United States v. Mykayla Marie Golden, 684 F. App'x 591

Mykayla Golden pleaded guilty to conspiring to distribute methamphetamine; Guidelines range was 70–80 months, but she initially received five years probation with six months in a halfway house.
Golden repeatedly violated conditions (absconding, failing tests, cutting herself, medication changes, hospitalizations) and had multiple revocations of probation/supervised release leading to successive prison terms; parties did not appeal earlier revocations.
After a revocation that produced a 5-month sentence within a 3–9 month Guidelines range, Golden again absconded from a halfway house and was later sentenced to two years in prison following revocation of supervised release.
On appeal Golden raised procedural objections (district court allegedly failed to consider the 3–9 month Guidelines range, gave insufficient reasons, and impermissibly lengthened the sentence for treatment) and challenged substantive reasonableness (court gave too little weight to her medication/mental-health episode and showed improper frustration).
The Eighth Circuit reviewed unpreserved procedural objections for plain error and reviewed substantive challenges for abuse of discretion, affirmed the two-year revocation sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court failed to consider applicable 3–9 month Guidelines range	Golden: court ignored the 3–9 range when imposing 2-year sentence	Government: court had considered the range previously and the probation report reflected it; courts may be presumed to have considered it	Court: No plain error; presumption that court considered the range applies
Whether district court gave insufficient reasons for sentence	Golden: court did not adequately explain reasons, so sentence may be arbitrary	Government: sentencing transcript and prior consideration show adequate explanation	Court: No plain error; transcript shows adequate explanation of recidivism and need for structure
Whether sentence was impermissibly increased for rehabilitation/treatment (Tapia)	Golden: sentence lengthened to secure treatment/rehab	Government: recommended treatments were post-release; no evidence sentence was lengthened for rehabilitation	Court: No Tapia violation; treatments were to begin after release
Whether sentence was substantively unreasonable	Golden: court gave too little weight to cutting/medication and showed improper frustration, producing excessive sentence	Government: court considered those factors and was entitled to weigh recidivism heavily; repeated violations justify above-Guidelines revocation terms	Court: No abuse of discretion; sentence not substantively unreasonable given repeated violations

United States v. Thigpen, 848 F.3d 841 (8th Cir. 2017) (plain-error standard for unpreserved sentencing objections)
United States v. Perkins, 526 F.3d 1107 (8th Cir. 2008) (presumption that district court considered Guidelines range)
United States v. Chavarria-Ortiz, 828 F.3d 668 (8th Cir. 2016) (need to show reasonable probability of different outcome to prevail on inadequate-reasons claim)
Tapia v. United States, 564 U.S. 319 (2011) (district courts may not lengthen prison terms to promote rehabilitation or complete treatment)
United States v. Holdsworth, 830 F.3d 779 (8th Cir. 2016) (application of Tapia to sentencing)
United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (abuse-of-discretion standard for substantive review of sentences)
United States v. Vanhorn, 740 F.3d 1166 (8th Cir. 2014) (substantive-review narrowness; deference to district court)
United States v. Richart, 662 F.3d 1037 (8th Cir. 2011) (trial court’s discretionary weighting of mitigating factors upheld)
United States v. Kreitinger, 576 F.3d 500 (8th Cir. 2009) (upholding materially above-Guidelines revocation sentences in light of repeated violations)