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

Plaintiff appealed the dismissal of his claims against various Arkansas Department of Corrections staff members for damages stemming from injuries that he received when he was beaten by another inmate. Plaintiff alleged that Defendants failed to protect him from the beating. The district court dismissed Plaintiff’s claim on summary judgment, finding that he had failed to exhaust his administrative remedies even though he remained hospitalized from his injuries until the time for filing expired. At issue is whether the district court erred in dismissing Plaintiff’s complaint for failure to exhaust administrative remedies.   The Eighth Circuit reversed and remanded. The court concluded that the district court’s rant of summary judgment was premature. The court explained that the district court legally erred in declining to decide whether administrative remedies were “unavailable” to Plaintiff. As the Supreme Court stressed in Ross, the PLRA “contains its own textual exception to mandatory exhaustion.” The court explained that under the PLRA, the exhaustion requirement hinges on the ‘availability’ of administrative remedies. The court reversed because the district court declined to decide whether the prison’s grievance procedure was unavailable to Plaintiff. View "John Smith v. Jeremy Andrews" on Justia Law

Plaintiff, for her son A.H., sued Defendant Officer under 42 U.S.C. Section 1983, alleging he used excessive force by not giving a warning while searching with a canine trained to “bite and hold.” Trimble moved for summary judgment. The district court denied qualified immunity on the excessive force claim. Defendant appealed.   The Eighth Circuit affirmed. The court explained that there is no dispute that Defendant did not provide a warning when he deployed Ace or when Ace alerted to fresh human odor during the search. The parties dispute whether A.H. heard the warnings from the other officers. A.H., lying underneath a trailer, testified he did not hear any warnings. The court wrote that assuming the facts most favorably to A.H., he did not hear the other officers’ warnings and did not have the opportunity to surrender. Defendant had fair notice from the court’s precedent that the failure to give a warning and an opportunity to surrender violated clearly established law. View "TonyaMarie Adams v. Nathan Trimble" on Justia Law

Defendant was a passenger in a vehicle that was stopped by law enforcement while speeding in a construction zone. The driver admitted there was marijuana in the car. During the search, the driver tossed a bag to Defendant. The bag contained methamphetamine. Ultimately, the trooper seized both cell phones from the driver and Defendant.Although the phone found in the center console was a “burner” phone without any identifying subscriber information on it, it contained evidence tying Defendant to the phone, including: (1) messages identifying the sender as Defendant; (2) a photograph of Defendant's bank card; and (3) text messages between a sender using the phone and Defendant's sister. At trial, prosecutors planned to call the trooper to authenticate the phone. The district court allowed the trooper's testimony over objection.The Eighth Circuit affirmed, finding that direct evidence that the phone belonged to Defendant is not required and circumstantial evidence may be relied on to support authenticity. View "United States v. Jerry Wise" on Justia Law

Plaintiffs sued police officers under Sec. 1983 after the officers made warrantless entry into their apartment. The district court granted summary judgment to Plaintiffs and Defendants appealed.On appeal, the Eighth Circuit reversed. While warrantless searches are presumptively unreasonable, there is an exception when officers act with probable cause to believe that a crime has been committed and an objectively reasonable basis to believe that exigent circumstances exist.Here, the officers were dispatched to the scene in response to a report of domestic violence. The report received by the officers explained that the 911 call came from a neighbor who thought “abuse” was occurring and heard a “verbal argument,” “someone being thrown around,” and “yelling and screaming” in the upstairs apartment. The neighbor stated that a woman, her boyfriend, and a child lived in the apartment. This created anm exigency, justifying warrantless entry. View "Benedda Cotten v. Ryan Miller" on Justia Law

Defendant was arrested for narcotics and firearms charges. Once in custody, he made several inculpatory statements. However, prior to trial, he fled to Mexico for eight years before being apprehended. The district court denied Defendant's motion to suppress evidence based on a lack of probable cause and, at sentencing, the district court applied an obstruction-of-justice enhancement and rejected his request for an acceptance-of-responsibility reduction.The Eighth Circuit affirmed. The information contained in the affidavit was provided by an informant who had a history of providing reliable information. And, although Defendant pleaded guilty, the court did not err in denying his request for an acceptance-of-responsibility reduction based on Defendant's flight to Mexico. View "United States v. Jose Sandoval" on Justia Law

Law enforcement organized controlled buys using a confidential informant. Initially, Defendant was not the target of the investigation; however, events that transpired during the controlled buys led the MINE Task Force to suspect Defendant and his wife were involved in illegal drug activity, and they became the primary targets of the investigation.Based on information from the controlled buy, law enforcement obtained a warrant to search Defendant's home, ultimately seizing $154,000, firearms, ammunition, marijuana, and handwritten notes apparently detailing narcotics sales.Defendant sought suppression of the physical evidence, arguing that the warrant failed to establish probable caused and that it was based on false information. Defendant's motion cited inconsistencies with the affidavit. The district court rejected Defendnat's arguments, finding that, even if the statement were inaccurate, there was still enough to establish probable cause.The Eighth Circuit affirmed. Although the court agreed that the inaccuracies were concerning, when removed from the analysis, there was still probable cause for the warrant to issue. View "United States v. Nicholas Jones" on Justia Law

Defendant pleaded guilty to a firearms offense. The district court sentenced Defendant to sixty months’ imprisonment. Defendant argued that the district court committed procedural error by miscalculating his base offense level under the sentencing guidelines.   The Eighth Circuit affirmed, concluding that the court did not err. The court concluded that we conclude that Mo. Rev. Stat. Section 575.150.1(1) is divisible into multiple offenses. Therefore, the court applied the modified categorical approach to determine the alternative under which Defendant was convicted. According to the charging document and judgment in Defendant’s Missouri criminal case, he pleaded guilty to resisting arrest “by using or threatening the use of violence or physical force.” Therefore, Defendant’s prior conviction was for a crime of violence under the sentencing guidelines. View "United States v. Johnathan Brown" on Justia Law

The Eighth Circuit reversed the district court’s ruling denying the Deputy’s motion for qualified immunity in Plaintiff’s lawsuit, alleging that the Deputy’s conduct amounted to deliberate indifference to her seizure condition after she was arrested for driving while intoxicated. The Deputy asserted qualified immunity in his motion for summary judgment, which the district court denied.   The Eighth Circuit reversed. The court explained that the Deputy promptly attended to Plaintiff and asked her whether she was hurt or suffered from medical problems. She said no and did not advise him of her seizure disorder. Emergency medical personnel also observed Plaintiff and were content not to take her to the hospital, advising the Deputy that she had refused further treatment. He then took Plaintiff and her medications to jail. Barton I did not provide the Deputy with fair notice that his failure to seek further medical treatment for Plaintiff or to speak with the jailors about what Plaintiff’s boyfriend told him constituted deliberate indifference. Thus, Plaintiff failed to show that clearly established law prohibited the Deputy’s conduct, and the Deputy is entitled to qualified immunity. View "Kelly Martin v. Jordan Turner" on Justia Law

A federal jury convicted Defendant of attempted sex trafficking of a minor after he responded to an advertisement, negotiated a price for sexual relations with a 15-year-old, and traveled almost an hour through a snowstorm to a designated meeting point with items requested by the purported minor. At the end of Defendant’s trial, he moved for a judgment of acquittal, which the district court denied. On appeal, Defendant raised a limited sufficiency-of-the-evidence challenge.   The Eighth Circuit affirmed. The court explained that here, viewing the evidence in the light most favorable to the jury verdict, there is ample support for Defendant’s conviction. The evidence showed that Defendant responded to the undercover officer’s ad and, over five days, repeatedly expressed his desire to have various forms of sexual relations with the person advertised, even after learning and being reminded several times that she was only 15 years old. Defendant then extensively discussed his aversion to using condoms with the 15-year-old and negotiated a price and time to have sex with her. Defendant then drove almost an hour through a snowstorm to meet her at a prearranged meeting location and brought along both $100 in cash and the specific alcohol she requested that he bring to calm her nerves. View "United States v. Eswin Lopez" on Justia Law

Defendant pleaded guilty to being a felon in possession of a firearm. The district court imposed a 96-month sentence followed by three years of supervised release. Defendant served that sentence and began supervised release in October 2018. In February 2020, the district court revoked supervised release based on a domestic violence incident. After serving an additional year in custody, Defendant began a new one-year term of supervised release in January 2021. On April 1, 2021, while serving this second term, Defendant was arrested by Kansas City police officers for possessing a firearm used in a shooting earlier that day. Defendant pleaded guilty to a new felon-in-possession charge. At a combined supervised release revocation and sentencing hearing in August 2022, the district court revoked Defendant’s supervised release and imposed a 24-month sentence for the violations and a consecutive 96-month sentence for his new felon-in-possession conviction. Defendant appealed, arguing “the district court abused its discretion by imposing a substantively unreasonable total sentence of 120 months’ imprisonment.”   The Eighth Circuit affirmed. The court explained that the district court’s focus on Defendant’s criminal history -- including his “aged-out” convictions -- was appropriate considering Defendant’s lengthy violent criminal record, combative behavior when arrested, and the fact that he committed the instant offense while on a second term of supervised release for a prior felon-in-possession conviction. And the court sympathetically acknowledged Defendant’s drug addiction problem, recommending that he participate in the Bureau of Prisons’ Residential Drug Abuse Program so he could better combat his addiction. View "United States v. Bernard Manuel" on Justia Law