3553(a) factors and did not err in weighing them. Citing United States v. Feemster, 572 F.3d 455, 461–62 (8th Cir. 2009) (en banc), the panel applied deferential abuse-of-discretion review. It also noted that the sentence was below the Guidelines range, citing United States v. McCauley, 715 F.3d 1119, 1127 (8th Cir. 2013), for the observation that when a district court has varied downward, it is “nearly inconceivable” that it abused its discretion by not varying further.
Key Takeaways
- The Eighth Circuit affirmed both Stackhouse’s conviction and his 300-month sentence in an unpublished per curiam decision.
- The firearm-in-furtherance holding rested on the combined evidence described in the opinion, including testimony about Stackhouse carrying a handgun during a methamphetamine delivery and the firearm’s proximity to cash and a scale.
- The sentencing holding was case-specific: the panel found proper consideration and weighing of the § 3553(a) factors and also relied on the below-Guidelines sentence.
- The opinion’s references to a guilty plea and to trial evidence and a jury verdict are internally inconsistent and are not reconciled in the text.
Why It Matters
The decision identifies the evidence the panel found sufficient for Stackhouse’s firearm-in-furtherance conviction and confirms the distinct appellate standards applied to his conviction and sentence: de novo sufficiency review and deferential abuse-of-discretion review of substantive reasonableness.
Because the opinion is unpublished and addresses Stackhouse’s particular challenges, its discussion of the evidence and below-Guidelines sentence should not be recast as a universal rule that similar evidence always suffices or that every below-Guidelines sentence is substantively reasonable.