The Eighth Circuit Court of Appeals is reviewing a sentence imposed after Benjamin Higgerson's third supervised release revocation, addressing fundamental questions about proper judicial consideration of sentencing factors in repeat supervision violations.

The case, United States v. Benjamin John Higgerson (8th Cir. 2026), stems from an appeal of a sentence imposed by Chief Judge Stephanie M. Rose of the U.S. District Court for the Southern District of Iowa. Higgerson challenges his sentence as substantively unreasonable, arguing that the district court gave improper weight to certain factors during the revocation hearing.

The central legal issue involves the standard for substantive reasonableness in supervised release revocations. According to Eighth Circuit precedent established in United States v. DeMarrias (2018), a sentence following supervised release revocation is substantively unreasonable if the district court "fails to consider a relevant factor that should have received significant weight, gives significant weight to an improper or irrelevant factor, or considers only the appropriate factors but commits a clear error of judgment in weighing those factors."

Higgerson's appeal specifically challenges the district court's consideration of factors that may be inappropriate for supervised release revocation proceedings. The case highlights the ongoing evolution of appellate review standards for repeat supervision violations and the careful balance courts must maintain when imposing sentences following multiple revocations.

The Eighth Circuit's decision in this matter will provide important guidance to district courts throughout the circuit regarding the proper application of sentencing factors in supervised release revocation cases, particularly in situations involving repeat violations.