United States v. Knight

── United States v. Knight ── Court: Court of Appeals for the Fifth Circuit Date: June 08, 2026 Category: Direct Criminal Case: 25-30633 Document: 56-1 Page: 1 Date Filed: 06/08/2026 United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit No. 25-30633 FILED June 8, 2026 Summary Calendar ____________ Lyle W. Cayce Clerk United States of America, Plaintiff—Appellee, versus Brian O. Knight, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Middle District of Louisiana USDC No. 3:25-CR-14-1 ______________________________ Before Higginbotham, Engelhardt, and Ramirez, Circuit Judges. Per Curiam: * Brian O. Knight challenges the substantive reasonableness of the 15- month sentence imposed following his guilty plea conviction for possession of a firearm by a convicted felon. He first argues that the district court gave significant weight to an improper factor, his need for rehabilitation, in violation of Tapia v. United States, 564 U.S. 319, 332-34 (2011). Because he _____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 25-30633 Document: 56-1 Page: 2 Date Filed: 06/08/2026 No. 25-30633 did not raise this specific argument in the district court, we review it for plain error. See United States v. Zarco-Beiza, 24 F.4th 477, 481-82 (5th Cir. 2022). The court’s statements regarding rehabilitation and Knight’s alcohol abuse, viewed in context, did not clearly or obviously violate Tapia. Thus, Knight has not demonstrated reversible plain error. See Puckett v. United States, 556 U.S. 129, 135 (2009). Knight also contends the district court failed to give sufficient weight to his post-incarceration rehabilitation and gave too much weight to his dangerousness based on unrelated charges. The district court thoroughly considered Knight’s history and his arguments for a lesser sentence but concluded that a within-guidelines sentence was appropriate in light of the 18 U.S.C. § 3553(a) factors. Knight fails to show any abuse of discretion. See United States v. Castillo-Rubio, 34 F.4th 404, 411 (5th Cir. 2022). AFFIRMED. 2