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

The Eighth Circuit held that the evidence was sufficient to convict defendant of possession with intent to distribute marijuana, possessing a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm. The court also held that the district court did not abuse its discretion in denying defendant's motion for a new trial where the government's closing argument was permissible under Federal Rule of Evidence 404(b); there was no error in admitting forensic testimony by the government's experts because their testimony on the absence of DNA and fingerprints on the firearms and ammunition was relevant and helpful to the jury; and there was no error in admitting a photo of defendant in handcuffs where the district court gave a cautionary instruction.The court further held that the district court did not err by sentencing defendant as a career offender under USSG 4B1.1(a); by imposing an enhancement under USSG 2D1.1(b)(12) for maintaining a drug premises; and by imposing an enhancement under USSG 3B1.1 for leadership role in the offense. Accordingly, the court affirmed defendant's conviction and sentence. View "United States v. Jefferson" on Justia Law

The Bankruptcy Court denied the State's claim filed on behalf of unnamed charities for lack of standing, and denied the State's claim on behalf of Team Makers on the equitable doctrine of laches.The Bankruptcy Appellate Panel (BAP) held that the State failed to show the requisite injury to a substantial segment of North Dakota's population, and affirmed its ruling that the State did not have parens patriae standing to file a claim on behalf of Team Makers and other charities. While the panel agreed with the Bankruptcy Court that finality is a very important interest, particularly in a case of this duration, the panel held that laches does not apply to tardily-filed claims that are filed in time to permit distribution under Section 726(a) of the Bankruptcy Code. Accordingly, the panel affirmed in part, reversed in part, and remanded for reconsideration. View "North Dakota v. Bala" on Justia Law

After Primerica filed an interpleader action under Federal Rule of Civil Procedure 22 in order to resolve competing claims to Garvin Reid's life insurance proceeds, the district court awarded summary judgment and the insurance proceeds to Ila Reid, Garvin's widow. However, the district court granted summary judgment in favor of Primerica on Ila's counterclaim against Primerica for breach of contract stemming from the disputed life insurance policy.The Eighth Circuit held that there is a legitimate dispute over the question of fault in creating the competing claims to Garvin's life insurance proceeds, and circuit precedent has not previously required a fault determination in the interpleader context. In this case, there is an active dispute on appeal regarding whether the competing claims to Garvin's insurance proceeds arose because of Primerica's failure to process the 2002 Multipurpose Change Form or because of Garvin's failure to respond when Primerica sought more information in 2002. Accordingly, the court remanded for a fault determination by the district court and further proceedings. View "Primerica Life Insurance Co. v. Reid" on Justia Law

The Eighth Circuit affirmed defendant's revocation sentence, holding that defendant's sentence was not substantively unreasonable. In explaining the revocation sentence it was imposing, the district court discussed defendant's history and characteristics, observing that his criminal history was "replete with violence and assaultive behavior," and assaultive incidents illustrated defendant's "impulsive and violent behavior." The district court also took into account and considered all the 18 U.S.C. 3553(a) factors that apply in a revocation hearing, directly responding to the "disrespect" complaint in defendant's allocution. Therefore, the district court neither gave significant weight to an improper or irrelevant factor nor abused its substantial discretion by imposing a substantively unreasonable sentence. View "United States v. Porter" on Justia Law

This case arose from a Ponzi scheme perpetrated by Thomas Petters from 1994 to 2008 through his company, PCI. These appeals involve the Trustee’s separate claw back claims against defendants. The Trustee asserted claims under 11 U.S.C. 544(b)(1), which permits a trustee to "avoid any transfer of an interest of the debtor . . . that is voidable under applicable law by a creditor holding an unsecured claim." In this case, the applicable law is the Minnesota Uniform Fraudulent Transfers Act (MUFTA).The Eighth Circuit held that the district court erred in applying the Supreme Court of Minnesota's controlling MUFTA decision in Finn v. Alliance Bank, 860 N.W.2d 638 (Minn. 2015), and the Minnesota law of void contracts. Therefore, the court reversed summary judgment against Papadimos and Kanios. The court also reversed and remanded in the Boosalis case because the district erred in instructing the jury on the MUFTA elements of "good faith" and "reasonably equivalent value." In both cases, the court held that the district court erred in concluding that Minnesota rather than federal law governed the award of prejudgment interest. The court rejected defendants' other arguments. View "Kelley v. Boosalis" on Justia Law

The Eighth Circuit vacated defendant's sentence and remanded for resentencing before a different judge. Defendant alleged that, absent the district court's advice, he likely would have accepted the government's offer and received a lighter sentence. The government concedes that the district court plainly crossed the line as soon as it suggested, with a plea deal still on the table, that defendant could do better if he went to trial.The court held that there is a reasonable probability that defendant would have pleaded guilty but for the district judge's comments at the plea proceedings. In light of the circumstances, the court determined that the remedy that best balances the competing objectives is vacating defendant's sentence and remanding for resentencing before a different judge. View "United States v. Harrison" on Justia Law

The Eighth Circuit affirmed defendant's sentence as an armed career criminal after he pleaded guilty to being a felon in possession of a firearm. The court held that the district court was entitled to treat the fact that defendant was convicted of the 1997 robbery offense as established where the government failed to produce the charging document. In this case, defendant did not object to the PSR's recitation that he was, in fact, convicted of the 1997 robbery offense.The court has held that a charging document can provide sufficient evidence to support a finding that the defendant was necessarily convicted of a violent felony offense, but no case has held that the government must produce the charging document to establish the fact of conviction. The court also held that precedent establishes that defendant's 1997 Missouri first degree robbery conviction categorically qualified as a violent felony under the Armed Career Criminal Act's elements clause. Therefore, the district court did not err in sentencing defendant as an armed career criminal. View "United States v. Witherspoon" on Justia Law

The Eighth Circuit affirmed defendant's conviction of conspiracy to violate federal health care laws, as well as eleven substantive counts of health care fraud. The court held that the evidence was sufficient to support the verdict where defendant voluntarily and intentionally participated in a conspiracy with knowledge that it was unjustifiable and wrongful to receive kickbacks and defraud Medicare. In this case, viewed in the light most favorable to the government, the evidence of significant experience with federal health care program reimbursements, his attestation that he would comply with federal anti-kickback laws, and his collection of specimens without a doctor's orders, is collectively enough evidence to support a conclusion that he knew the arrangement with AMS was unjustifiable and wrongful when he voluntarily joined the conspiracy. View "United States v. Goodwin" on Justia Law

The Eighth Circuit affirmed the district court's reduction of defendant's sentence to 277 months' imprisonment under the First Step Act. The court held that defendant's suggestion that the district court did not understand its First Step Act discretion is without merit where the district court expressly recognized and exercised its discretion to reduce his sentence. Furthermore, nothing in the record suggests that the district court did not understand the scope of its discretion under the First Step Act. In determining the extent of the reduction, the district court placed emphasis on a proportional reduction based on defendant's advisory range under the current guidelines. Thus, the district court had a reasoned basis for its decision and did not abuse its substantial discretion.The court rejected defendant's contention that the district court's summary procedure violated the "complete review" provision of Section 404(c) of the First Step Act and deprived defendant of Due Process. The court explained that defendant had notice of the district court's proposed action and an opportunity to respond before the district court issued an order adequately explaining the basis for its decision. There was no constitutional procedural obligation to do more. View "United States v. Booker" on Justia Law

The Eighth Circuit held that the district court did not abuse its discretion in denying defendant relief under the First Step Act. The court rejected defendant's contention that the district court violated his right to a complete review and held that the district court's conclusion that defendant's initial sentence was sufficient but not greater than necessary to address the essential sentencing considerations was sufficient to satisfy the court that the district court had considered the parties' arguments and had a reasoned basis for exercising its own decisionmaking authority. Finally, the court held that Section 404 of the First Step Act does not require district courts to analyze the 18 U.S.C. 3553(a) factors in making their decisions. In this case, there was no abuse of the district court's substantial sentencing discretion in denying defendant relief under the First Step Act. View "United States v. Hoskins" on Justia Law