The U.S. Court of Appeals for the Eighth Circuit affirmed a 32-year prison sentence for Stephan Rashad Haley, who pleaded guilty to multiple federal charges including drug trafficking, fraud, and money laundering offenses. The court issued its decision Jan. 5, 2026, in consolidated cases stemming from two separate federal indictments.
Haley, also known by the aliases "Ace" and "Bosh," was sentenced to 384 months in prison by the U.S. District Court for the Southern District of Iowa. The charges originated from two separate federal cases that were later consolidated prior to his plea hearing.
The appeals process took an unusual turn when Haley's court-appointed counsel filed a motion to withdraw from representation and submitted what is known as an Anders brief. Under *Anders v. California* (1967), defense attorneys can seek to withdraw from appeals cases when they determine there are no meritorious grounds for appeal. The Anders brief allows counsel to fulfill their constitutional obligation to provide effective assistance while acknowledging the lack of viable appellate issues.
In the Anders brief, counsel challenged only one aspect of Haley's sentence: the district court's application of an enhancement for maintaining a drug premises. This sentencing enhancement can significantly increase prison time for defendants who operate or maintain locations used for drug trafficking activities.
The three-judge panel, consisting of Circuit Judges Benton, Shepherd, and Kelly, reviewed the sentencing enhancement and concluded that the district court correctly applied it. The court cited precedent from *United States v. Turner*, a previous Eighth Circuit decision that provides guidance on when the drug premises enhancement is appropriately applied.
Despite having counsel file the Anders brief indicating no meritorious appeals, Haley also filed a pro se brief representing himself. In his self-filed brief, Haley raised two significant claims: that his guilty plea was not voluntary and that his court-appointed counsel provided ineffective assistance.
Challenges to plea voluntariness typically involve arguments that a defendant did not fully understand the charges, potential penalties, or consequences of pleading guilty. Such claims require courts to examine whether the defendant was properly informed during the plea colloquy and whether any coercion or promises influenced the decision to plead guilty.
Ineffective assistance of counsel claims, established under *Strickland v. Washington* (1984), require defendants to show both that their attorney's performance fell below professional standards and that this deficient performance prejudiced the defense. These claims are notoriously difficult to prove and require specific evidence of attorney errors that affected the case outcome.
The court's per curiam opinion, meaning it was issued by the panel as a whole rather than authored by a single judge, suggests the appeals court found Haley's arguments unpersuasive. Per curiam opinions are often used for cases where the legal issues are straightforward or where the court unanimously agrees on the outcome.
The case highlights the federal justice system's approach to complex multi-charge prosecutions. Drug trafficking cases often involve additional charges such as money laundering and fraud, as criminal organizations frequently use financial crimes to hide proceeds from drug sales. The consolidation of multiple indictments into a single case reflects prosecutors' strategy to address the full scope of criminal activity.
Haley's 32-year sentence reflects the serious nature of federal drug trafficking penalties, particularly when combined with financial crimes. Federal sentencing guidelines consider factors including the type and quantity of drugs involved, the defendant's role in the operation, criminal history, and any sentence enhancements such as the drug premises enhancement applied in this case.
The Eighth Circuit's jurisdiction covers Iowa, Minnesota, Missouri, Arkansas, Nebraska, North Dakota, and South Dakota. The court regularly handles appeals from federal drug prosecutions, as the region serves as both a destination and transit corridor for illegal narcotics.
This unpublished decision means it cannot be cited as binding precedent in future cases, though it may be referenced for its persuasive value. The quick turnaround from submission on Dec. 24, 2025, to decision on Jan. 5, 2026, suggests the court found the issues straightforward.
The denial of Haley's appeals exhausts his direct appeal rights, though he may still pursue post-conviction relief through other federal court procedures. Such proceedings typically involve claims of constitutional violations or newly discovered evidence and are filed in the district court where the original conviction occurred.
The case demonstrates the federal courts' efficiency in processing appeals with limited merit while ensuring defendants receive constitutionally required representation through the Anders brief procedure.