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8th Circuit Affirms Consecutive Terms for Repeat Firearm Offender

The U.S. Court of Appeals for the Eighth Circuit affirmed a district court's decision to revoke supervised release and impose consecutive sentences against Anthony Wooten, who pleaded guilty to being a felon in possession of a firearm while on supervised release for similar prior convictions.

AI-generated Summary
4 min readcourtlistener
Seal of the Eighth Circuit Court of Appeals

Case Information

Case No.:
No. 24-2940

Key Takeaways

  • Wooten pleaded guilty to felon in possession while on supervised release for prior similar convictions
  • District court imposed 24-month concurrent revocation sentences to run consecutively to new conviction
  • Eighth Circuit affirmed the consecutive sentencing structure on appeal
  • Case involved substantial ammunition including high-capacity drum magazine
  • Ruling reinforces consequences for supervised release violations involving repeat firearms offenses

The U.S. Court of Appeals for the Eighth Circuit affirmed a federal district court's decision to impose consecutive sentences on a repeat firearms offender who violated his supervised release by committing another felon-in-possession offense. The court issued its ruling Feb. 12, 2026, in *United States v. Anthony Wooten*, rejecting the defendant's appeal of his sentence structure.

Anthony Wooten pleaded guilty Jan. 2, 2024, to being a felon in possession of a firearm while on supervised release for prior felon-in-possession and escape convictions. The U.S. District Court for the Western District of Missouri revoked Wooten's supervised release and imposed concurrent 24-month revocation sentences in both cases to run consecutively to his new sentence for the 2024 conviction.

The case stems from Wooten's lengthy criminal history involving firearms and escape. In 2013, Wooten was sentenced in the Eastern District of Missouri to 46 months' imprisonment followed by three years of supervised release for being a felon in possession of a firearm. While on that supervised release, Wooten escaped from his residential reentry center.

After his apprehension, Wooten pleaded guilty to escape and received a 36-month prison term followed by two years of supervised release. When he was released from prison in 2022, his supervision was transferred to the Western District of Missouri.

The incident that led to the current charges occurred May 30, 2023, while Wooten remained on supervised release. Police arrested him in St. Louis after he fled a traffic stop. A search of his vehicle revealed a .40 caliber handgun loaded with 21 rounds of ammunition and a 50-round drum magazine containing 41 rounds of ammunition.

Wooten was charged in the Eastern District of Missouri with being a felon in possession of a firearm. He subsequently pleaded guilty to the offense, marking his second conviction for the same federal crime while under court supervision.

The district court's sentencing structure involved multiple components reflecting Wooten's pattern of violations. The court revoked his supervised release from both the original 2013 felon-in-possession conviction and the subsequent escape conviction. For these revocations, the court imposed concurrent 24-month sentences that would run consecutively to whatever sentence he received for his new 2024 firearms conviction.

This sentencing approach means Wooten must serve his revocation time in addition to, rather than alongside, his sentence for the new offense. Consecutive sentencing is often used in cases involving repeat offenders or violations that occur while under court supervision, as it reflects the separate nature of each violation and the defendant's continued disregard for legal restrictions.

Circuit Judge Ralph Erickson authored the opinion for the three-judge panel, which also included Circuit Judges Raymond Gruender and William Kelly. The panel heard oral arguments Dec. 15, 2025, before issuing its decision affirming the lower court.

The Eighth Circuit's affirmance indicates the appeals court found no error in the district court's handling of the supervised release violations or the decision to structure the sentences consecutively. Federal courts have broad discretion in supervised release revocation proceedings, particularly when defendants commit new crimes while under supervision.

Felon-in-possession cases represent a significant portion of federal firearms prosecutions. The offense typically carries substantial penalties, especially for repeat offenders who demonstrate a pattern of violating federal firearms restrictions. The presence of substantial ammunition in Wooten's case - 62 total rounds including a high-capacity drum magazine - likely factored into sentencing considerations.

The case illustrates the cascading consequences that can result from violating supervised release terms. When federal defendants commit new crimes while under court supervision, they face both punishment for the new offense and separate penalties for violating the terms of their release from previous convictions.

Supervised release violations are treated as distinct from new criminal charges, allowing courts to impose separate sanctions that reflect both the new criminal conduct and the defendant's failure to comply with court-ordered supervision requirements. This dual approach is designed to both punish violations and deter future non-compliance with court supervision.

The Eighth Circuit's decision reinforces federal courts' authority to structure sentences consecutively in cases involving supervised release violations, particularly when defendants demonstrate a pattern of similar criminal conduct. The ruling provides precedent for similar cases involving repeat firearms offenders who violate supervision terms.

Wooten's case demonstrates the serious consequences federal defendants face when they continue criminal activity while on supervised release, especially involving firearms. The consecutive nature of his sentences means he will serve additional time specifically for violating his supervised release terms, separate from punishment for his new offense.

The February 2026 ruling represents the final word on Wooten's sentencing appeal, as the Eighth Circuit affirmed the district court's decision without modification. The case reinforces federal courts' approach to repeat offenders who violate firearms restrictions while under court supervision.

Topics

supervised release violationfirearm possessionescaperevocation sentencingconsecutive sentences

Original Source: courtlistener

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