United States v. Antonio Evans

── United States v. Antonio Evans ── Court: Court of Appeals for the Eighth Circuit Date: May 12, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1181 ___________________________ United States of America Plaintiff - Appellant v. Antonio Rayshaun Evans Defendant - Appellee ____________ Appeal from United States District Court for the Northern District of Iowa - Eastern ____________ Submitted: November 20, 2025 Filed: May 12, 2026 ____________ Before BENTON, GRASZ, and STRAS, Circuit Judges. ____________ GRASZ, Circuit Judge. Antonio Evans was convicted of two offenses that can carry enhanced mandatory minimums under 21 U.S.C. § 841(b)(1)(A). The district court 1 decided not to apply the enhancement because, in its view, it could not do so without 1 The Honorable C.J. Williams, Chief United States District Judge for the Northern District of Iowa. violating either Evans’s Sixth Amendment rights or 21 U.S.C. § 851. The government appeals, and we affirm. I. Background Evans was indicted on six counts, including conspiracy to distribute a controlled substance and distribution of a controlled substance in violation of § 841(a)(1). These counts can both carry an enhanced mandatory minimum sentence when a defendant has previously been convicted of a “serious drug felony.” § 841(b)(1)(A). A “serious drug felony” is “an offense under State law, involving manufacturing, distributing, or possessing with intent to manufacture or distribute, a controlled substance . . . , for which a maximum term of imprisonment of ten years or more is prescribed by law,” 18 U.S.C. § 924(e)(2)(A)(ii), and “for which — (A) the offender served a term of imprisonment of more than 12 months; and (B) the offender’s release from any term of imprisonment was within 15 years of the commencement of the instant offense.” 21 U.S.C. § 802(58). Evans was previously convicted of possession with intent to deliver cocaine in violation of Iowa Code § 124.401(1)(c), and this offense carries a 10-year maximum sentence. See Iowa Code § 902.9(1)(d). So if the government proves the two “incarceration- related facts” — i.e., that Evans served more than 12 months in prison and was released within 15 years of commencing his instant offense conduct — an enhanced mandatory minimum may apply. Congress outlined the procedure for applying this enhancement in § 851. First, “the United States attorney [must] file[] an information . . . stating in writing the previous convictions to be relied upon.” § 851(a)(1). Second, “the court shall after conviction but before pronouncement of sentence inquire of the person with respect to whom the information was filed whether he affirms or denies that he has been previously convicted as alleged . . . .” Id. § 851(b). Third, “[i]f the person denies any allegation of the information of prior conviction, . . . he shall file a written -2- response . . . .” Id. § 851(c)(1). Fourth, “[t]he court shall hold a hearing to determine any issues raised by the response which would except the person from increased punishment.” Id. This “hearing shall be before the court without a jury,” and “[a]t the request of either party, the court shall enter findings of fact and conclusions of law.” Id. And fifth, “if the court determines, after [the] hearing, that the person is subject to increased punishment by reason of prior convictions, the court shall proceed to impose sentence upon him . . . .” Id.