8th Circuit upholds 37-month sentence for Iowa woman who bought 11 guns for someone else…
United States v. Ladonna Henderson
Status and record
Your position
Do you support this decision?
An advisory read. Your position on a ruling is citizen opinion; it does not form a citizen mandate and is never a legal appeal.
Civitus citizens
Take a position above to see how verified Civitus citizens are weighing in. Positions stay sealed until you have one of your own.
The Civitus brief
AI analysis
Plain English
8th Circuit upholds 37-month sentence for Iowa woman who bought 11 guns for someone else, rejecting her claim the judge improperly found she fled prosecution.
Why it matters
The Eighth Circuit affirmed Ladonna Henderson's 37-month prison sentence for making false statements during firearm purchases and possessing firearms as an unlawful drug user. Henderson argued her sentence was unreasonable because the district court improperly found she left Iowa to avoid prosecution, a fact she said was unsupported by the record. The appeals court disagreed, finding the district court's factual findings were supported by evidence and that weighing those findings to reach the sentence was not an abuse of discretion.
Who it affects
This ruling directly affects Ladonna Henderson and her sentence. More broadly, it is relevant to criminal defendants who argue at sentencing that a judge relied on factually unsupported reasons, and to how courts weigh competing explanations for a defendant's conduct when determining an appropriate sentence.
What happens next
Current
Decision issued Jul 23, 2026
Unpublished opinion
Next
Possible rehearing
Parties can ask the same court to reconsider. Then: possible supreme court petition.
View possible path
- Decision issued Jul 23, 2026Unpublished opinion
- Possible rehearingParties can ask the same court to reconsider.
- Possible Supreme Court petitionThe Supreme Court takes only a small share of petitions.
Citizens vs Court
Civitus citizens
Sealed
Take a counted position to open the tally.
Appellate court
Decision issued
Jul 23, 2026 · Unpublished opinion
Take a position above to open the comparison.
A comparison of public sentiment with the ruling. Courts are not subject to a citizen mandate, and judges are not elected representatives.
Take action
Courts decide cases; Congress can respond with legislation. Telling your representative is the civic lever here.
Public discussion
Add a tag
Citizen opinion on this ruling, not a rehearing of the case. Similar opinions on this case can open a solution poll.
3 similar opinions open a solution poll
Loading opinions
Deeper context
Long-form analysis, legal background, and source material
Read analysisAnalysis · Source
DEEPER READ
Between November 2022 and June 2023, Ladonna Henderson purchased or attempted to purchase eleven firearms in Waterloo, Iowa. On the federal forms required for each purchase, she falsely stated she was the actual buyer and that she did not use controlled substances. In fact, she was buying the guns for someone else, and she was a marijuana user. She was indicted on nine counts in September 2023 and ultimately pleaded guilty to all of them in February 2025. The district court sentenced her to 37 months in prison, which was at the low end of the recommended sentencing guidelines range of 37 to 46 months. The central question on appeal was whether the district court relied on an improper factor when sentencing Henderson, specifically whether it wrongly concluded she had left Iowa to flee prosecution. Henderson was found in Illinois about nine months after her indictment was unsealed. The government called her a fugitive and pointed to a newspaper article about the case, an acquaintance who said Henderson knew about the arrest warrant, and Henderson's own statement to a child welfare worker that her children would stay with a relative in Illinois while she handled her criminal charges. Henderson countered that she left because her former partner had threatened her, a state court had refused to hold him in contempt of a protective order, and she feared for her safety. The district court found that Henderson's departure was motivated at least in part by a desire to avoid responsibility for her criminal charges, while also acknowledging her safety concerns about her former partner as a possible additional reason. It declined to give the safety concern significant mitigating weight. The Eighth Circuit reviewed the sentence for abuse of discretion and the underlying facts for clear error. The court found no clear error in the factual findings, noting that record evidence supported each of the district court's conclusions. It also found no abuse of discretion in how the district court weighed those findings when choosing the sentence. The appeals court also addressed a procedural question about whether Henderson had properly preserved her objection. The government argued she had not objected at sentencing and should face a harder standard of review on appeal. The court rejected that argument, finding that Henderson had in fact disputed the flight characterization at sentencing, and that no additional objection was needed to later challenge the substantive reasonableness of the sentence on appeal. The ruling affirms the 37-month sentence without any noted dissent.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-2535 ___________________________ United States of America Plaintiff - Appellee v. Ladonna Henderson Defendant - Appellant ____________ Appeal from United States District Court for the Northern District of Iowa - Eastern ____________ Submitted: April 13, 2026 Filed: July 23, 2026 [Unpublished] ____________ Before KELLY, ARNOLD, and KOBES, Circuit Judges. ____________ PER CURIAM. Ladonna Henderson pleaded guilty to multiple firearm-related offenses and the district court1 sentenced her to 37 months in prison. She appeals her sentence. 1 The Honorable C.J. Williams, Chief Judge, United States District Court for the Northern District of Iowa. I. In Waterloo, Iowa, between November 2022 and June 2023, Henderson purchased or attempted to purchase eleven firearms. When she purchased the firearms, she falsely stated on each ATF Firearms Transaction Record form that she was the actual purchaser and that she was not an unlawful user of controlled substances. Neither assertion was true: she purchased the firearms on behalf of another person, and she was an unlawful user of marijuana at the time of the purchases. On September 20, 2023, Henderson was indicted on two counts of making a false statement during the purchase of a firearm, in violation of 18 U.S.C. § 924(a)(1)(A); six counts of making a false statement during the purchase of a firearm, in violation of 18 U.S.C. §§ 922(a)(6) and 924(a)(2); and one count of possession of firearms as an unlawful user of controlled substances, in violation of 18 U.S.C. §§ 922(g)(3) and 924(a)(8). The indictment was sealed until September 26, 2023, when Henderson’s co-defendant was arrested. Henderson was arrested on June 18, 2024, in Chicago, Illinois. She waived her right to an identity hearing and was ultimately released on conditions to appear as ordered in the Northern District of Iowa. In February 2025, Henderson pleaded guilty to all nine counts. At sentencing, neither Henderson nor the government objected to the calculation of the Sentencing Guidelines as recommended in the Presentence Investigation Report, resulting in an advisory Guidelines range of 37 to 46 months. Henderson moved for a sentence below the advisory range, and the government sought a sentence within the range. After considering the unobjected-to documents the parties presented as evidence at the sentencing hearing, the district court denied Henderson’s motion and imposed a 37-month term of imprisonment and a 3-year term of supervised release. -2- II. On appeal, Henderson challenges the substantive reasonableness of her sentence. We review for an abuse of discretion.2 See United States v. Neri, 73 F.4th 984, 988 (8th Cir. 2023) (“A district court abuses its discretion when it (1) fails to consider a relevant factor that should have received significant weight; (2) gives significant weight to an improper or irrelevant factor; or (3) considers only the appropriate factors but in weighing those factors commits a clear error of judgment.” (quoting United States v. Feemster, 572 F.3d 455, 461 (8th Cir. 2009))). Henderson contends the district court gave significant weight to an improper factor when it relied on a fact unsupported by the record—that she left her home in Waterloo to avoid prosecution—resulting in a substantively unreasonable sentence. Approximately nine months after the indictment was unsealed, Henderson was arrested in Illinois. The government asserts she left the jurisdiction to flee prosecution and was a “fugitive” during this time period. To support this assertion, the government offered a local newspaper article published the day after her co- defendant was arrested, which described Henderson’s charges. An acquaintance of Henderson’s told law enforcement that Henderson showed him the article and that 2 The government asks us to reframe Henderson’s argument as one alleging procedural error and to apply plain error review, asserting Henderson did not object to the error at the district court. But Henderson did object. In its argument to the court at sentencing, the government characterized Henderson’s decision to leave Waterloo shortly after she was indicted as “flight from prosecution.” Henderson countered, telling the court she “dispute[s] and ha[s] disputed that [she] fled prosecution in this case,” and she offered an alternative reason why she left the state. To the extent this is an alleged procedural error, it is preserved. To the extent the district court then relied on its factual findings on this issue when determining an appropriate sentence, Henderson was not required to lodge another objection to assert the sentence was substantively unreasonable. United States v. Kouangvan, 844 F.3d 996, 999 (8th Cir. 2017) (“No objection is needed to preserve an attack on the substantive reasonableness of a sentence.” (quoting United States v. Bain, 586 F.3d 634, 641 (8th Cir. 2009) (per curiam)). -3- he believed she knew there was a warrant for her arrest, which was why she decided to leave Waterloo. A couple of days after the newspaper article ran, Henderson spoke with a Child Protection Worker (CPW) regarding her minor children. During the conversation, Henderson told the CPW that her children would be staying with her aunt in Illinois while Henderson addressed her pending criminal charges. Henderson disputes the government’s characterization of her decision to leave Waterloo, explaining she left because she feared for her safety after her former partner and father of her minor children threatened her, and a state court judge refused to hold him in contempt of an active Protective Order. The record at sentencing included the May 2023 Protective Order, Henderson’s September 2023 report of the violation to law enforcement, the warrant issued for her former partner’s arrest, and the Initial Appearance Order scheduling a contempt hearing for October 19, 2023. Ultimately, the district court found Henderson’s decision to leave the state was motivated, at least in part, to “evade responsibility” for her pending criminal charges. The court found Henderson left the jurisdiction after she knew she had been indicted and chose not to turn herself in or report to authorities. The district court also recognized that her desire to avoid contact with her former partner may have been an additional motivating factor, but it declined to give this mitigating factor significant weight. We see no clear error in the district court’s factual findings. See United States v. Foard, 108 F.4th 729, 736 (8th Cir. 2024) (“We review factual findings at sentencing for clear error.”). The court identified more than one reason for Henderson’s absence from the jurisdiction, crediting the government’s characterization in part and Henderson’s in part. Each finding is supported by record evidence. And we do not discern an abuse of the district court’s broad discretion in weighing those findings to reach an appropriate sentence. -4- The judgment of the district court is affirmed. _____________________________
Sources
- Official opinionPrimary record
Public record. Timeline facts only; no accusation of wrongdoing. Advisory citizen opinion does not form a citizen mandate.