Case Explained: United States of America v. Donavan Jay White Owl

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-07-30 The eighth-circuit affirmed Donavan White Owl’s fifteen-year sentence for voluntary manslaughter, rejecting his challenges to the denial of a sentencing guideline adjustment and the upward variance imposed by the district court. The court held that the district court did not clearly err in denying White Owl a two-level downward adjustment for acceptance of responsibility under USSG § 3E1.1 because White Owl denied involvement in the fire during his presentence interview, claimed he pled guilty only to escape jail, and accused his wife of lying, conduct inconsistent with genuine acceptance of responsibility. The court further ruled that the district court did not abuse its discretion by varying upward from the advisory guideline range based on facts not admitted in the plea agreement, finding sufficient indicia of reliability in trial testimony and FBI interview reports regarding White Owl’s motive and actions. Additionally, the court found no plain error in rejecting White Owl’s Sixth Amendment argument, noting that Supreme Court precedent permits sentencing judges to make factual findings that support an upward variance within statutory limits, and determined the sentence was not substantively unreasonable under 18 U.S.C. § 3553(a) given the seriousness of the offense and White Owl’s lack of remorse. The judgment of the district court stands. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.