United States v. Jennifer Mares-Flores

── United States v. Jennifer Mares-Flores ── Court: Court of Appeals for the Eighth Circuit Date: June 03, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1725 ___________________________ United States of America Plaintiff - Appellee v. Jennifer Mares-Flores Defendant - Appellant ____________ Appeal from United States District Court for the Southern District of Iowa - Central ____________ Submitted: January 12, 2026 Filed: June 3, 2026 [Unpublished] ____________ Before SHEPHERD, KELLY, and STRAS, Circuit Judges. ____________ PER CURIAM. In 2016, Jennifer Mares-Flores was convicted of one count of conspiracy to distribute methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1), (b)(1)(C) and 846, for which she was sentenced to 78 months’ imprisonment, followed by 3 years of supervised release. After the completion of her sentence of incarceration, and following two revocations of supervised release, the United States Probation Office filed a petition to revoke Mares-Flores’s supervised release for a third time, alleging that she committed five new law violations, all related to possession of controlled substances. The district court 1 granted the petition, revoked Mares-Flores’s supervised release, and sentenced her to 18 months’ imprisonment, followed by an additional 2 years of supervised release. On appeal, Mares-Flores challenges the substantive reasonableness of her revocation sentence. Having jurisdiction under 28 U.S.C. § 1291, we affirm. Mares-Flores’s conviction arises from her participation in a multi-person scheme to distribute methamphetamine in the Northern District of Iowa. After completing her original sentence of incarceration, Mares-Flores began serving supervised release in July 2022, and her supervision was transferred to the Southern District of Iowa. Within months, Mares-Flores violated various conditions of her supervised release—all related to drug activity—resulting in the Probation Office seeking to have it revoked. The district court granted the Probation Office’s petition, revoked Mares-Flores’s supervised release, and sentenced her to 6 months’ imprisonment, followed by 30 months of supervised release. After completing this term of incarceration, in July 2023, Mares-Flores reported to a residential reentry facility, where she immediately tested positive for methamphetamine and marijuana. When Mares-Flores was expelled from the facility three months later for engaging in drug dealing activities and was also found to be in contact with a felon, the Probation Office again petitioned to revoke Mares-Flores’s supervised release. The district court revoked Mares-Flores’s supervised release for a second time and sentenced her to 8 months’ imprisonment followed by 24 months of supervised release. Mares-Flores began serving her current term of supervised release in June 2024. In December 2024, the Probation Office filed a petition seeking the revocation of supervised release based on five new law violations, which it alleged were 1 The Honorable Stephanie M. Rose, Chief Judge, United States District Court for the Southern District of Iowa. -2- possession with intent to distribute marijuana, possession with intent to distribute methamphetamine, failure to affix a tax stamp, possession of a controlled substance, and possession of drug paraphernalia. These new law violations stemmed from Mares-Flores’s arrest in Indianola, Iowa, where police recovered, during a se