8th Circuit upholds 24-month prison sentence for Michael Good after supervised release revocation, finding no…
United States v. Michael Good
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8th Circuit upholds 24-month prison sentence for Michael Good after supervised release revocation, finding no reversible error in how the district court handled sentencing guidelines.
Why it matters
The U.S. Court of Appeals for the Eighth Circuit affirmed the district court's decision to revoke Michael Good's supervised release and sentence him to 24 months in prison. Good argued that the district court made a procedural error by never explicitly stating the grade of his most serious violation or calculating the applicable guidelines range. The appeals court found that the record showed the court did treat the violations as Grade C and applied the corresponding range, and that even if there was any error, it did not rise to the level required for reversal and likely made no difference in the outcome.
Who it affects
This ruling directly affects people on federal supervised release who may face revocation proceedings and want to challenge how a sentencing court applies the revocation guidelines. It also serves as a reminder to defense attorneys to raise procedural objections at the time of the hearing, since failing to do so means a much harder standard applies on appeal.
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Decision issued Jul 21, 2026
Unpublished opinion
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- Decision issued Jul 21, 2026Unpublished opinion
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Jul 21, 2026 · Unpublished opinion
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DEEPER READ
Michael Good was on supervised release when the district court revoked it and sentenced him to 24 months in prison. On appeal, Good argued that the district court committed a procedural error by failing to explicitly state the grade of his most serious violation and calculate the applicable sentencing guidelines range before imposing his sentence. These are steps courts are generally expected to take in supervised release revocation proceedings. The Eighth Circuit reviewed the case under a demanding standard called plain error review, which applies when a defendant did not raise the objection at the time of the lower court proceeding. Under plain error review, a defendant must show that any error was clear or obvious, not merely subject to reasonable disagreement. The court found that the record, taken as a whole, showed the district court did in fact treat Good's violations as Grade C, the least serious category under the guidelines. At the revocation hearing, the court calculated guidelines ranges for each grade, confirmed that Good was admitting only to Grade C violations, and the government also recommended a sentence based on Grade C. The government acknowledged it could only prove the gun Good allegedly brandished was a toy, which would make the related offense a misdemeanor, and the court proceeded on that assumption. Even assuming some procedural error occurred, the court concluded Good had not shown it was clear or obvious. Additionally, the court found the error would have been harmless in any event. The district court had warned Good in October 2024 that his modifications were his last chance and that drinking alcohol again would result in a two-year prison sentence. At the April 2025 hearing, Good admitted to violating the alcohol prohibition. The appeals court concluded the district court would have imposed the same sentence regardless of any guidelines calculation issue. The court was unanimous and there was no dissent noted in the opinion. The ruling does not create new law but applies existing standards about when procedural errors in sentencing require reversal.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1918 ___________________________ United States of America Plaintiff - Appellee v. Michael R. Good Defendant - Appellant ____________ Appeal from United States District Court for the Western District of Missouri - Kansas City ____________ Submitted: July 6, 2026 Filed: July 21, 2026 [Unpublished] ____________ Before GRUENDER, BENTON, and SHEPHERD, Circuit Judges. ____________ PER CURIAM. Michael R. Good appeals after the district court 1 revoked his supervised release and sentenced him to 24 months in prison. Having jurisdiction under 28 U.S.C. § 1291, this court affirms. 1 The Honorable Roseann A. Ketchmark, United States District Judge for the Western District of Missouri. On appeal, Good argues that the district court plainly erred because it never explicitly determined the grade of his most serious violation or calculated the applicable revocation Guidelines range. Upon careful review, this court finds no basis for reversal. See United States v. Brown, 992 F.3d 665, 672 (8th Cir. 2021) (standard of review for forfeited procedural error is plain error); see also United States v. Shaw, 104 F.4th 691, 693 (8th Cir. 2024) (failure to calculate Guidelines range is procedural error). The record shows that the district court found Good’s violations were Grade C and applied the corresponding Guidelines range. Among other indicators at the revocation hearing, the court calculated the Guidelines ranges for each grade, and confirmed that Good was stipulating only to Grade C violations; and the government joined in Good’s sentencing recommendation based on Grade C. The government presented no evidence or argument to suggest Good committed a Grade B violation, and in fact clarified that, if the gun Good was accused of brandishing was merely a toy—which it acknowledged was all that it could prove— then the related new-crime violation was likely a misdemeanor offense. The court stated it was proceeding on the presumption that the gun was a toy. See 18 U.S.C. § 3583(e)(3) (court must find, by a preponderance of the evidence, that defendant violated supervised-release condition); U.S.S.G. § 7B1.1 (offense punishable by term of imprisonment of one year or less is Grade C violation); United States v. Krzyzaniak, 702 F.3d 1082, 1085 (8th Cir. 2013) (considering sentencing record, taken as a whole, when reviewing whether district court procedurally erred). Even assuming the failure to more clearly announce the Grade-C designation and corresponding Guidelines range was procedural error, however, this court concludes that Good has not demonstrated the error was clear or obvious. See United States v. Winston, 850 F.3d 377, 380 (8th Cir. 2017) (to demonstrate plain error, defendant must show, inter alia, error that is clear or obvious under current law); see also United States v. De Aquino, 142 F.4th 628, 633 (8th Cir. 2025) (“In order to warrant reversal on plain-error review, the legal error must be clear or obvious, rather than subject to reasonable dispute.”) (cleaned up); United States v. Elbert, 20 F.4th 413, 415 (8th Cir. 2021); United States v. Trung Dang, 907 F.3d 561, 565 (8th Cir. 2018). In any event, the record suggests the court would have imposed the same -2- statutory maximum sentence regardless of the applicable Guidelines range. When it last ordered modifications to Good’s conditions of supervised release in October 2024, it cautioned him that the modifications would be his “last chance,” and if he drank alcohol again, he would receive a two-year prison sentence. At the April 2025 revocation hearing, Good stipulated to violating a condition prohibiting him from consuming alcohol. See United States v. Hamilton, 929 F.3d 943, 948 (8th Cir. 2019) (Guidelines error is harmless where district court indicates it would have alternatively imposed the same sentence without the error). The judgment is affirmed. ______________________________ -3-
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