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

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Defendant was convicted in 2003 of producing, transporting, and reproducing child pornography and sentenced to 235 months in prison, followed by 5 years of supervised release. After defendant violated three conditions of supervised release, the district court imposed a new condition requiring polygraph testing. The Eighth Circuit affirmed the district court's imposition of the new condition, holding that defendant's unwillingness to obey rules restricting his access to child pornography shows that polygraph testing is necessary to protect the public from further crimes. The court also held that defendant waived any challenges to the district court's denial of his motions for relief in Appeal No. 19-3362. View "United States v. Smith" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit affirmed the district court's decision to modify defendant's two conditions of supervised release imposed after he was convicted in 2003 of producing, transporting, and reproducing child pornography. The court held that, although the district court erred by denying defendant a hearing before modifying Conditions 6 and 7, the error was harmless. In this case, Condition 6 concerned defendant's contact with minors and Condition 7 concerned possession and access to pornography. View "United States v. Smith" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit affirmed the district court's reduction of defendant's sentence pursuant to the First Step Act. The court held that the district court accurately noted that the sentence sought to be reduced was a substantial downward variance from the applicable guideline range and concluded the initial variance had eliminated excessiveness the First Step Act was intended to remedy. Furthermore, in evaluating the existing sentence, the district court also considered post-sentence rehabilitation and the 18 U.S.C. 3553(a) sentencing factors. The court also held that there was no procedural or legal error in defendant's 216 month sentence, and the district court did not abuse its substantial sentencing discretion or impose a substantively unreasonable sentence by declining to reduce defendant's sentence below 216 months imprisonment. View "United States v. Harris" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit affirmed the district court's reduction of defendant's sentence under 18 U.S.C. 3582(c)(2). The court held that there is no constitutionally protected liberty interest in a discretionary sentence reduction and thus the Due Process Clause does not afford procedural protections to those who seek one. Therefore, the court rejected defendant's claim that the district court should have held an evidentiary hearing before it ruled on his motion. The court also held that there is enough information on the record for meaningful appellate review where the district court quoted the eligibility report and described, among other things, that defendant was the leader of a large drug conspiracy and issued multiple threats to codefendants, an attorney, and a government agent in an attempt to obstruct the investigation against him. View "United States v. Alaniz" on Justia Law

Posted in: Criminal Law
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In this action brought under 42 U.S.C. 1983, the Eighth Circuit affirmed the district court's grant of summary judgment in favor of the Police Defendants, a probation officer, various Board Defendants, and the City. Plaintiff filed suit after his convictions related to armed robbery were reversed, and the victim of the crime did not want to testify at another trial, the State declined to retry the case, and plaintiff was released. The court held that the district court correctly granted summary judgment to the Police Defendants on the section 1983 Brady claim, because plaintiff failed to establish a genuine dispute of material fact about whether the Police Defendants violated his constitutionally protected federal rights by suppress or destroying evidence in bad faith. The court also held that, because the record evidence does not create a genuine dispute of material fact regarding plaintiff's fabrication-of-evidence claims, the district court did not err in granting summary judgment to the Police Defendants. Furthermore, the district court court did not err in granting summary judgment to the Police Defendants on plaintiff's failure-to-investigate claim. Finally, the court held that plaintiff's conspiracy and Monell claims necessarily failed. View "McKay v. City of St. Louis" on Justia Law

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The Eighth Circuit affirmed defendant's conviction and sentence for two counts of assaulting an intimate partner by strangling, one count of assault with a dangerous weapon, and one count of domestic assault by an habitual offender. Assuming without deciding that defendant did not waive his right to appeal the issue, the court held that defendant failed to show justifiable dissatisfaction with his attorney and the magistrate judge did not err in denying his request for substitute counsel. The court also held that the magistrate judge did not err by continuing the trial over defendant's objection and excluding the time from calculations under the Speedy Trial Act; the district court did not err by denying defendant's mid-trial request to proceed pro se; and the district court properly considered the 18 U.S.C. 3553(a) factors and did not abuse its discretion by imposing an within-Guidelines sentence. View "United States v. Harlan" on Justia Law

Posted in: Criminal Law
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Plaintiff filed suit against several prison officials in their individual capacities under 42 U.S.C. 1983, challenging a disciplinary adjudication, conditions of confinement, adequacy of medical treatment, and alleged retaliatory acts. The district court denied motions to dismiss and for summary judgment. The Eighth Circuit held that officials were entitled to a ruling on their defense of qualified immunity as to the Eighth Amendment claims in Count II. Because the order granting the motion for reconsideration effectively denied the officials' motion to dismiss without ruling on qualified immunity, the court remanded the case for further proceedings to address the question of qualified immunity on Count II. As to the remaining claims, the court held that the district court did not abuse its discretion by determining that the officials failed to properly plead or carry their burden of proof as to any defenses of privileges and immunities. Accordingly, the court rejected the challenge to the order denying summary judgment on the remaining counts. View "Spann v. Lombardi" on Justia Law

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A student and her parents filed suit against the Minnesota Department of Education, alleging that the school district's failure to classify the student as disabled denied her the right to a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The ALJ concluded that the school district's treatment of the student violated the IDEA and related state special-education laws. The district court then denied the school district's motion for judgment on the administrative record and granted, in part, the student's motion for judgment on the record, modifying the award of compensatory education. The Eighth Circuit held that the district court did not abuse its discretion in denying the school district's request for supplementation of the record; the school district's evaluation of the student was insufficiently informed and legally deficient; the student is eligible for special education and a state-funded FAPE like every other child with a disability; the ALJ and the district court did not err in concluding the school district had breached its obligation to identify the student by the spring of her eighth-grade year as a child eligible for special education; and the district court did not err in finding plaintiffs were entitled to recover the costs associated with comprehensive psychological evaluation, educational evaluation and private educational services. However, the court reinstated the ALJ's award of compensatory education costs. View "Independent School District No. 283 v. E.M.D.H." on Justia Law

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The Eighth Circuit affirmed defendant's conviction of drug trafficking and firearms offenses. The court held that the district court's jury instructions adequately covered the substance of defendant's proposed instruction on "mere presence" and the district court did not abuse its discretion in rejecting defendant's proposed instruction. In this case, defendant's proposed mere presence instruction would have been largely duplicative, and the instructions as a whole already conveyed that the government must prove more than proximity to the gun and drugs in order to convict. View "United States v. Franklin" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit reversed the district court's order affirming the ALJ's denial of plaintiff's application for disability benefits. The court held that the ALJ's error in failing to provide good reason for giving plaintiff's treating psychiatrist's opinion limited weight was not harmless error. In this case, the failure to comply with SSA regulations is more than a drafting issue, it is legal error. Furthermore, the court cannot determine whether the ALJ would have reached the same decision denying benefits, even if the ALJ had followed the proper procedure for considering and explaining the value of the psychiatrist's opinion. Accordingly, the court remanded for further administrative proceedings and for reconsideration of plaintiff's claims. View "Lucus v. Saul" on Justia Law