Case Explained: United States of America v. Jonathon Del Smith

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-26 The eighth-circuit reversed the district court’s order requiring Jonathon Del Smith to undergo a psychosexual evaluation as part of his prison sentence but affirmed the remainder of his 30-month imprisonment, which was ordered to run consecutively to an existing state sentence. The court held that under *Tapia v. United States*, 564 U.S. 319 (2011), federal district courts lack statutory authority under 18 U.S.C. § 3582(c) to mandate specific prison placements or treatment programs, including psychosexual evaluations, as a condition of imprisonment; while courts may recommend such measures to the Bureau of Prisons, they cannot order them directly. Regarding the substantive reasonableness of the sentence, the court applied a deferential abuse-of-discretion standard under *United States v. Feemster* and 18 U.S.C. § 3553(a), finding no clear error of judgment in the district court’s decision to impose consecutive sentences based on Smith’s offense conduct, post-incarceration solicitation, and prior Idaho felony history. The practical consequence is that the case is remanded to the district court to vacate the invalid psychosexual evaluation directive while leaving the 30-month federal sentence intact. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.