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

A police officer in Des Moines, Iowa attempted to stop a vehicle driven by Dylan Pettyjohn for lacking license plates or a temporary registration. Pettyjohn fled, leading the officer on a high-speed chase through a residential area before crashing. He then ran from the vehicle, discarding a loaded revolver and a fanny pack containing 54 fentanyl pills, $389 in small bills, marijuana, and about 85 grams of methamphetamine. A search of his vehicle yielded a digital scale with white residue, more marijuana, and shell casings. Pettyjohn was arrested, and a federal grand jury indicted him on multiple counts related to drug possession with intent to distribute, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm.The United States District Court for the Southern District of Iowa denied Pettyjohn’s motion to dismiss the felon in possession charge, rejecting his argument that 18 U.S.C. § 922(g)(1) violated the Second Amendment. The court also allowed limited admission of his prior felony convictions for impeachment purposes, after an agreement between Pettyjohn and the government. At trial, Pettyjohn moved for acquittal based on insufficient evidence, but the district court found the evidence sufficient and denied the motions. The jury found Pettyjohn guilty on all counts, and the court sentenced him to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirmed the district court’s evidentiary rulings under Rules 404(b) and 609, and upheld the constitutionality of § 922(g)(1) based on circuit precedent. The Eighth Circuit held that the evidence was sufficient to support the convictions, the district court did not abuse its discretion in admitting prior conviction evidence, and § 922(g)(1) is constitutional. The judgment of the district court was affirmed. View "United States v. Pettyjohn" on Justia Law

A company operating movie theaters in several Midwestern states offered free movie trailers on its website to attract customers. After a website visitor viewed these trailers, she began to receive targeted advertisements on her Facebook page. She alleged that the company had installed a program, Meta Pixel, which tracked her activity and shared her personal information with Meta (Facebook’s parent company). She claimed that the company, as a “video tape service provider,” had a duty under the Video Privacy Protection Act not to disclose her personally identifiable information without consent.The United States District Court for the District of Minnesota dismissed the complaint. The district court found that the company was not a “video tape service provider” as defined by the statute, because it was not engaged in the business of renting, selling, or delivering prerecorded video cassette tapes or similar audio visual materials. As a result, the court concluded that the company had no statutory obligation to withhold the plaintiff’s personal information under the Act.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The appellate court agreed with the district court, holding that movie theaters are not “engaged in the business” of renting, selling, or delivering prerecorded video cassette tapes or similar audio visual materials. The court reasoned that the statutory definition requires a physical medium similar to video cassette tapes, which does not include theatrical screenings or free online trailers. The court further determined that offering trailers online did not constitute a separate business of delivering audio visual materials for livelihood or gain. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "Christopherson v. Cinema Entertainment Corp." on Justia Law

Devon Holt was charged with being a felon in possession of a firearm after investigators obtained a warrant to search his Facebook account and found posts and messages referencing firearms. These included statements suggesting he was carrying a firearm and expressing motives related to self-protection and respect. Holt pleaded not guilty, and his case proceeded to trial. He objected to the admission of this Facebook content, arguing it was prejudicial, but the district court admitted some of the posts for the limited purpose of showing knowledge and motive, instructing the jury accordingly. The jury convicted Holt.The United States District Court for the District of Minnesota sentenced Holt to 42 months’ imprisonment, slightly above the minimum of the guideline range. Holt argued for a lower sentence, citing difficult pretrial detention conditions and uncertainty before sentencing. The district court explained its reasoning in detail, acknowledging both aggravating and mitigating factors, including Holt’s positive use of his time in jail. Holt then appealed, challenging both the admission of the Facebook evidence and the adequacy of the sentencing explanation.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary and sentencing decisions. It held that the Facebook content was properly admitted under Federal Rule of Evidence 404(b) because it was relevant to issues of Holt’s knowledge and motive and was not unfairly prejudicial. The appellate court also found that the district court gave a sufficiently detailed explanation for its sentencing decision, considered the relevant factors, and imposed a substantively reasonable sentence. Consequently, the Eighth Circuit affirmed both the conviction and the sentence. View "United States v. Holt" on Justia Law

Raphael Nunn was convicted of kidnapping, bank fraud, and aggravated identity theft based on three incidents involving separate victims. In the first incident, Nunn robbed C.L. at gunpoint and stole her purse, later using her bank cards for unauthorized purchases. The second incident involved the theft of J.T.’s backpack, which contained her bank cards, subsequently used without her permission. In the third incident, Nunn kidnapped S.E. from a parking garage, forced her to withdraw cash from a bank, and left her at a park. Law enforcement identified Nunn as the perpetrator in all three cases and arrested him.Prior to trial in the United States District Court for the District of Minnesota, Nunn moved to suppress statements made during a custodial interview, arguing he had invoked his right to counsel. The magistrate judge denied the motion, finding the invocation ambiguous, and the district court adopted this ruling. At trial, the government introduced Nunn’s interview statements and allowed C.L. to make a spontaneous in-court identification, to which Nunn did not object. The jury found Nunn guilty on all counts. The Presentence Investigation Report calculated an advisory guidelines range of 168 to 210 months plus a 24-month mandatory minimum. The district court varied upward, citing Nunn’s lengthy criminal history and imposed a total sentence of 288 months.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the conviction and sentence. The court held that the district court did not clearly err in denying the motion to suppress because Nunn’s statement was not an unambiguous invocation of his Miranda rights. The admission of C.L.’s in-court identification did not constitute plain error. Additionally, the district court did not abuse its discretion in imposing an above-guidelines sentence, properly weighing both aggravating and mitigating factors. View "United States v. Nunn" on Justia Law

A detainee at the St. Louis County jail, Jovon Mitchell, developed severe symptoms including vomiting, a severe headache, dizziness, difficulty standing and walking, and slurred speech over the course of December 23–25, 2019. Various jail nurses and staff responded to his complaints with minimal or delayed medical care, despite jail policies requiring prompt attention for such symptoms. Jovon was ultimately found unresponsive and died from a stroke after being transferred to a hospital. His brother, Juan Mitchell, filed suit under 42 U.S.C. § 1983, alleging deliberate indifference to Jovon’s serious medical needs by individual medical staff and correctional officers, as well as failure-to-train and unconstitutional policy claims against supervisory staff and St. Louis County. State law claims were also asserted.The United States District Court for the Eastern District of Missouri granted the defendants' motions to dismiss the federal claims for failure to state a claim and declined to exercise supplemental jurisdiction over the state law claims, thereby dismissing them as well. The district court did not address the issue of qualified immunity. Juan Mitchell appealed the dismissal as to certain defendants.The United States Court of Appeals for the Eighth Circuit held that the complaint plausibly alleged deliberate indifference to Jovon’s serious medical needs by three nurses, but not by the physician assistant or correctional officers involved. The Court also found that the failure-to-train claim against St. Louis County was plausibly stated but concluded that the claims against the individual supervisors did not sufficiently allege notice of a pattern of unconstitutional acts. The Court affirmed the dismissal in part and reversed in part, remanding for further proceedings. The Court instructed the district court to exercise supplemental jurisdiction over the state law claims, given the reinstatement of certain federal claims. View "Mitchell v. Saint Louis County" on Justia Law

An inmate at the McPherson Unit, a maximum-security prison in Arkansas, alleged that from 2010 to 2014, a chaplain at the facility sexually assaulted her weekly in his office. The chaplain, who was permitted by policy to be alone with female inmates, also assaulted at least two other inmates in a similar, regular manner. He resigned in 2014 and later pleaded guilty to third-degree sexual assault. The inmate brought a lawsuit under 42 U.S.C. § 1983 against several prison officials in their individual capacities, claiming they failed to protect her from the assaults and failed to supervise the chaplain adequately.The United States District Court for the Eastern District of Arkansas, Chief Judge Kristine G. Baker presiding, denied in part the defendants’ motions for summary judgment based on qualified immunity. The court found there were genuine issues of material fact regarding whether the defendants—three particular officials—were aware of the chaplain’s conduct and were deliberately indifferent to the risk he posed. The district court also found genuine disputes as to whether two of the officials had sufficient supervisory authority over the chaplain to be liable for failure to supervise and whether they took appropriate remedial action.The United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment on qualified immunity grounds. It held that, construing the facts in the light most favorable to the inmate, a reasonable jury could find the defendants were deliberately indifferent to a substantial risk of serious harm, violating clearly established Eighth Amendment rights. The appellate court also held that there were genuine disputes of material fact regarding the supervisory liability of two officials. Accordingly, the Eighth Circuit affirmed the district court’s denial of summary judgment, allowing the inmate’s claims to proceed to trial. View "Arnett v. Norris" on Justia Law

Two individuals from Colorado, involved in drug trafficking, drew law enforcement attention while driving through South Dakota. After a high-speed chase ended on the Pine Ridge Indian Reservation, their vehicle ran low on gas. When they stopped, an FBI victim specialist, returning from a work assignment in an official vehicle, stopped to offer assistance. The defendants carjacked him at gunpoint, forced him into the backseat, and drove to a gas station. The victim escaped, and the defendants later abandoned the stolen vehicle. Both men were subsequently arrested in Colorado. The government brought multiple charges, including kidnapping a federal officer, carjacking, using a firearm during a crime of violence, and illegal firearm possession.The United States District Court for the District of South Dakota oversaw their joint trial. The court denied Morales’s motions to sever the trials and to obtain the victim’s medical records. It allowed limited portions of a codefendant’s confession and evidence of other drug activity, some as intrinsic and some as extrinsic under Federal Rule of Evidence 404(b). Both defendants were convicted on all counts by a jury and received lengthy sentences. The district court applied enhancements and upward variances based on the facts found at sentencing.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed several trial and sentencing issues. It held that the district court did not abuse its discretion in denying severance or in admitting the challenged evidence. The court found that any error in failing to give a limiting instruction regarding the confession did not affect the outcome. The court concluded the evidence was sufficient to support all convictions, including the statutory elements of kidnapping a federal officer and using a firearm. The Eighth Circuit affirmed the sentences, finding no clear or obvious error with the enhancements or the upward variance. Accordingly, the court affirmed the district court’s judgments. View "United States v. Alvarez-Sorto" on Justia Law

In early 2023, law enforcement in Sioux City, Iowa, used a confidential informant, MS, to investigate methamphetamine distribution. MS identified AP as a supplier, who, in turn, sourced methamphetamine from a man known as “Arkansas,” believed to be Johnnie A. Cannon. Through three controlled buys, investigators observed Cannon’s involvement: he was seen at AP’s residence during each transaction, and physical evidence—including serialized cash from a controlled buy—was seized from him. During a post-arrest interview, Cannon admitted to distributing methamphetamine, including to AP.The United States District Court for the Northern District of Iowa presided over Cannon’s trial. Cannon’s counsel made several motions and challenges at trial, including a Batson challenge regarding jury composition, a motion for judgment of acquittal, and motions for a new trial and arrest of judgment. The district court denied these motions. A jury found Cannon guilty of conspiracy to distribute methamphetamine and three counts of distribution and aiding and abetting distribution. The court sentenced him to 262 months’ imprisonment for these convictions and revoked his supervised release from a prior conviction, imposing an additional 37 months.On appeal, Cannon argued before the United States Court of Appeals for the Eighth Circuit that his Sixth Amendment right to a jury drawn from a fair cross-section was violated, that the admission of his prior conviction was improper under Rule 404(b), that there was insufficient evidence to support his convictions, and that he received ineffective assistance of counsel. The Eighth Circuit held that Cannon’s cross-section jury claim lacked evidence of systematic exclusion, affirmed the admission of his prior conviction as relevant under established precedent, found the trial evidence sufficient to sustain the convictions, and declined to consider the ineffective assistance claim on direct appeal. The court affirmed both the convictions and the revocation of supervised release. View "United States v. Cannon" on Justia Law

Late on January 10, 2022, Kansas City police officers stopped a pickup truck with a broken headlight and expired license plate. The driver, Alonzo Miller, was not the vehicle’s owner and could not provide proof of insurance. The officers recognized the area Miller had driven from as one known for criminal activity. During the stop, Miller exhibited nervous behavior. A computer check revealed Miller was on probation and parole for a violent felony involving a firearm. The officers, noting a significant age difference between Miller and his passenger and the late hour, suspected possible illicit activity. After Miller mentioned “something under there” when asked about illegal items and consented to a vehicle search, the officers asked him to step out. Miller behaved unusually, triggering further suspicion. As an officer attempted a frisk, Miller resisted, and a firearm discharged from his coat pocket. Miller was arrested and later indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Missouri denied Miller’s motion to suppress evidence from the stop and search. The magistrate judge found the stop lawful, that Miller’s consent to search was voluntary, and that the officers had reasonable suspicion to extend the stop and frisk Miller based on the totality of the circumstances—including Miller’s criminal history, behavior, and responses during the encounter. The district court adopted these findings. Miller then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Miller’s suppression motion, applying de novo review to legal conclusions and clear error review to factual findings. The court held that, under the totality of the circumstances, the officers had reasonable suspicion to extend the stop, request consent to search the vehicle, and frisk Miller. The judgment of the district court was affirmed. View "United States v. Miller" on Justia Law

In this case, Roland Pour Sr. purchased and insured a home in Minnesota, where his children Kmontee and Roland Jr. lived. Pour Sr. moved to Georgia in 2019, updating all personal records to reflect his new residence but did not sell the Minnesota home or notify the insurer of his change in residence. He maintained some belongings in the Minnesota home and visited occasionally, while his children continued to live there and paid for utilities. In September 2021, a fire damaged the home and personal property. Pour Sr., living in Georgia at the time, filed a claim under the homeowners insurance policy for damages to the house, his own property stored there, and his children’s property and living expenses.The United States District Court for the District of Minnesota reviewed cross motions for summary judgment. Applying Minnesota law, the court granted summary judgment to Liberty Mutual, holding that the policy did not cover the home or attached structures because Pour Sr. did not “reside” at the house at the time of the fire. The court also held that Kmontee and Roland’s property was not covered because, although they lived in the home, they were not “residents of Pour Sr.’s household” as defined by the policy and Minnesota law. Pour Sr.’s claim for his own property was settled and not at issue.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling de novo. The appellate court affirmed the district court’s judgment, holding that, under the unambiguous terms of the policy and Minnesota law, Pour Sr. did not reside at the Minnesota home during the relevant period, and his children were not insureds under the policy because they did not reside in his household. The court found no conflict with Minnesota’s Standard Fire Insurance Policy and rejected arguments regarding ambiguity or illusory coverage. View "Pour v. Liberty Mutual Pers. Ins. Co." on Justia Law