United States v. Del Evans, Jr.

── United States v. Del Evans, Jr. ── Court: Court of Appeals for the Eighth Circuit Date: June 08, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1491 ___________________________ United States of America Plaintiff - Appellee v. Del Martinez Evans, Jr. Defendant - Appellant ___________________________ No. 25-1492 ___________________________ United States of America Plaintiff - Appellee v. Del Martinez Evans, Jr. Defendant - Appellant ___________________________  No. 25-1493 ___________________________ United States of America Plaintiff - Appellee v. Del Martinez Evans, Jr. Defendant - Appellant ____________ Appeals from United States District Court for the Northern District of Iowa - Western ____________ Submitted: January 16, 2026 Filed: June 8, 2026 [Unpublished] ____________ Before SHEPHERD, KELLY, and STRAS, Circuit Judges. ____________ PER CURIAM. Despite committing multiple bank robberies, Del Evans argues he is not a career offender. See U.S.S.G. § 4B1.1. It turns out that it does not matter because the district court1 was clear that his sentence would be the same either way. 1 The Honorable Leonard T. Strand, United States District Judge for the Northern District of Iowa. -2-  I. Evans has a habit of robbing banks. In 2008, he robbed his first one and tried again within just a few days. Six years later, during a transfer to a halfway house, he escaped and committed three more. The robberies followed the same pattern: Evans would give a note to the teller, who would then hand over the money. The two sets of convictions, one for each group of robberies, landed him in federal prison for over a decade. Then, just two months after beginning supervised release, Evans once again walked into a bank and handed a note to the teller, who gave him $5,308 in cash. He fled the scene, but officers arrested him the same day. Two consequences followed. The first was revocation of supervised release, which led to concurrent 24-month prison terms, one for each federal sentence he was serving. 2 The second was another federal bank-robbery conviction, see 18 U.S.C. § 2113(a), which the district court thought made him a career offender, see U.S.S.G. § 4B1.1(a) (applying an enhancement if “the instant offense of conviction is a felony that is . . . a crime of violence” and “the defendant has at least two prior felony convictions of . . . a crime of violence”). He received a 188-month consecutive sentence, which was at the top of the advisory range. The court explained that, even if it was wrong about the enhancement, “188 months [was] simply the minimum sentence” it would impose. II. “Any error” here “became harmless the moment the district court made clear that the sentence would be the same, with or without” the career-offender enhancement. United States v. Mejia, 172 F.4th 601, 606 (8th Cir. 2026). Provided that it considered “why a longer sentence was ‘sufficient, but not greater than 2 Although Evans also filed notices of appeal in the revocation cases, he did not address them in his brief. We affirm both sentences. See 8th Cir. R. 47B. -3- necessary,’ to serve ‘the purposes’ of the federal sentencing s