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

Defendant entered a conditional plea of guilty to one count of being a felon in possession of ammunition. Defendant reserved his right to appeal the district court’s denial of his motion to suppress and subsequently appealed. Defendant argued the district court erred in denying his motion to suppress because he was unlawfully arrested in his home, and the attenuation doctrine does not apply to render the evidence that was seized during a subsequent search admissible against him.   The Eighth Circuit affirmed. The court concluded that under the circumstances, it cannot say the district court committed a clear error in finding that Defendant’s consent to search was voluntary. The court expressly considered the relevant factors for assessing voluntariness before reaching its conclusion, including those weighing against a finding of voluntary consent. Further, the court wrote that weighing the appropriate factors, it concluded that Defendant’s voluntary consent to the search of his residence was sufficient to purge the taint of the officers’ initial unlawful conduct. The district court did not err in denying Defendant’s motion to suppress evidence obtained from the December 14, 2019, search. View "United States v. Gary Harris" on Justia Law

Plaintiffs sued various officials of the State of Arkansas, alleging that these officials (collectively, “ADHS defendants”) violated their due process rights under the Fourteenth Amendment. The officials moved to dismiss the complaint with prejudice. The district court denied the motion. On appeal, the ADHS Defendants argued that the Eleventh Amendment bars suits by individuals brought against a state or its agencies or departments, regardless of the relief sought.   The Eighth Circuit affirmed. The court explained that Plaintiffs’ ARChoices benefits must be reassessed each year and, according to Plaintiffs’ allegations, “ADHS has no plans to switch to a different assessment tool, allocation methodology, or notice of action than those now used.” The very harm alleged remains likely to recur barring a change in the state’s operation of the program or judicial intervention. Under these circumstances, the court concluded that sovereign immunity does not bar this suit.   Further, the court concluded that beneficiaries have a clearly established right to be provided adequate notice of reduction, loss, or termination of benefits. No fundamental difference exists between this case and Jacobs: in both cases, beneficiaries suffered a loss of benefits under ARChoices. Thus, Plaintiffs have sufficiently pleaded that ADHS violated their right to notice. Finally, the court held that Plaintiffs have also alleged involvement by each ADHS defendant in creating, applying, or interpreting this policy. Thus, Plaintiffs have adequately alleged facts to survive a dismissal motion raising the defense. View "Ginger Elder v. Cindy Gillespie" on Justia Law

Defendant entered a conditional guilty plea to narcotics and ammunition charges after the trail court denied his motion to suppress GPS locational data and subsequent post0-Miranda statements made to detectivews. Law enforcement, working with a confidential informant (CI), installed a GPS tracker on the CI's vehicle. Subsequently, Defendant borrowed CI's vehicle, which led to his arrest.The Eighth Circuit held that the district court did not err in denying Defendant's motion to suppress. Defendant did not have a reasonable expectation of privacy in his location and movements in a borrowed vehicle. View "United States v. Joshua Dewilfond" on Justia Law

Defendant served a 48-month sentence for use of interstate facilities to promote prostitution and began a three-year term of supervised release in October 2020. The district court first revoked supervised release on August 31, 2021, when Defendant admitted drug use and failure to participate in required drug counseling; Defendant began a 24-month term of supervised release that day.   His probation officer petitioned the court to issue a warrant, alleging numerous violations of supervised release. At the conclusion of a revocation hearing, the court found that Defendant committed the violations, revoked supervised release, and sentenced Defendant to 10 months’ imprisonment followed by 24 months of supervised release. Defendant appealed the revocation sentence, arguing the court violated his due process right to confront witnesses at the revocation hearing and imposed additional special conditions of supervised release that are substantively unreasonable.   The Eighth Circuit affirmed. The court explained that the facts recited in the warrant petition with the author present to testify, and Defendant’s testimony corroborating some of the alleged Grade C violations, including admissions he had not complied with sex offender registration requirements and had tested positive for cocaine use, were ample evidence supporting the district court’s decision to revoke supervised release. Further, the court found that the district court did not abuse its substantial discretion when it imposed additional conditions addressing what the court described as Defendant’s “high-risk behavior” and “continued disregard for the conditions imposed.” View "United States v. La'Ron Clower" on Justia Law

The Anoka County Jail referred every detainee born outside the United States, including Plaintiff, to Immigration and Customs Enforcement. The district court determined that this policy violates the Equal Protection Clause, and a jury awarded her $30,000 on a false-imprisonment theory.   The Eighth Circuit affirmed. The court explained that the district court’s conclusion was correct: Anoka County’s policy is a classic example of national-origin discrimination. On its face, it treats people differently depending on where they were born. Those born abroad must wait anywhere from 20 minutes to 6 hours longer while deputies consult ICE. For those born in the United States, by contrast, there is no call and release is immediate. The court explained that it is also significant that Anoka County had national-origin-neutral alternatives at its disposal. The failure to consider these alternatives provides further evidence that it did not adopt a narrowly tailored policy. View "Myriam Parada v. Anoka County" on Justia Law

Defendant was arrested in connection to a narcoticcs trafficking operation after police pulled over the vehicle he was riding in as a passenger. The driver consented to a search, during which offers found heroin. Officers seized Defendant's phone and obtained a warrant on the basis that Defendant was a drug dealer.The district court denied Defendant's motion to suppress the contents of his phone under the Wiretap Act, as well as his statements to police. The court later denied his motions for a directed verdict and new trial. Defendant appealed the denial of his motions as well as his sentence.The Eighth Circuit affirmed. Regarding the motion to suppress, officers had probable cause to approach the car based on the evidence in the officers' possession. The Eighth Circuit also found that the district court did not abuse its discretion in denying Defendant's motion for a directed verdict and motion for a new trial.Finally, the Eighth Circuit found that the district court reviewed all the evidence that Defendant presented to the court and did not err in weighing the evidence differently than Defendant would have preferred. View "United States v. Eric Griggs" on Justia Law

Defendant entered a conditional guilty plea to being a felon in possession of a firearm, preserving his right to appeal the district court's denial of his motion to suppress. The Eighth Circuit affirmed Defendant's conviction, finding that the traffic stop that led to the discovery of the challenged evidence was supported by reasonable suspicion. The police officer's decision to pull Defendant over after learning that he was driving a vehicle that had been reported stolen was sufficient to at least give rise to reasonable suspicion. View "United States v. Patrick James" on Justia Law

Several dog owners sued the City of Council Bluffs challenging the constitutionality of an ordinance prohibiting “pit bulls" under 42 Sec. 1983. The trial court granted the City's motion for summary judgment, finding that the ordinance had the "required rational relationship to the health, safety, and public welfare interests of the city to survive rational basis review." The dog owners appealed the trial court's ruling pertaining to their equal protection and substantive due process claims.The Eighth Circuit affirmed. The court first noted that the parties agreed that rational-basis review was appropriate. However, the dog owners claimed that their evidence "negates every conceivable basis for the Ordinance’s rational relationship," presenting expert testimony that showed, among other things, pitbulls were not any more dangerous than other breeds of dogs that were permitted under the ordinance. ultimately, the court concluded that the City had a conceivable basis to believe banning pit bulls would promote the health and safety of Council Bluff citizens. View "Rachael Danker v. The City of Council Bluffs" on Justia Law

A jury found Defendant guilty of sex trafficking of a minor. Defendant raised several issues on appeal. First, he argues that the district court violated his Sixth Amendment right to self-representation by denying his requests to proceed pro se. Second, he contends that the evidence at trial was insufficient to sustain his conviction. Third, he argues that the district court admitted unfairly prejudicial evidence. Finally, he submits that two of the special conditions of supervised release imposed by the district court are impermissibly vague and overbroad.   The Eighth Circuit affirmed but remand for clarification of the two special conditions. In regards to the special conditions the court explained that although a sentencing judge has “broad discretion” when imposing terms of supervised release, we have said that a special condition of supervised release is unconstitutionally vague when it “fails to convey sufficiently definite warning as to the proscribed conduct . . . when measured by common understanding and practices.” The court held that Defendant is correct that the two special conditions are unconstitutionally vague and overbroad, respectively. The court remanded for the narrow purpose of amending the written judgment as it relates to Special Conditions 2 and 3. View "United States v. Anthony Atkins" on Justia Law

Plaintiff attended protests in downtown St. Louis. While she was leaving, an armored St. Louis Metropolitan Police Department (“SLMPD”) vehicle fired tear gas in her direction. Plaintiff sued the City of St. Louis, 12 police officers who were members of the SWAT team on duty that night, and several SLMPD officials for constitutional and state law violations. The district court denied a motion to dismiss based on qualified immunity for four Defendant officers specifically alleged to have been in the armored vehicle at the time of the incident. As to eight Defendant officers not specifically alleged to have been in the vehicle, the district court denied the motion to dismiss on the grounds that additional discovery was needed.   The Eighth Circuit reversed the denial of qualified immunity as to the eight Defendant officers for whom specific allegations were not made. The court affirmed as to the four defendant officers for whom specific allegations were made. The court explained that Plaintiff’s allegation, and the district court’s finding, that Plaintiff was not committing a crime when she was tear-gassed is enough to plausibly allege the tear-gassing was in retaliation for the First Amendment activity.  Further, the complaint did not plausibly allege that the eight officers were personally involved in the violation of clearly established constitutional rights. Accordingly, the court reversed the district court’s denial of the Officers’ motion to dismiss. View "Megan Green v. Cliff Sommer" on Justia Law