8th Circuit upholds Davon Williams's 420-month sentence and drug/firearm convictions, finding no legal errors at…
United States v. Davon Williams
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8th Circuit upholds Davon Williams's 420-month sentence and drug/firearm convictions, finding no legal errors at trial or sentencing.
Why it matters
The Eighth Circuit Court of Appeals affirmed the conviction and 420-month prison sentence of Davon Williams, who was found guilty by a jury of drug and firearm offenses. The court rejected Williams's challenges to his conviction, the jury instructions, and the calculation of his sentencing range. The court also found his sentence was not unreasonably harsh, noting it was actually below the Guidelines range.
Who it affects
This ruling directly affects Davon Williams, who will serve his 420-month federal prison sentence. More broadly, it reinforces existing rules for defendants in drug and firearm cases who seek to challenge convictions or sentences on similar legal grounds in the Eighth Circuit.
What happens next
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Decision issued Jul 16, 2026
Unpublished opinion
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- Decision issued Jul 16, 2026Unpublished opinion
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Jul 16, 2026 · Unpublished opinion
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Davon Williams was convicted by a jury of possessing firearms in furtherance of drug-trafficking crimes, along with related drug offenses, and was sentenced to 420 months (35 years) in prison by a federal district court in the Western District of Missouri. He appealed, and his attorney filed a special type of brief called an Anders brief, which is used when a lawyer believes there are no strong legal arguments to make on appeal but still wants to flag potential issues for the court. Williams also filed his own pro se brief, meaning he argued his own points without a lawyer. Williams raised several arguments. He argued that two Supreme Court decisions, Johnson v. United States and United States v. Davis, should help his case by invalidating part of the federal firearm statute he was convicted under. The Eighth Circuit disagreed, explaining that those decisions apply to crimes of violence, not drug-trafficking crimes, so they did not help Williams. He also challenged whether the evidence at trial was strong enough to support his convictions, but the court found the evidence was sufficient for a reasonable jury to find him guilty beyond a reasonable doubt. Williams further argued that the district court made errors in calculating his sentencing Guidelines range. The appeals court found no such errors, and added that even if there had been a miscalculation, it would not have changed the outcome because the district court stated it would have imposed the same sentence regardless. On the question of whether the sentence was too harsh overall, the court applied a deferential standard and found no abuse of discretion, noting that the court properly weighed the relevant sentencing factors and actually sentenced Williams below the Guidelines range. The appeals court also independently reviewed the entire record and found no additional issues worth pursuing on appeal. As a result, it affirmed the judgment, upheld the sentence, and granted Williams's attorney permission to withdraw from the case. There was no dissent noted in the opinion.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-2705 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Davon R. Williams lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Western District of Missouri - Kansas City ____________ Submitted: July 9, 2026 Filed: July 16, 2026 [Unpublished] ____________ Before GRUENDER, SHEPHERD, and JUSTIN D. SMITH, Circuit Judges. ____________ PER CURIAM. Davon Williams appeals after a jury convicted him of drug and firearm offenses and the district court1 sentenced him to 420 months in prison. His counsel 1 The Honorable David Gregory Kays, United States District Judge for the Western District of Missouri. has moved for leave to withdraw, and has filed a brief under Anders v. California, 386 U.S. 738 (1967), challenging the sentence. Williams has filed a pro se brief challenging his conviction and the calculation of the Guidelines range. Upon careful review, we conclude that Williams’s arguments based on Johnson v. United States, 576 U.S. 591 (2015) and United States v. Davis, 588 U.S. 445 (2019) are unavailing. See In re Navarro, 931 F.3d 1298, 1302 (11th Cir. 2019) (per curiam) (18 U.S.C. § 924(c) conviction based on drug-trafficking crimes is outside the scope of Johnson and Davis). We also conclude that the evidence at trial was sufficient to support Williams’s convictions for possessing firearms in furtherance of drug-trafficking crimes, see United States v. Timlick, 481 F.3d 1080, 1082 (8th Cir. 2007) (sufficiency of evidence to sustain conviction is reviewed de novo); United States v. Spears, 454 F.3d 830, 832 (8th Cir. 2006) (appellate court does not weigh evidence or assess credibility of witnesses; examining evidence in light most favorable to verdict and accepting all reasonable inferences which tend to support jury verdict; appellate court will reverse only if no reasonable jury could have found defendant guilty beyond reasonable doubt); and that the district court did not err in giving non-model jury instructions, see United States v. Owens, 966 F.3d 700, 705 (8th Cir. 2020) (model jury instructions serve as helpful suggestions but are not binding on the district courts unless promulgated by this court). We further conclude that the district court did not err in calculating Williams’s Guidelines range, and note that any error would have been harmless, as the court stated that it would have imposed the same sentence even if it had sustained his objections. See United States v. Turner, 781 F.3d 374, 393 (8th Cir. 2015) (construction and application of Guidelines are reviewed de novo; factual findings are reviewed for clear error); United States v. Hamilton, 929 F.3d 943, 948 (8th Cir. 2019) (Guidelines miscalculation is harmless when the district court indicates that it would have alternatively imposed the same sentence even if a lower range applied). -2- As to the argument in the Anders brief, we conclude that the district court did not impose a substantively unreasonable sentence, as the court properly considered the factors listed in 18 U.S.C. § 3553(a) and did not err in weighing the relevant factors. See United States v. Feemster, 572 F.3d 455, 461-62 (8th Cir. 2009) (en banc) (reviewing sentences for substantive reasonableness under deferential abuse of discretion standard; abuse of discretion occurs when the court fails to consider relevant factor, gives significant weight to an improper or irrelevant factor, or commits a clear error of judgment in weighing the appropriate factors). Further, the court imposed a sentence below the Guidelines range. See United States v. McCauley, 715 F.3d 1119, 1127 (8th Cir. 2013) (noting that when the district court has varied below the Guidelines range, it is “nearly inconceivable” that the court abused its discretion in not varying further). We have also independently reviewed the record under Penson v. Ohio, 488 U.S. 75 (1988), and we find no non-frivolous issues for appeal. Accordingly, we affirm the judgment, and we grant counsel’s motion to withdraw. ______________________________ -3-
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