Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

George Harper, Jr. was indicted for being a felon in possession of ammunition following a shooting incident in Davenport, Iowa. After two unsuccessful suppression motions, he pled guilty. At sentencing, the district court applied the attempted murder cross-reference and sentenced Harper to 67 months’ imprisonment. Harper appealed the application of the cross-reference and the denial of one of his suppression motions.The United States District Court for the Southern District of Iowa denied Harper’s motion to suppress A.H.’s eyewitness identification, concluding that A.H. knew Harper before the incident and that his reluctance to identify Harper initially was due to fear of involvement in a police investigation. The court also found that Detective Reeves’s thumb placement on Harper’s photograph was not impermissibly suggestive. Harper pled guilty but preserved his right to appeal the denial of his motion to suppress and the district court’s sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the identification procedure did not create a substantial likelihood of irreparable misidentification, as A.H. knew Harper and identified him from surveillance footage before the photo array. The court also found that the district court did not err in applying the attempted murder cross-reference, as Harper fired multiple rounds at X.B., demonstrating an intent to kill or callous disregard for human life. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Harper" on Justia Law

In January 2020, Detective Josh Winter of the Clinton, Iowa, Police Department stopped Johnathon Lawrence Rose for having heavily-tinted windows, which violated Iowa law. During the stop, Rose's behavior made Winter nervous, prompting him to request a canine unit. The drug-detection dog alerted to the presence of drugs, leading to a search of Rose's car, where officers found drug paraphernalia and suspected drug residue. Rose was arrested, and further searches at the police department and his residence revealed more drugs, ammunition, and firearms. Rose was indicted for possessing methamphetamine with intent to distribute and unlawfully possessing a firearm as a felon.The United States District Court for the Southern District of Iowa held an evidentiary hearing and denied Rose's motion to suppress the evidence. Rose entered a conditional guilty plea, reserving his right to appeal the denial of the motion to suppress. The district court determined Rose was a career offender and sentenced him to 210 months of imprisonment. Rose appealed, and the United States Court of Appeals for the Eighth Circuit affirmed his sentence. Rose then filed a motion for relief under 28 U.S.C. § 2255, alleging ineffective assistance of counsel. The district court agreed, vacated his sentence, and reimposed it, allowing Rose to appeal again.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's denial of the motion to suppress, finding no constitutional violations in the traffic stop, searches, or Rose's incriminating statements. However, the court reversed Rose's sentence, agreeing with the government's concession that the case must be remanded for resentencing in light of a recent decision in United States v. Daye, which impacted the classification of Rose as a career offender. The case was remanded for further proceedings consistent with this opinion. View "United States v. Rose" on Justia Law

Larry Hayward was convicted by a jury of five counts related to heroin offenses. He subsequently filed a motion for acquittal or a new trial, which was denied. On appeal, Hayward contended that the district court erred by admitting evidence of an uncharged controlled buy involving heroin and fentanyl and argued that the evidence was insufficient to support his convictions for conspiracy to distribute drugs and aiding and abetting drug distribution.The United States District Court for the Western District of Missouri oversaw Hayward's trial. The court admitted evidence of an uncharged controlled buy from August 2019, which involved fentanyl, over Hayward's objections. Hayward was convicted on all counts and sentenced to 240 months in prison. He then appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting the evidence of the uncharged controlled buy. The court found that the evidence was relevant to Hayward's intent, was sufficiently similar to the charged crimes, was supported by sufficient evidence, and that its probative value was not substantially outweighed by the risk of unfair prejudice.The appellate court also found that there was sufficient evidence to support Hayward's convictions. The court noted that multiple witnesses testified about Hayward's involvement in a heroin distribution operation with his partner, Jasmine Steed. The court concluded that a reasonable jury could infer that Hayward was part of a conspiracy to distribute heroin and that he aided and abetted the distribution of heroin by Steed and another individual, Demario Brown.The Eighth Circuit affirmed the district court's judgment, upholding Hayward's convictions and sentence. View "United States v. Hayward" on Justia Law

Amity Dimock, the mother of Kobe Dimock-Heisler, sued the City of Brooklyn Center and four police officers, alleging unconstitutional warrantless entry and use of deadly force. The incident began when Kobe's grandfather, Erwin Heisler, called 911 reporting that Kobe had threatened him with a knife and hammer. When officers arrived, they entered the home without a warrant, leading to a confrontation where Kobe, holding a knife, was shot and killed by officers.The United States District Court for the District of Minnesota granted summary judgment in favor of the officers, citing qualified immunity. The court found that the officers reasonably believed exigent circumstances justified their warrantless entry and that they had probable cause to believe Kobe posed an immediate threat, justifying the use of deadly force. Dimock appealed the decision, challenging the grant of qualified immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the officers were entitled to qualified immunity. The court determined that the officers' belief in the existence of exigent circumstances was reasonable given the information they had, including Kobe's previous threats and mental health history. Additionally, the court found that the use of deadly force was justified as the officers had probable cause to believe Kobe posed an immediate threat to his grandmother and the officers, even though Kobe was only holding the knife and not actively attacking anyone at the moment of the shooting. The court concluded that the rights asserted by Dimock were not clearly established in this context, thus affirming the summary judgment in favor of the officers. View "Dimock v. City of Brooklyn Center" on Justia Law

Ann Jones filed lawsuits against Bloomingdales.com, LLC, and Papa John's International, Inc., alleging that their websites used "session replay" technology to record her electronic communications, including mouse movements, clicks, and keystrokes, without her knowledge. She claimed this technology invaded her privacy by creating a detailed record of her website visits, which could be used for targeted advertisements and website improvements.In the Eastern District of Missouri, the district court dismissed Jones's complaint against Bloomingdales for lack of subject-matter jurisdiction, citing a lack of concrete injury as she did not allege the capture of sensitive information. In the case against Papa John's, the district court dismissed the complaint for lack of personal jurisdiction. Jones appealed both dismissals.The United States Court of Appeals for the Eighth Circuit reviewed the cases and consolidated them for oral argument. The court held that Jones did not plausibly allege a concrete injury in either case, affirming the lower courts' judgments. The court noted that Jones's allegations did not demonstrate that the session-replay technology captured any private or sensitive information, such as social security numbers, medical history, or financial details. The court compared the situation to a security camera in a physical store, where customers do not have a reasonable expectation of privacy regarding their general movements.The Eighth Circuit concluded that Jones lacked standing to sue because her allegations did not show a concrete harm to her privacy. The court emphasized that merely asserting an invasion of privacy without supporting facts is insufficient to establish standing. Therefore, the court affirmed the dismissals of both cases. View "Jones v. Bloomingdales.com, LLC" on Justia Law

Brandon Phillips, who had several Missouri marijuana-possession convictions, pleaded guilty to a federal felon-in-possession charge. Despite Missouri legalizing marijuana and planning to expunge certain convictions, the district court sentenced him to 120 months in prison and imposed a lifetime ban on federal benefits.The United States District Court for the Eastern District of Missouri overruled Phillips's objection that his criminal history was overstated due to Missouri's legalization of marijuana. The court stated it would have imposed the same sentence regardless of the marijuana convictions. Phillips's marijuana convictions were still on record at the time of sentencing, although they were later expunged. Phillips argued that the expungement should require resentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that Phillips did not preserve the expungement issue for appellate review, as he did not clearly state the grounds for his objection in the district court. The court also determined that even if the issue had been preserved, the district court would have imposed the same sentence based on the 18 U.S.C. § 3553(a) factors, considering Phillips's reoffending on parole and possession of a large quantity of fentanyl.However, the Eighth Circuit vacated the federal-benefits ban, finding it was a plain error to apply it to Phillips, as the ban only applies to drug distributors, not gun possessors. The court held that the district court's application of the ban was clearly incorrect and affected Phillips's substantial rights. The court affirmed the 120-month prison sentence but vacated the federal-benefits ban. View "United States v. Phillips" on Justia Law

Kyle J. Dalen was civilly committed but not taken into custody. Five months later, he was arrested for felony harassment and stalking and placed in county jail. Dalen sued, alleging pretrial punishment, unreasonable restraint, and deliberate indifference to his medical needs. The district court dismissed his complaint, and Dalen appealed.The United States District Court for the District of Minnesota dismissed Dalen's complaint, concluding that he failed to plausibly allege his claims under federal law. Dalen argued that the district court improperly dismissed his claim of deliberate indifference in violation of the Fourteenth Amendment’s Due Process Clause. He also claimed that the defendant’s failure to transfer him from jail to a treatment facility was punitive and that his detention constituted unreasonable restraint.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Dalen's complaint lacked sufficient facts to support an objectively serious medical need, as required to prove deliberate indifference. The court also found that Dalen failed to show that his detention conditions were intentionally punitive or not reasonably related to a legitimate governmental purpose. Additionally, the court determined that Dalen did not provide specific facts about how he was restrained, which is necessary to support a claim of unreasonable restraint.The Eighth Circuit affirmed the district court's dismissal of Dalen's claims, concluding that he did not meet the necessary legal standards to proceed with his lawsuit. View "Dalen v. Harpstead" on Justia Law

Rusty J. Driscoll was convicted by a jury of conspiracy to distribute controlled substances, violating 21 U.S.C. §§ 841(a)(1) and 846. He was sentenced to 540 months by the United States District Court for the District of South Dakota. Driscoll appealed his conviction and sentence, arguing restricted access to discovery, improper admission of photos at trial, and the unreasonableness of his sentence.The District of South Dakota's standard discovery order restricted dissemination of discovery materials, which Driscoll's counsel had stipulated to. Driscoll's motions for personal access to discovery materials were denied. The district court found no good cause for exemption from the discovery order, emphasizing Driscoll's disruptive behavior, his review of discovery with counsel, and a co-defendant's testimony that Driscoll shared information from a proffer report.Driscoll challenged the admission of photos of items found during a search, arguing that the DEA agent who took the photos lacked personal knowledge. The court found the photos were sufficiently authenticated and admissible. Driscoll also argued that a photo of a letter addressed to him violated the best evidence rule, but the court held that the rule did not apply as the agent adopted the photo as his testimony. Driscoll's objection to the agent's testimony as unfairly prejudicial was also dismissed.Driscoll contended that his sentence was unreasonable due to disparities with his co-conspirators' sentences. The court found that the district court did not abuse its discretion, noting that Driscoll had a higher offense level and criminal history category, did not plead guilty or accept responsibility, and was considered the head of the conspiracy.The United States Court of Appeals for the Eighth Circuit affirmed the district court's judgment. View "United States v. Driscoll" on Justia Law

Shannon Montgomery filed a claim for disability benefits in May 2013, citing medical conditions including chiari malformation, syringomyelia, syrinx cavities, and degenerative disc disorder. An administrative law judge (ALJ) denied his claim, and the Appeals Council declined to review the decision. Montgomery then sought judicial review. In 2016, the district court reversed the SSA's decision and remanded the case, ordering a consultative examination and consideration of Montgomery's work history. Despite this, the ALJ again denied the claim without the required examination, leading to another remand. Eventually, after multiple remands and hearings, the ALJ denied the claim again in January 2022, finding Montgomery had severe impairments but could perform light work.The district court affirmed the ALJ's decision, and Montgomery appealed to the United States Court of Appeals for the Eighth Circuit. The appellate court reviewed the case de novo, focusing on whether the ALJ's decision was supported by substantial evidence. The court noted that the ALJ followed the five-step process for determining disability and found that Montgomery's impairments did not meet or equal any listed impairments. The ALJ concluded that Montgomery had the residual functional capacity (RFC) to perform light work and could adjust to other work available in the national economy.The Eighth Circuit addressed Montgomery's arguments regarding the 2016 Remand Order and found that the ALJ had complied with the order by considering Montgomery's work history and obtaining a consultative examination. The court also found that substantial evidence supported the ALJ's RFC assessment and denial of benefits, including opinions from state agency physicians and a medical expert. Consequently, the Eighth Circuit affirmed the district court's judgment, upholding the denial of Montgomery's disability benefits. View "Montgomery v. O'Malley" on Justia Law

Tad Mayfield, a nonpartisan legislative specialist in the assistant chief clerk’s office of the Missouri House of Representatives, was terminated on August 6, 2020, after sending an email on August 3, 2020, to the Speaker of the House and the President Pro Tem of the Missouri Senate advocating for mandatory face masks in the state capitol building due to COVID-19 concerns. Mayfield filed a lawsuit under 42 U.S.C. § 1983, alleging wrongful termination in retaliation for his email, claiming it violated his First Amendment rights.The case proceeded to a jury trial in the United States District Court for the Western District of Missouri. The jury found in favor of Mayfield, awarding him $15,000 in punitive damages and $14,993.93 in actual damages for lost wages. The district court denied the defendants' motions for judgment as a matter of law and awarded Mayfield attorney’s fees.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Mayfield’s email was protected speech under the First Amendment as it addressed a matter of public concern. The court found that the defendants failed to show that the email had an adverse impact on the efficiency of the House’s operations, which would have necessitated a Pickering balancing test. The court also upheld the jury’s finding that the email was a substantial or motivating factor in Mayfield’s termination and rejected the defendants' claim of qualified immunity, stating that the right to speak on matters of public concern was clearly established.Additionally, the court found sufficient evidence to support the submission of punitive damages to the jury, given the defendants' knowledge that terminating an employee for raising public health concerns could be illegal. The court also upheld the district court’s award of attorney’s fees to Mayfield, finding no abuse of discretion. View "Mayfield v. Miller" on Justia Law