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

Police went to arrest Defendant for an incident that happened the day before. Defendant fled first on an ATV and then in a car. Once stopped, Defendant was sent to the hospital to receive medical attention. Meanwhile, officers searched Defendant’s car, finding guns and ammunition. A grand jury indicted Defendant for being a prohibited person in possession of a firearm. Defendant moved to suppress his statements, arguing that his Miranda waiver was invalid. The district court denied the motion. Defendant then moved in limine to exclude testimony that he had or used a gun in connection with the incident that led police to confront him on April 22. The district court granted the motion in part, prohibiting the Government from presenting hearsay testimony about the gun. Defendant also moved in limine to exclude evidence of his second flight from police, which was denied.   The Eighth Circuit affirmed. The court explained that here, the totality of the circumstances suggests that Defendant voluntarily, knowingly, and intelligently waived his rights. He was not intimidated, coerced, or deceived. On the contrary, officers ensured Defendant appreciated the rights he was waiving, told him that it was his decision to talk, and advised him that he could end the interview at any time. The evidence at trial showed that on the day the guns were discovered, police watched Defendant get in a car and drive off. When the pursuit ended, police found two guns in the passenger seat. View "United States v. Patrick Medearis" on Justia Law

Plaintiff sued Missouri prison officials under 42 U.S.C. Section 1983, alleging deprivations of his constitutional rights while incarcerated. The officials moved for summary judgment based on qualified immunity, and the district court denied the motion on two sets of claims. The officials appealed a portion of the order.   The Eighth Circuit reversed. The court explained that even assuming for the sake of analysis that Plaintiff enjoyed a clearly established liberty interest in avoiding assignment to administrative segregation, it was not clearly established that he was entitled to the procedures set forth in Wolff v. McDonnell, 418 U.S. 539. Further, the court explained that a reasonable official could have believed that the procedures applied in Plaintiff’s case were constitutionally sufficient. Informal due process requires only “some notice of the reasons for the inmate’s placement . . . and enough time to prepare adequately for the administrative review.” The procedures applied here meet the informal due process standard. The officials gave Plaintiff adequate notice of the reasons for his placement. The notice informed Plaintiff of his rights and identified the alleged victim, the date of the sexual assault, and the prison rule that he allegedly violated. View "James Spann v. George Lombardi" on Justia Law

Plaintiff filed a Section 1983 lawsuit against several defendants, including agents of the Grand Forks Narcotics Task Force (“GFNTF”). Plaintiff alleged two Fourth Amendment violations: (I) the warrant was based upon deliberate falsehood or reckless disregard for the truth -- the use of the informant to develop and generate false evidence incorporated in an affidavit; and (ii) Defendants deprived Plaintiff of a preliminary hearing at which Plaintiff would have been discharged because the warrant was not supported by probable cause. Plaintiff appealed the grant of summary judgment dismissing these claims.   The Eighth Circuit affirmed. The court agreed with the district court that the affidavit provided probable cause to arrest Plaintiff, even if corrected to include the information Plaintiff alleged was recklessly omitted. The court explained that there is no evidence any of the defendants knew about the false “murder-for-hire” allegations when the warrant affidavit was submitted. An agent does not “violate a clearly established constitutional right by omitting information from a warrant application that he does not actually know, even if the reason is his own reckless investigation.” As Plaintiff’s subsequent, lengthy investigation of the informant makes clear, minimal further investigation into the informant’s criminal history would not have exonerated Plaintiff. View "Henry Howe v. Steven Gilpin" on Justia Law

Defendant moved to suppress evidence from a traffic stop, claiming that the officers unconstitutionally delayed it to conduct a drug-dog search and that the dog’s alert did not provide probable cause to search. The district court denied most of the motion. A jury convicted Defendant for possession of 50 grams or more of methamphetamine with intent to distribute and conspiracy to distribute 500 grams or more of a mixture and substance containing meth. Defendant appealed the denial of the motion to suppress.   The Eighth Circuit affirmed. The court held that the Troopers here had reasonable suspicion before stopping Defendant, which existed throughout the stop. Only 27 minutes passed from the stop until the dog’s alert. This delay did not violate the Fourth Amendment because the Troopers acted diligently to pursue the mission of the stop: to assist with the investigation of Defendant’s drug-related activity. Further, the court held that based on the totality of the circumstances at the scene of the stop, the dog’s alert provided probable cause to search the vehicles. View "United States v. Larry Rederick" on Justia Law

This case started more than fifty years ago when Minnie Liddell sued to desegregate the St. Louis public school system. The NAACP joined the lawsuit, and the State of Missouri (among others) became a defendant. The parties struck a deal that lasted until 1999 when they agreed to end Missouri’s remedial obligations. The Missouri Legislature ratified the parties’ settlement agreement and created a charter-school option. A group of charter schools complained to the Missouri Legislature, which altered the funding formula in 2006. The revised formula, part of Senate Bill 287, is what has led to the current dispute. The St. Louis Public School District and one of the plaintiffs asked the district court to enforce the settlement agreement by having Missouri reimburse it for the special-sales-tax revenue it had lost under the new funding formula. The district court sided with Missouri, and both sides appealed. Plaintiffs continued to believe that the St. Louis Public School District should receive all the special-sales-tax revenue. And Missouri argued that the desegregation-spending condition finds no support in the settlement agreement.   The Eighth Circuit affirmed the district court’s judgment but vacated the part requiring charter schools to spend those funds on “desegregation measures.” The court explained that there has been no “disproportionate adverse financial impact” on the St. Louis Public School District because it never had a right to keep all the special-sales-tax revenue for itself. Moreover, the court rejected the argument that allowing charter schools to spend their money as they see fit is inconsistent with the “purpose” of the settlement agreement. View "Deric Liddell v. State of Missouri" on Justia Law

Defendant was sentenced to 840 months of incarceration following a guilty plea to two counts of producing child pornography (360 months each) and one count of committing an offense while a registered sex offender (mandatory minimum of 120 months). Defendant’s pornography production offense involved the sexual abuse of his ten-year-old nephew and four-year-old niece. In addition to the incarceration, the district court also imposed ten years of supervised release. As a special condition of the supervised release, the district court required that Defendant not contact the victims or the victims’ family without permission from his probation officer. Defendant argued that the district court made three reversible errors during sentencing. Specifically, he asserted that (1) his lengthy sentence is substantively unreasonable; (2) the special condition of supervised release is not narrowly tailored; and (3) the district court failed to make an individualized inquiry when crafting the special condition of supervised release.   The Eighth Circuit affirmed, holding that the district court did not abuse its discretion in either the length of the sentence or in imposing the challenged special condition of supervised release. The court held that the district court considered all the applicable Section 3553(a) factors and committed no clear error of judgment in weighing them. Further, the court found that the district court highlighted the hideousness and destructiveness of Defendant’s crimes. The district court concluded that Defendant “fundamentally violated the trust of these good people and this child, these children.” The court’s statement reflects its individualized inquiry into Defendant’s case and made a sufficient record of the court’s thorough consideration of the circumstances. View "United States v. Andrew Scanlan" on Justia Law

Defendant pleaded guilty to three firearm and controlled-substance offenses. Defendant appealed, arguing that the district court erred in sentencing him as a career offender under United States Sentencing Guidelines Section 4B1.1(a).   The Eighth Circuit affirmed. The court wrote that based on the language and structure of Iowa’s conspiracy statutes, Iowa state court decisions, and Iowa’s model jury instructions, it concludes that Section 706.3(2) is divisible as to the non-forcible felony that serves as the object of a conspiracy. Here, the specific object of Defendant’s Section 706.3(2) conspiracy is not in dispute: the PSR stated that Defendant was convicted of conspiracy to commit the offense of willful injury causing bodily injury, and Defendant does not contend that he conspired to commit a different offense. Further, the court explained that because it “generally interprets the identical ACCA and Guidelines force clauses interchangeably,” willful injury causing bodily injury qualifies as a “crime of violence” under the Guidelines as well. View "United States v. Devon McConnell" on Justia Law

Defendant was charged with thirteen charges related to fraud and tax evasion. Defendant insisted on representing himself, despite the District Court’s thorough colloquy. Ultimately, Defendant was convicted and sentenced to 97 months imprisonment, followed by three years of supervised release.Defendant appealed on several grounds, including insufficiency of the evidence, the district court’s acceptance of his expressed desire to represent himself, evidentiary issues, and sentencing issues. The court rejected Defendant’s appellate issues in turn and affirmed his conviction.However, on the government’s cross-appeal, the court vacated the judgment. The District Court erred in failing to award the government the costs of the prosecution. View "United States v. Jeffrey Kock" on Justia Law

In March 2021, the Camden County Commission voted to ban Plaintiff from county property for one year because he allegedly disrupted and harassed county officials and employees. Plaintiff sued Camden County, the Camden County Commission, and Commissioner (collectively, “Defendants”), claiming that Defendants retaliated against him for exercising his rights under the First Amendment.Defendant sought a preliminary injunction against Defendants and a damages claim against the Commissioner. The District Court granted the preliminary injunction over the Commissioner’s qualified immunity defense, finding that Plaintiff adequately alleged a violation of clearly established rights. However, the court determined Defendants’ appeal of the injunction was moot because it would have expired in March 2022. View "Nathan Rinne v. Camden County" on Justia Law

Plaintiff, a former pretrial detainee in the custody of the Ozark County Sheriff’s Department, filed an action pursuant to 42 U.S.C. Section 1983 claiming that Defendants acted with deliberate indifference to Plaintiff’s serious medical needs by denying him prescription medication. Defendants moved for summary judgment on the basis of qualified immunity. The district court denied the motion.   The Eighth Circuit affirmed. The court explained that Plaintiff has sufficiently demonstrated that Defendants were subjectively aware of but disregarded a serious medical need. The facts construed in the light most favorable to Plaintiff show that the “defendants, who are not medical personnel, substituted their controlled substance ‘policy’ and their schedule for administering or failing to administer medication for that of a treating physician.” Further, Defendants failed to administer or misadministered the medication to Plaintiff despite knowing a doctor prescribed them and despite Plaintiff’s repeated requests for his medication. Construing the facts in the light most favorable to Plaintiff, his “right to adequate treatment was clearly established, and the district court properly denied Defendants qualified immunity. View "Tracy Presson v. Darrin Reed" on Justia Law