United States v. James Harrell, 982 F.3d 1137

On March 18, 2018, police responded to shots fired in Davenport, Iowa; witnesses identified James Harrell as the shooter as he drove by in a white Kia.
Harrell led officers on a high-speed, 15-block pursuit (estimated 75–85 mph), crashed, and was found unconscious; officers observed a nine-millimeter pistol on the driver’s floorboard.
Harrell pleaded guilty to being a prohibited person in possession of a firearm (18 U.S.C. §§ 922(g)(1), 922(g)(9), 924(a)(2)).
At sentencing the Guidelines range was 46–57 months; the government sought 57 months emphasizing community danger; Harrell presented mental-health evidence and post-offense rehabilitation and requested probation.
The district court said it considered the § 3553(a) factors, described the offense as "exceedingly aggravated," referenced local gun-violence concerns, and imposed 46 months’ imprisonment plus three years’ supervised release.
On appeal Harrell argued (1) procedural error from the court’s reliance on facts not in the record, and (2) that the sentence was substantively unreasonable for underweighting his mental-health history and rehabilitation; the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court committed procedural error by relying on facts not in the record (e.g., "extraordinary gun violence" in the Quad Cities; community perception of Harrell).	Harrell: Court relied on unsupported factual assertions and improper speculation.	Government: Court may rely on PSR, reliable evidence, and judicial experience; its statements did not form the principal basis for the sentence.	No plain error. Even if remarks were unsupported, Harrell failed to show a reasonable probability the sentence would have been lower absent them.
Whether the sentence was substantively unreasonable for failing to give adequate weight to Harrell's mental-health history and post-offense rehabilitation.	Harrell: District court did not give sufficient weight to mitigating evidence and rehabilitation; a downward variance was warranted.	Government: Court considered mental-health and rehabilitation but permissibly weighed deterrence, public safety, and prior convictions more heavily.	No abuse of discretion. The court considered § 3553(a) factors and reasonably imposed a within-Guidelines (bottom-range) sentence.

United States v. Cloud, 956 F.3d 985 (8th Cir. 2019) (framework for procedural then substantive review of sentences)
United States v. Bonnell, 932 F.3d 1080 (8th Cir. 2019) (plain-error standard for unpreserved sentencing objections)
Gall v. United States, 552 U.S. 38 (2007) (district courts must consider § 3553(a) factors and have wide latitude in weighing them)
United States v. Eagle Pipe, 911 F.3d 1245 (8th Cir. 2019) (unsupported sentencing remarks are not reversible if not the principal basis for the sentence)
United States v. Zayas, 758 F.3d 986 (8th Cir. 2014) (district court may rely on undisputed PSR facts at sentencing)
United States v. Durr, 875 F.3d 419 (8th Cir. 2017) (assessment of whether unsupported facts were a "principal basis" for a sentence)
United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (abuse-of-discretion standard and deferential review of sentencing decisions)