United States v. Medard Elonge
CourtCourt of Appeals for the Eighth Circuit
Date FiledNovember 13, 2026
Docket26-1752
StatusUnpublished
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Full Opinion
United States Court of Appeals
For the Eighth Circuit
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No. 26-1752
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Medard Lotahe Elonge
lllllllllllllllllllllDefendant - Appellant
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Appeal from United States District Court
for the Northern District of Iowa - Eastern
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Submitted: November 3, 2026
Filed: November 13, 2026
[Unpublished]
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Before LOKEN, SHEPHERD, and ERICKSON, Circuit Judges.
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PER CURIAM.
Medard Elonge, a citizen of the Democratic Republic of the Congo, appeals the
within-Guidelines-range sentence imposed by the district court1 after he pled guilty
1
The Honorable C.J. Williams, Chief Judge, United States District Court for the
Northern District of Iowa.
to conspiring to defraud the United States. His counsel has moved to withdraw, and
has filed a brief under Anders v. California, 386 U.S. 738 (1967), challenging the
substantive reasonableness of the sentence. Elonge has filed a pro se brief
challenging the validity of his guilty plea and counsel’s effectiveness, and raising
“newly discovered evidence.”
We conclude that Elonge entered into the plea agreement knowingly and
voluntarily, see United States v. Green, 521 F.3d 929, 931 (8th Cir. 2008) (standard
of review); Nguyen v. United States, 114 F.3d 699, 703 (8th Cir. 1997) (defendant’s
statements during plea hearing carry strong presumption of verity); and that any
challenge to the factual basis for his plea was contradicted by Elonge’s adoption of
the factual basis at the plea hearing, see United States v. Watson, 883 F.3d 1033,
1037-38 (8th Cir. 2018) (concluding self-serving assertion that defendant was
confused as to factual basis was directly contradicted by admissions at plea hearing).
Relatedly, we conclude the district court did not abuse its discretion in implicitly
denying any motion to withdraw his guilty plea. See United States v. Osei, 679 F.3d
742, 746-47 (8th Cir. 2012) (standard of review; affirming denial of motion to
withdraw guilty plea where defendant testified clearly about the factual basis for his
guilty plea, responded coherently when asked whether he had adequately conferred
with counsel, and indicated he understood and accepted that his plea would be final).
We also conclude that Elonge’s allegations of prosecutorial misconduct lack support
in the record, see United States v. New, 491 F.3d 369, 378 (8th Cir. 2007) (standard
of review), and that any claims of ineffective assistance of counsel are more
appropriate for collateral review, see United States v. Ramirez-Hernandez, 449 F.3d
824, 826-27 (8th Cir. 2006).
Additionally, we conclude that the district court did not impose a substantively
unreasonable sentence, as there is no indication the court failed to consider a relevant
factor, gave significant weight to an improper factor, or committed a clear error of
judgment in weighing the proper factors. See United States v. Newell, 186 F.4th
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1052, 1054 (8th Cir. 2026) (reviewing sentence under deferential abuse-of-discretion
standard; within-Guidelines-range sentence entitled to presumption of
reasonableness); United States v. Feemster, 572 F.3d 455, 461-62 (8th Cir. 2009) (en
banc) (discussing substantive reasonableness); see also United States v. Anderson,
90 F.4th 1226, 1227 (8th Cir. 2024) (explaining district court has wide latitude in
weighing relevant factors, including discretion to assign more weight to offense’s
nature and characteristics than to defendant’s mitigating personal characteristics).
Finally, we have independently reviewed the record under Penson v. Ohio, 488
U.S. 75 (1988), and have found no nonfrivolous issues for appeal. Accordingly, we
grant counsel’s motion to withdraw and affirm the judgment.
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