United States v. Hunter Bonnell, 932 F.3d 1080

Defendant Hunter Dean Bonnell pled guilty to being a felon in possession of ammunition in violation of 18 U.S.C. §§ 922(g)(1), 924(a)(2).
The district court calculated the advisory Guidelines range and imposed an 84-month federal sentence to run consecutively to his undischarged state sentences.
Bonnell did not object at sentencing to the imposition of a consecutive federal sentence.
The district court explained its exercise of discretion, noting § 5G1.3(d) is advisory and stating a consecutive term was "the right thing to do," while remarking on practical state-to-federal custody transfers.
Bonnell appealed, arguing the district court erred by concluding a consecutive sentence was required and challenging the court’s comments about state custody practices.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 5G1.3(d) required a consecutive federal sentence	Bonnell: district court concluded consecutive sentence was required	Government: § 5G1.3(d) is discretionary; court may impose concurrent or consecutive sentence	Court: No plain error; § 5G1.3(d) is discretionary and the court properly exercised that discretion
Whether the district court plainly erred by discussing state prison practices	Bonnell: remarks improperly influenced sentencing	Government: comments were an academic/practical observation, not the sole basis	Court: No plain error; comments were speculative and permissible to consider among factors
Whether Bonnell can satisfy plain-error prejudice prong	Bonnell: alleged error affected substantial rights and outcome	Government: sentencing record shows consideration of §3553(a) factors and Guidelines; no reasonable probability of better outcome	Court: Bonnell failed to show a reasonable probability of a more favorable sentence
Whether the sentence was substantively reasonable	Bonnell: consecutive sentence unreasonable	Government: district court weighed Guidelines and §3553(a) factors and imposed low-end consecutive sentence	Court: Sentence was substantively reasonable; no abuse of discretion

United States v. Becker, 636 F.3d 402 (8th Cir. 2011) (district court has discretion to impose consecutive or concurrent sentence and may make practical observations about state custody)
United States v. Rutherford, 599 F.3d 817 (8th Cir. 2010) (Guidelines are a starting point; court may impose consecutive sentence after considering §3553(a))
Gall v. United States, 552 U.S. 38 (2007) (standard for reviewing reasonableness of sentencing decisions)
United States v. Thorne, 896 F.3d 861 (8th Cir. 2018) (procedural-review framework for sentencing decisions)
United States v. Keller, 413 F.3d 706 (8th Cir. 2005) (elements of plain-error review in sentencing context)
United States v. Pirani, 406 F.3d 543 (8th Cir. 2005) (prejudice prong requires reasonable probability of a different outcome)
United States v. Miner, 544 F.3d 930 (8th Cir. 2008) (substantive-reasonableness review: factors court must consider)
United States v. Peterson, 869 F.3d 620 (8th Cir. 2017) (district courts have wide discretion to impose consecutive sentences)