The U.S. Court of Appeals for the Eighth Circuit affirmed a below-Guidelines sentence imposed on Jessica Peters following her guilty plea to child pornography charges, rejecting arguments that the sentence was substantively unreasonable.
The case, *United States v. Jessica Rochelle Peters* (8th Cir. 2026), arose from an appeal of a sentence imposed by District Judge Rebecca Goodgame Ebinger in the U.S. District Court for the Southern District of Iowa. Peters had pleaded guilty to child pornography offenses but received a sentence below the federal sentencing guidelines range.
Peters' defense counsel filed an Anders brief, a type of appellate filing used when an attorney believes an appeal lacks merit but seeks court permission to withdraw from representation. Under *Anders v. California* (1967), attorneys must file a brief identifying potential issues while explaining why they believe the appeal is frivolous. In this case, counsel challenged the substantive reasonableness of Peters' sentence despite it being below the guidelines range.
The appellate court's per curiam opinion, filed Jan. 27, 2026, was brief and unpublished. The three-judge panel consisting of Circuit Judges Smith, Shepherd, and Erickson conducted what they described as a "careful review" before concluding that the district court did not impose a substantively unreasonable sentence.
The Eighth Circuit applied established precedent in reaching its decision, citing *United States v. Feemster* (8th Cir. 2009), which established that sentences are reviewed under a deferential abuse-of-discretion standard when examining substantive reasonableness. The court also referenced *United States v. McCauley* (8th Cir. 2013) in its analysis.
The case highlights ongoing complexities in federal sentencing for child pornography offenses. While the federal sentencing guidelines provide recommended sentence ranges based on various factors, federal judges retain discretion to impose sentences above or below those guidelines when justified by the circumstances of the case and the defendant.
Substantive reasonableness challenges typically argue that a sentence is either too harsh or too lenient given the totality of circumstances. In this case, Peters' attorney argued the below-Guidelines sentence was substantively unreasonable, though the specific arguments are not detailed in the available court documents.
Peters also moved for appointment of new counsel, suggesting dissatisfaction with her current legal representation. The court's opinion does not address this motion separately, focusing instead on the substantive sentencing challenge.
Federal child pornography cases often involve complex sentencing considerations. Courts must balance factors including the defendant's criminal history, the nature and extent of the offense, the need for deterrence, and the potential for rehabilitation. The federal guidelines for these offenses have been subject to criticism from some judges who view them as potentially leading to disproportionately harsh sentences in certain cases.
The Eighth Circuit's decision reinforces the principle that trial judges have considerable discretion in sentencing, even when departing from guidelines ranges. Appeals courts generally defer to district court sentencing decisions unless they constitute a clear abuse of discretion.
The unpublished nature of the opinion means it will have limited precedential value, serving primarily to resolve the specific dispute in Peters' case rather than establishing broader legal principles. Unpublished opinions are typically issued in cases where the court applies well-established law to routine factual situations.
The case was submitted to the appellate court on Jan. 20, 2026, and decided just one week later, suggesting the court found the issues straightforward and the appeal lacking in merit. This timeline is consistent with the court's treatment of Anders briefs, which often receive expedited review when counsel has identified no viable appellate issues.
For Peters, the affirmance means her sentence will stand as imposed by the district court. The rejection of her attorney's Anders brief indicates the appellate court found no reversible error in the sentencing proceedings or the ultimate sentence imposed.
The case underscores the high bar defendants face when challenging sentences on substantive reasonableness grounds, particularly when the sentence falls below recommended guidelines ranges. Courts generally view below-Guidelines sentences as favoring defendants, making successful challenges relatively rare.
The Eighth Circuit's brief opinion provides little insight into the specific circumstances of Peters' case or the factors that led the district court to impose a below-Guidelines sentence. Such details would typically be found in the district court's sentencing transcript or written sentencing memorandum, which are not part of the appellate record made public in this unpublished decision.