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

Defendant and co-Defendant were convicted of conspiracy to distribute methamphetamine and, conspiracy to commit money laundering, and possession of firearms in furtherance of a drug trafficking crime. Co-Defendant was also convicted of illegal re-entry. Defendant challenged the sufficiency of the evidence against her, and co-Defendant contends the district court abused its discretion when it refused to allow witnesses who are Mexican nationals to testify by Zoom and admitted evidence of an unrelated assault with a firearm.   The Eighth Circuit affirmed in part and reversed in part the district court’s denial of Defendant’s motion for judgment of acquittal and vacated her conviction for conspiracy to commit money laundering. The court reversed the district court’s denial of Defendant’s motion for a new trial on the drug trafficking and firearms counts and remanded for proceeding. The court affirmed with respect to co-Defendant. The court explained that it is unable to determine whether the district court abused its discretion by not considering a matter that should have been given significant weight by giving significant weight to something improper or irrelevant or if it committed a clear error of judgment. Therefore, the court remanded to the district court for consideration of Defendant’s motion for a new trial as it relates to the drug trafficking conspiracy and related firearms count. View "United States v. Maria Nava" on Justia Law

Defendant shot a man in the chest and led police on a high-speed chase through a residential neighborhood before his eventual capture. When arrested, he possessed a pistol, ammunition, and bags containing methamphetamine and fentanyl. One of the bags appeared to have been opened using teeth, and officers observed Walker becoming lethargic and losing consciousness. Officers administered two doses of Naloxone to revive him before transporting him to a hospital. Defendant eventually pleaded guilty to possessing a firearm as a previously convicted felon in violation of 18 U.S.C. Section 922(g). The district court determined Defendant was an armed career criminal pursuant to 18 U.S.C. Section 924(e), and also determined his extensive and violent criminal history merited an above-Guidelines-range sentence. The district court ultimately varied from a guideline range of 188–235 months and imposed a sentence of 300 months’ imprisonment and five years’ supervised release.   The Eighth Circuit vacated the sentence imposed in this case and remanded for resentencing. The court explained that the district court’s failure to specifically address the standard conditions of supervised release and the third special condition, which relates to the two special conditions that were orally pronounced, was a matter of mere oversight. As such, the court vacated that portion of the judgment and commitment order imposing the standard conditions of supervised release and the third special condition and remand to the district court for a resentencing, limited to the standard conditions and third special condition. View "United States v. Bradley Walker" on Justia Law

A jury found Defendant guilty of sex trafficking by force, fraud, or coercion, facilitating prostitution, and distributing methylenedioxymethamphetamine (“MDMA”) to a person under twenty-one. Most relevant for this appeal, the government relied on evidence related to the trafficking of A.E., who, at the time, was a college student and under twenty-one. According to the indictment, Defendant trafficked A.E. between approximately February 2 and March 14, 2020. Defendant argued he is entitled to a new trial on two of the three counts because the district court made evidentiary errors and the government deprived him of a fair trial.   The Eighth Circuit affirmed. The court explained that there was no plain error. While Defendant relies on United States v. Johnson, 968 F.2d 768 (8th Cir. 1992), for the proposition that a prosecutor may not urge the jury to convict so as to protect community values or deter other criminal conduct, this is not what occurred here. Rather, the government referenced Defendant’s victims, tracking the evidence presented at trial. And although the government stated someone should end Defendant’s behavior by telling him “no” and “enough is enough,” the context was recounting the evidence presented at trial. Indeed, the government concluded by urging the jury to rely on the evidence. The district court did not plainly err by failing to sua sponte correct the government’s closing argument. View "United States v. Darrius Redd" on Justia Law

Plaintiff sued under 42 U.S.C. Section 1983 on behalf of her son, who died in a vehicle accident while fleeing Defendants, St. Louis County police officers. Plaintiff claimed the officers failed to provide medical aid in violation of the Due Process Clause of the Fourteenth Amendment of the U.S. Constitution, and the officers filed a motion for summary judgment based on qualified immunity. The district court denied the motion, concluding there were genuine disputes of material facts that prevented it from holding the officers were entitled to immunity at this stage of the proceedings.   The Eighth Circuit affirmed. The court explained that Plaintiff does not argue that the officers simply delayed calling for medical assistance. Instead, she argues the officers never called for medical assistance—thus denying medical aid altogether. The court explained that in such cases where no medical aid was provided, there is no need to provide evidence demonstrating the detrimental effect of the lack of aid. The court wrote that because the officers failed to render any aid, rather than simply delaying in providing it, precedent does not require Plaintiff to demonstrate the detrimental effect of the lack of aid. Thus, we agree with the district court that, viewed in the light most favorable to Plaintiff, she has shown a clearly established constitutional violation. View "Clara Cheeks v. Mark Jakob" on Justia Law

Appellant was civilly committed pursuant to 18 U.S.C. Section 4246 in February 2009 due to a mental disease or defect that created a substantial risk of harm to the public. After several conditional releases and revocations, in April 2022, and while represented by counsel, Appellant filed a motion for discharge pro se, which the district court denied on the basis that a motion for discharge may not be filed by a pro se petitioner. Appellant appealed, asserting that prohibiting him from seeking a discharge pro se is a violation of his Fifth Amendment due process rights.The Eighth Circuit affirmed. The court explained that Section 4247(h) provides the process by which a civilly committed person may seek a discharge. The provision plainly permits only counsel or the legal guardian of the committed person to file a motion to discharge Accordingly, it follows that a committed person may not file such a motion pro se. The court explained that Appellant asserts that this amounts to a denial of access to the courts. The court wrote that it has previously addressed the Sixth Amendment right of self-representation in the context of civil commitment, concluding that this right does not apply to civil commitment proceedings. Further, the court explained that even assuming that the right of self-representation applies to a Fifth Amendment access-to-the-courts claim, Appellant’s claim would still fail because he cannot show the requisite prejudice. View "United States v. Luis Vazques" on Justia Law

EEE Minerals, LLC, and a Trustee for The Vohs Family Revocable Living Trust, sued the State of North Dakota, the Board of University and School Lands, and the Board’s commissioner in a dispute over mineral interests in McKenzie County, North Dakota. Plaintiffs alleged that state law related to mineral ownership was preempted by federal law and that the defendants had engaged in an unconstitutional taking of the plaintiffs’ mineral interests. Plaintiffs sought damages, an injunction, and declaratory relief. The district court dismissed the action.   The Eighth Circuit affirmed. Plaintiffs contend that the Flood Control Act impliedly preempts the North Dakota statute because the state law “stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress.” The court explained that it is not convinced that the State’s determination of a high-water mark, and the attendant settling of property rights under state law, stands as an obstacle to accomplishing the objectives of the Flood Control Act. The court wrote that the interests of the United States and the goals of the Flood Control Act are unaffected by a dispute between the State and a private party over mineral rights that were not acquired by the federal government.   Further, the court explained that Plaintiffs have not established that the United States will be prevented from flooding or inundating any land covered by the 1957 deed in which the State claims ownership of mineral interests under state law. The Flood Control Act would not dictate that property rights be assigned to Plaintiffs. View "EEE Minerals, LLC v. State of North Dakota" on Justia Law

A jury found Sherman and Smith guilty of conspiracy to commit witness tampering resulting in death. The jury also found Smith guilty of witness tampering, resulting in death, conspiracy to possess with intent to distribute methamphetamine, and aiding and abetting the use of a firearm in relation to a drug-trafficking crime.  The district court denied Defendants’ motions for judgment of acquittal on those counts and sentenced both men to life imprisonment.   The Eighth Circuit affirmed. First, the court considered whether the district court erred in denying Sherman’s repeated requests to be tried separately from Smith. The court explained that it was convinced that the district court’s repeated limiting instructions sufficiently cured whatever risk of prejudice existed. Accordingly, the district court did not abuse its discretion in denying the motions to sever.   Further, the court explained that Sherman and Smith argue that the Government failed to establish a nexus between their conduct and an official proceeding. However, the court held that sufficient evidence demonstrates a nexus between the murder and the upcoming revocation hearing, as well as a potential future federal prosecution for distributing drugs.   Moreover, Smith claimed that the evidence was insufficient to support his conviction for conspiracy to possess with intent to distribute methamphetamine and the related firearms charge. The court explained that because Smith’s challenge to his conviction on the firearms offense rests entirely on his argument that the evidence was not sufficient to prove a drug-distribution conspiracy, the court found the evidence sufficient to prove Smith’s guilt on the firearms offense as well. View "United States v. Samuel Sherman" on Justia Law

The BIA denied Petitioner’s request for cancellation of removal based on the failure to show “exceptional and extremely unusual hardship” to his United States-citizen children. The BIA granted voluntary departure to Mexico. Petitioner then discovered evidence of substandard attorney performance by his attorney before the IJ and filed a timely motion to reopen, alleging ineffective assistance of counsel. Petitioner also submitted evidence obtained between the final order and the motion to reopen, asserting that two of his children suffered from emotional- and mental-health issues that could not be adequately addressed in Mexico. The BIA denied the motion to reopen, holding that even if counsel had been unprepared before the IJ, different counsel represented Petitioner in the initial appeal to the BIA.   The Eighth Circuit affirmed. The court found no abuse of discretion. The court explained that here, considering all of the evidence presented, the BIA rationally determined that the addition of the later-submitted evidence of emotional- and mental health issues failed to establish exceptional and extremely unusual hardship. The evidence demonstrated neither that the health issues were severe nor that treatment would be unavailable in Mexico. The BIA also rationally determined there had been no showing of prejudice associated with the claim of attorney ineffectiveness. Further, on appeal, Petitioner failed to articulate how the initial counsel’s failures affected the outcome. View "Ignacio Trejo-Gamez v. Merrick B. Garland" on Justia Law

The City of Belle Plaine, Minnesota, designated Veterans Memorial Park as a limited public forum and granted permits to two groups to place monuments there. Before the Satanic Temple could place its monument, the City closed the Park as a limited public forum and terminated both permits. The Satanic Temple sued the City. The district court dismissed its claims, except for promissory estoppel. When the Satanic Temple moved to amend its complaint, a Magistrate Judg2denied its motion. The Satanic Temple filed a second suit, reasserting the dismissed claims and adding new ones. The district court held that res judicata bars the second suit and granted summary judgment to the City on the promissory estoppel claim from the first suit.   The Eighth Circuit affirmed. The court explained that the Satanic Temple failed to plausibly allege that closing the Park as a limited public forum was unreasonable or viewpoint discriminatory. The court further explained that the Satanic Temple asserted that the City violated its free exercise rights. The court explained that although the Enacting and Recession Resolutions were facially neutral, facial neutrality is not a safe harbor if the City’s actions targeted the Satanic Temple’s religious conduct. However, the Satanic Temple failed to plausibly claim that its display was targeted. Moreover, the Satanic Temple has not plausibly alleged that it and the Veterans Club were similarly situated or that it was treated differently. The City gave a permit to both groups, had no control over the fact that the Veterans Club placed its statue first, and closed the Park as a limited public forum to everyone. View "The Satanic Temple v. City of Belle Plaine" on Justia Law

Defendant sexually abused C.M. and E.A.H. in his mother’s basement on separate occasions. L.M., the legal guardian of C.M. and E.A.H. and sister of Defendant’s mother, often brought the two children to the house for visits. At trial, the jury heard testimony from C.M., E.A.H., L.M., and a forensic examiner. The Government introduced evidence of Defendant’s prior conviction of abusive sexual contact of a person incapable of consent. Defendant moved for judgment of acquittal, which the district court denied, and was convicted of two counts of aggravated sexual abuse of a child and one count of witness tampering. The district court sentenced him to life in prison for each sexual abuse count and 20 years for witness tampering, running concurrently. On appeal, Defendant alleged insufficient evidence to support the verdict, improper joinder of charges, improper introduction of evidence of his prior conviction, and procedural and substantive sentencing errors.   The Eighth Circuit affirmed. The court explained that Defendant argued that because the sexual abuses of C.M. and E.A.H. involved different methods of penetration, victims of different ages, and different occurrences, the charges were improperly joined. However, the court explained that the victims do not have to be the same age. Further, the court wrote that joinder was proper because the offenses were of a similar character. “In applying the same or similar character standard, we have found joinder of offenses to be proper when the two counts refer to the same type of offenses occurring over a relatively short period of time, and the evidence as to each count overlaps.” View "United States v. Jerome Goodhouse, Jr." on Justia Law