--- title: "United States v. Norris" citation: "62 F.4th 441 (8th Cir. 2023)" authority_id: "AUTH-CA8-NORRIS-62-F4TH-441" authority_type: "case" jurisdiction: "federal_eighth_circuit" precedential_status: "binding_in_ca8" official_url: "https://ecf.ca8.uscourts.gov/opndir/23/03/213849P.pdf" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA8-NORRIS-62-F4TH-441/" legal_review: "2026-08-25" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # United States v. Norris ## Holdings used - Rule 32.1(c)(1) does not require counsel or a hearing before denial of termination or modification, and a separate denial explanation is unnecessary when the record makes the court's basis discernible. ## Material limitation Binding only in the Eighth Circuit and only for the bounded procedural postures in the linked claims. Official published opinion reviewed. The holdings concern denial: an actual condition modification ordinarily triggers Rule 32.1, and Norris does not approve a record from which no basis can be discerned. A comprehensive commercial citator was not run. ## Official source and pinpoints 62 F.4th 441 (8th Cir. 2023), 62 F.4th 445–51: ## Linked claims - `CLM-CIR8-005` ## Used in - [Eighth Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/eighth-circuit.md)