Case Explained: United States of America v. Steven Clay Bruhn

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-17 The eighth-circuit affirmed the district court’s upward variance sentence of 20 months’ imprisonment imposed upon revocation of Steven Bruhn’s supervised release. The court applied the plain error standard of review, requiring the appellant to demonstrate that the district court committed an error that was obvious, affected his substantial rights, and seriously affected the fairness, integrity, or public reputation of judicial proceedings. The court held that the district court did not plainly err by relying on facts found in the unobjected-to violation report and statements made by the probation officer regarding Bruhn’s lack of intent to participate in the Teen Challenge rehabilitation program. Specifically, the court found that the record supported the district court’s conclusion that Bruhn had a history of noncompliance, failed to take his addiction seriously, and violated the trust placed in him, thereby providing a reasoned basis for the upward variance under 18 U.S.C. § 3553(a). As a result, the sentence stands, and Bruhn must serve the 20-month term. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.