Case Explained: United States of America v. Gregory Shawn Berry

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-07-23 The eighth-circuit affirmed the 48-month imprisonment sentence imposed on Gregory Shawn Berry for violating 18 U.S.C. § 922(a)(6) by making a false statement in the acquisition of a firearm. The court applied a two-step review standard, first examining whether the district court committed significant procedural error and second assessing substantive reasonableness under an abuse-of-discretion standard. Regarding procedural error, the court held that the district court did not clearly err in considering facts relevant to Berry’s conduct as a firearms dealer, even though he pleaded guilty only to making a false statement; the record supported the finding that Berry purchased lower receivers, assembled them into operable firearms, and sold them for profit without a license. Regarding substantive reasonableness, the court determined that the district court did not abuse its discretion by giving significant weight to this relevant conduct under 18 U.S.C. § 3553(a) factors when imposing a sentence below the applicable United States Sentencing Guidelines range of 57 to 71 months. Consequently, the judgment of the district court is affirmed and Berry’s sentence stands. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.