Yet another set of defendants losing reasonableness arguments in the Eighth Circuit

As has been its common practice, the Eighth Circuit yesterday embraced all of the governments claims on appeal in a series of reasonableness rulings (decisions here and here and here and here). 

The Circuit’s rejection of various defendants’ arguments in their appeals of long sentences is not at all surprising.  But the reversal of a seemingly reasoned below-guideline sentence in US v. Carlson, No. 06-3372 (8th Cir. Aug. 20, 2007) (available here) suggests that the Circuit still has a tendency to view sentences of probation as presumptively unreasonable, even though the Supreme Court in Rita stressed that circuits may not apply such a presumption to non-guideline sentences.