The U.S. Court of Appeals for the Eighth Circuit affirmed a 63-month federal prison sentence for Christopher King, who pled guilty to possession of firearms by a prohibited person in violation of federal law. The court rejected King's appeal challenging the district court's calculation of his sentencing guidelines range.
King pled guilty to violations of 18 U.S.C. §§ 922(g)(1), 922(g)(3), and 924(a)(8), which prohibit certain categories of individuals from possessing firearms. The U.S. District Court for the Northern District of Iowa sentenced King to 63 months' imprisonment, a term that fell within the applicable federal sentencing guidelines range.
On appeal, King argued that the district court made errors in calculating his sentencing guidelines range, specifically challenging the court's drug quantity determinations. King requested that the Eighth Circuit remand his case for resentencing based on these alleged calculation errors.
The district court had adopted the Presentence Investigation Report (PSIR), which applied U.S. Sentencing Guidelines § 2K2.1(b)(6)(B) based on King's involvement in felony offenses under Iowa state law. These underlying offenses included possession of a controlled substance with intent to distribute and distribution of controlled substances, specifically methamphetamine and marijuana.
After applying the applicable enhancements under § 2K2.1, King's adjusted offense level was calculated at 22. The district court then applied the cross-reference provision in U.S.S.G. § 2K2.1(c)(1)(A), which requires courts to apply the guidelines for the offense level of a substantive offense if it results in a higher sentence than the firearm offense alone.
This cross-reference provision directed the court to apply the guidelines for possession of controlled substances with intent to distribute, as this offense carried a higher penalty than the firearms violations. The cross-reference mechanism ensures that defendants who commit firearms offenses in connection with drug crimes receive sentences that reflect the full scope of their criminal conduct.
The Eighth Circuit's unpublished per curiam opinion, filed Feb. 3, 2026, rejected King's challenge to these calculations. The three-judge panel, consisting of Chief Judge Colloton and Circuit Judges Shepherd and Erickson, found no error in the district court's sentencing guidelines analysis.
Federal firearms laws impose significant penalties on prohibited persons who unlawfully possess weapons. Under 18 U.S.C. § 922(g), several categories of individuals are barred from possessing firearms, including convicted felons, individuals with certain mental health histories, and those subject to domestic violence restraining orders. Section 924(a)(8) provides enhanced penalties for these violations.
The case illustrates how federal sentencing guidelines account for the relationship between firearms offenses and underlying criminal conduct. When defendants possess weapons in connection with drug trafficking activities, the guidelines often result in enhanced sentences that reflect both the firearms violation and the drug-related conduct.
King's case was appealed from the Northern District of Iowa's Cedar Rapids division, where the Honorable Leonard T. Strand presided over the sentencing proceedings. The case was submitted to the Eighth Circuit on Nov. 17, 2025, and decided approximately two and a half months later.
The Eighth Circuit's affirmance of King's sentence reflects the appellate court's deference to district court sentencing determinations when they fall within established guidelines ranges. Appeals courts typically review sentencing calculations for clear error and will not disturb sentences that properly apply the federal sentencing guidelines framework.
This decision reinforces the federal judiciary's approach to firearms offenses committed by prohibited persons, particularly when such offenses occur in connection with drug trafficking activities. The enhanced penalties available under federal law serve both deterrent and public safety purposes by imposing substantial prison terms on individuals who unlawfully combine weapons possession with drug-related criminal conduct.
The unpublished nature of the Eighth Circuit's opinion indicates that the court viewed King's appeal as raising routine legal issues that did not warrant precedential treatment. Unpublished opinions typically address straightforward applications of established legal principles rather than novel questions of law.
King's unsuccessful appeal demonstrates the challenges defendants face when challenging sentencing guidelines calculations on appeal, particularly when district courts have carefully applied established enhancement provisions and cross-references that account for related criminal conduct.