United States v. Anthony Mitchell, 2 F.4th 786

Mitchell served 48 months for unlawful firearm possession and began a 36‑month term of supervised release.
In Sept. 2019 Mitchell and others entered a blocked Des Moines alley where a fight occurred with Georan Churchill; Churchill recorded a 26‑second video and sustained facial injuries requiring stitches.
Churchill testified Mitchell grabbed, threw, and kicked him; Mitchell testified he punched Churchill once while responding to an attack and denied kicking him.
The government moved to revoke Mitchell’s supervised release, alleging Mitchell committed willful injury in violation of Iowa law; the district court found Churchill credible, concluded Mitchell committed the offense, revoked supervised release, and imposed 24 months’ imprisonment.
Mitchell appealed, arguing insufficient evidence (intent and serious‑injury elements) and that the 24‑month within‑Guidelines sentence was substantively unreasonable.
The Eighth Circuit affirmed, holding the district court’s factual findings were not clearly erroneous and the sentence was reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation is supported by proof Mitchell committed a new state crime (willful injury under Iowa law)	Mitchell: acted in self‑defense; government failed to prove intent to cause serious injury	Gov: Churchill credible; video, 911 call, Mitchell's admission, and injuries corroborate intent and conduct	Court: Finding not clearly erroneous; credibility determinations upheld; revocation affirmed
Whether 24‑month within‑Guidelines sentence was substantively unreasonable	Mitchell: employment and work history warranted a lower sentence	Gov: district court considered employment but reasonably weighed repeated violations and conduct	Court: Presumption of reasonableness for within‑Guidelines sentence not rebutted; sentence affirmed

United States v. Boyd, 792 F.3d 916 (revocation decision reviewed for abuse of discretion; factual findings for clear error)
United States v. Carothers, 337 F.3d 1017 (credibility findings of district court given deference)
United States v. Hernandez, 281 F.3d 746 (credibility determinations are virtually unreviewable on appeal)
Jima v. Barr, 942 F.3d 468 (discussing Iowa’s definition of bodily injury)
State v. McKee, 312 N.W.2d 907 (Iowa: bodily injury includes physical pain or impairment)
State v. Gordon, 560 N.W.2d 4 (Iowa case on bodily injury definition)
United States v. Goodale, 738 F.3d 917 (within‑Guidelines sentence presumptively reasonable)
United States v. Campbell, 986 F.3d 782 (district court’s sentencing discretion in weighing factors)