United States v. Garnett Propst

── United States v. Garnett Propst ── Court: Court of Appeals for the Eighth Circuit Date: May 12, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-3520 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Garnett Adam Propst lllllllllllllllllllllDefendant - Appellant ___________________________ No. 25-1168 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Levi Allen Doolin lllllllllllllllllllllDefendant - Appellant ____________ Appeals from United States District Court for the Northern District of Iowa - Cedar Rapids ____________  Submitted: May 7, 2026 Filed: May 12, 2026 [Unpublished] ____________ Before SHEPHERD, ERICKSON, and KOBES, Circuit Judges. ____________ PER CURIAM. In these consolidated appeals, co-defendants Garnett Propst and Levi Doolin appeal the sentences the district court1 imposed after they pleaded guilty to firearm- related offenses. Propst argues that the court imposed a substantively unreasonable sentence, as it erred in giving “significant weight” to his involvement of a co-defendant in the offense. We conclude that the district court did not impose a substantively unreasonable sentence, as there is no indication that the district court overlooked a relevant factor, gave significant weight to an improper or irrelevant factor, or committed a clear error of judgment in weighing the relevant factors. See United States v. David, 682 F.3d 1074, 1077 (8th Cir. 2012) (court of appeals reviews reasonableness of sentence for abuse of discretion); United States v. Pickar, 666 F.3d 1167, 1169 (8th Cir. 2012) (district court abuses its discretion when it fails to consider relevant factor that should have received significant weight, gives significant weight to improper or irrelevant factor, or considers only appropriate factors but commits clear error of judgment in weighing those factors). The offense conduct, which involved Propst’s involvement of the co-defendant, was a proper factor, and the district court did not abuse its discretion in weighing that specific offense conduct. See United States v. Farmer, 647 F.3d 1175, 1179 (8th Cir. 2011) (simply 1 The Honorable C.J. Williams, Chief Judge, United States District Court for the Northern District of Iowa. -2- because district court weighed relevant factors more heavily than defendant preferred does not mean it abused discretion); United States v. Anderson, 90 F.4th 1126, 1127 (8th Cir. 2024) (district court has wide latitude in weighing relevant factors, including discretion to assign more weight to offense’s nature and circumstances than to defendant’s mitigating personal characteristics). Doolin argues that: the district court incorrectly considered a 22-caliber rifle as relevant conduct; an adjustment for obstruction of justice was incorrect because he was not aware he was being investigated federally when he instructed his friend to destroy his cellphone; and the court erred in denying an acceptance-of- responsibility reduction. He also argues that the district court imposed a substantively unreasonable sentence by not giving enough weight to his young age and lack of state felony convictions in his record. We conclude that the district court did not err in considering the 22-caliber rifle as relevant conduct in calculating the Guidelines, as it was temporally close to the charged conduct; he repeatedly engaged in the same criminal conduct (possession of a firearm and aiding and abetting) between March and November 2023; and the c