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

Ashley Chacon pled guilty to possession with intent to distribute 50 grams or more of methamphetamine. Emiliano Nava Munoz and Valentin Nava Munoz pled guilty to conspiracy to distribute and distribution of 50 grams or more of methamphetamine. The district court sentenced Chacon to 60 months, Emiliano to 280 months, and Valentin to 180 months in prison. They appealed their sentences.The United States District Court for the Southern District of Iowa denied Chacon's motion to suppress evidence from a car search. Chacon argued that the traffic stop was impermissibly extended and that the drug-detection dog's contact with the car was an unlawful trespass. The district court found that the stop was not prolonged beyond the time reasonably required to complete the original purpose of the stop and that the dog's contact with the car did not violate the Fourth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the officer's questions during the traffic stop were ordinary inquiries and that the stop was not impermissibly extended. The court also held that the drug-detection dog's contact with the car did not violate the Fourth Amendment because the dog acted instinctively. The court affirmed the district court's denial of Chacon's motion to suppress.Emiliano challenged the enhancements to his sentence for maintaining drug premises and for his role as a manager or supervisor. The court found that Emiliano used his residence and another property for substantial drug-trafficking activities and that he had control over the premises. The court also found that Emiliano was a manager or supervisor of the criminal activity. Valentin challenged his role enhancement, but the court found that he directed transactions and recruited others into the offense. The court affirmed the sentences for Emiliano and Valentin. The judgments were affirmed. View "United States v. Munoz" on Justia Law

Armando Angel Cheshier was convicted of distributing a controlled substance resulting in serious bodily injury and possession of a controlled substance with intent to distribute. He was sentenced to 252 months for the first count and 240 months for the second and third counts, to run concurrently. Cheshier appealed his conviction, arguing that the district court erred in rejecting his guilty plea and in instructing the jury on intentional distribution of a controlled substance.The United States District Court for the District of South Dakota rejected Cheshier's guilty plea because he explicitly denied distributing fentanyl to the victim during the plea hearing. Cheshier also challenged the jury instructions, but the district court found that the instructions accurately reflected the law, including the requirement that the government prove he knowingly or intentionally distributed the controlled substance.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not plainly err in rejecting Cheshier's guilty plea, as he denied the factual basis for the plea. The appellate court also found that the district court did not abuse its discretion in instructing the jury, as the instructions were a correct statement of the law. Additionally, the court determined that there was sufficient evidence for a reasonable jury to conclude that Cheshier knowingly or intentionally distributed fentanyl to the victim and that the victim's death resulted from the fentanyl.The Eighth Circuit affirmed the judgment of the district court, upholding Cheshier's conviction and sentence. View "United States v. Cheshier" on Justia Law

Quincy Martez Chambers was convicted by a jury for possession of ammunition by a felon, violating 18 U.S.C. §§ 922(g)(1) and 924(e). The incident involved the shooting of Nairobi Anderson, the mother of Chambers's child, by a masked man. Anderson was shot in the chest and struck in the head. Chambers was sentenced to 360 months in prison by the district court, which found the object of his offense to be first-degree murder, applying relevant sentencing enhancements.The United States District Court for the Eastern District of Arkansas sentenced Chambers, applying a base offense level of 33, with additional enhancements for Anderson's injuries and obstruction of justice. Chambers was also classified as an Armed Career Criminal under 18 U.S.C. § 924(e), leading to a statutory range of 15 years to life imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Chambers challenged the sufficiency of the evidence, the admission of certain evidence, and the application of sentencing enhancements. The appellate court found sufficient evidence to support the jury's verdict, including Anderson's initial identifications and other corroborating evidence. The court also upheld the admission of text messages and video stills as relevant to Anderson's credibility and motive for recanting her identification. The court found no plain error in their admission.The appellate court affirmed the district court's application of the cross-reference to attempted first-degree murder, the enhancements for the severity of Anderson's injuries, and obstruction of justice. The court also upheld Chambers's classification as an Armed Career Criminal, finding his nolo contendere plea to domestic battery constituted a violent felony under the ACCA. The judgment of the district court was affirmed. View "United States v. Chambers" on Justia Law

Jose Rolando Gonzalez entered a conditional guilty plea to one count of conspiracy to distribute a controlled substance, reserving the right to appeal the district court's denial of his motion to suppress evidence. On September 25, 2022, two separate calls were made to law enforcement reporting a black car driving erratically on I-29. South Dakota State Trooper Chris Spielmann and Trooper Mitchell Lang, along with Brookings Police Officer Seth Bonnema, located the car at a gas station. Gonzalez and his passenger, Marquez Gonzalez, were questioned, and their inconsistent and suspicious responses led Officer Bonnema to use a K-9 unit, which indicated the presence of drugs. A search revealed methamphetamine, cash, drug paraphernalia, and cell phones.The United States District Court for the District of South Dakota denied Gonzalez's motion to suppress the evidence, finding that the officers had reasonable suspicion to stop and search the vehicle. Gonzalez appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court applied a mixed standard of review, examining factual findings for clear error and legal conclusions de novo. The court held that the officers had reasonable suspicion for the Terry stop based on the consistent reports of erratic driving, the car's location, and the corroboration of details such as the car's color and behavior. The court also found that the officers did not unlawfully prolong the stop, as Gonzalez's responses and the circumstances provided reasonable suspicion to expand the scope of the stop. The court affirmed the district court's denial of the motion to suppress. View "United States v. Gonzalez" on Justia Law

Joseph Thompson, Sr. was convicted by a jury of voluntary manslaughter under 18 U.S.C. §§ 1153 and 1112. The incident occurred when Thompson was visiting Charmayne Grooms at her home in Lower Brule, South Dakota. Marty LaRoche, the father of Grooms's children, attempted to enter the home through a window, leading to a confrontation outside between Thompson and LaRoche. LaRoche was found with multiple stab wounds and later died from his injuries. Thompson claimed self-defense, stating LaRoche tried to fight him.The United States District Court for the District of South Dakota denied Thompson's motion for judgment of acquittal and his request for a self-defense jury instruction based on South Dakota law. Instead, the court used the federal self-defense instruction. The jury found Thompson guilty of voluntary manslaughter, a lesser-included offense of the original second-degree murder charge.The United States Court of Appeals for the Eighth Circuit reviewed the case. Thompson argued that the district court erred in not using the South Dakota self-defense instruction and that there was insufficient evidence to support the jury's verdict. The Eighth Circuit held that the district court did not abuse its discretion in using the federal self-defense instruction, noting that federal law, not state law, governs self-defense claims in federal criminal trials. The court also found that sufficient evidence supported the jury's verdict, as Thompson left the safety of the home to confront LaRoche and inflicted multiple stab wounds, including fatal injuries.The Eighth Circuit affirmed the district court's judgment, upholding Thompson's conviction and sentence of 128 months' imprisonment. View "United States v. Thompson" on Justia Law

Muhammad Masood, a licensed physician from Pakistan, came to the United States in 2018 on a non-immigrant visa to work as an unpaid medical researcher. In 2019, he became radicalized by Islamic extremist content and planned to join ISIS. In March 2020, he was arrested at the Minneapolis airport with plans to travel to ISIS-controlled territory. A search revealed military and medical supplies, computers, and digital storage devices containing extremist propaganda. Masood pleaded guilty to attempting to provide material support to a designated foreign terrorist organization.The United States District Court for the District of Minnesota adopted the Presentence Investigation Report (PSR) and sentenced Masood to 216 months imprisonment, varying downward from the statutory maximum of 240 months. Masood appealed, arguing procedural errors in applying the terrorism enhancement, considering the 18 U.S.C. § 3553(a) sentencing factors, and alleged violations of his due process rights and right to allocution.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no procedural error in applying the terrorism enhancement, as the evidence supported that Masood's offense was intended to promote terrorism. The court also found that the district court adequately considered the § 3553(a) factors and provided a sufficient explanation for the sentence. Additionally, the court determined there was no violation of Rule 32(i) or the Due Process Clause, as Masood and his counsel were given opportunities to argue and allocute before the final sentence was imposed. The Eighth Circuit affirmed the district court's judgment. View "United States v. Masood" on Justia Law

Anthony Red Elk was convicted by a jury on one count of aggravated sexual abuse of a minor and two counts of sexual abuse. The charges were based on allegations by his niece, C.T.B., that Red Elk raped her once when she was under twelve and again on two occasions when she was nineteen and twenty. Additionally, the government introduced testimony from K.W., who alleged that Red Elk attempted to sexually assault her in 2007 when she was sixteen.The United States District Court for the District of South Dakota admitted K.W.'s testimony under Federal Rule of Evidence 413, which allows evidence of prior sexual assaults to show a defendant's propensity to commit such offenses. The court also applied two sentencing enhancements: a four-level enhancement for use of force on Counts 2 and 3, and a five-level enhancement for being a repeat and dangerous sex offender against minors, resulting in a total offense level of 46, reduced to the Sentencing Guidelines' maximum of 43. Red Elk was sentenced to life imprisonment on each count, to run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting K.W.'s testimony, finding it relevant and not unduly prejudicial under Rule 403. The court also upheld the application of the repeat and dangerous sex offender enhancement, finding that K.W.'s testimony established by a preponderance of the evidence that Red Elk attempted aggravated sexual abuse. Finally, the court found that any error in applying the use of force enhancement was harmless, as it did not affect the total offense level. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Elk" on Justia Law

Robert Carl Sharp was released from federal prison in 2012 and later sold herbal incense products containing a synthetic cannabinoid, AB-FUBINACA, while on supervised release. He was arrested in 2014 for violating his supervised release terms. During a proffer interview, Sharp, represented by attorney Joel Schwartz, admitted to selling synthetic cannabinoids to several individuals. In 2015, Sharp was indicted for conspiracy to manufacture and distribute a controlled substance and possession with intent to distribute. He pleaded guilty without a plea agreement but later sought to withdraw his plea, claiming Schwartz had a conflict of interest due to previous representation of potential witnesses.The United States District Court for the Northern District of Iowa denied Sharp's motion to withdraw his guilty plea, finding Schwartz credible and Sharp not credible. Sharp was sentenced to 360 months' imprisonment. On appeal, the Eighth Circuit affirmed his conviction, concluding that Sharp had not shown that proceeding to trial would have been objectively reasonable or that Schwartz's advice to plead guilty was linked to an actual conflict of interest.Sharp then filed a 28 U.S.C. § 2255 motion, claiming ineffective assistance of counsel due to Schwartz's alleged conflict of interest from previous representation of other individuals involved in the case. The district court denied the motion, determining that Sharp had not shown Schwartz failed to pursue a reasonable alternative defense strategy due to any conflicts.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Sharp's § 2255 motion, affirming the district court's decision. The court held that Sharp did not demonstrate that any alleged conflict of interest actually affected the adequacy of his representation, nor did he show that his new counsel, Michael Lahammer, performed deficiently. Thus, the court concluded that Sharp was not denied effective assistance of counsel and affirmed the judgment of the district court. View "Sharp v. United States" on Justia Law

Edwin Giovanni Salinas was stopped by law enforcement on the Lake Traverse Reservation in South Dakota. He was a passenger in a vehicle driven by Berta Rosmelvi Gonzales, who initially provided false identification. After her arrest, officers found Salinas throwing items inside the vehicle. They discovered methamphetamine in Gonzales’s purse and a backpack containing fentanyl in the trunk. Salinas and Gonzales were charged with conspiracy to distribute and possession with intent to distribute a controlled substance. A jury found Salinas guilty on both counts.The United States District Court for the District of South Dakota calculated a base offense level of 34 for Salinas, applying a two-level enhancement under U.S.S.G. § 2D1.1(b)(13) for trafficking counterfeit fentanyl pills and additional enhancements for his role in the offense. The court imposed a life sentence, citing Salinas’s presence on the reservation with a large quantity of fentanyl and the potential harm to the community.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the application of the § 2D1.1(b)(13) enhancement, finding sufficient evidence that Salinas acted with willful blindness regarding the counterfeit nature of the pills. However, the court held that the district court procedurally erred by basing the life sentence on clearly erroneous facts, specifically the unproven intention to distribute drugs on the reservation. The appellate court vacated Salinas’s life sentence and remanded for resentencing. View "United States v. Salinas" on Justia Law

Camron Jordan Henry pled guilty to unlawfully possessing a firearm as a convicted felon, violating 18 U.S.C. §§ 922(g)(1) and 924(a)(8). The district court sentenced him to 46 months in prison. Henry appealed the sentence, specifically challenging the application of a sentencing enhancement for "reckless endangerment during flight" under U.S.S.G. § 3C1.2. This enhancement applies if the defendant recklessly created a substantial risk of death or serious bodily injury to another person while fleeing from law enforcement.The United States District Court for the Western District of Missouri applied the enhancement, noting that Henry fled from police with a loaded gun in his pocket, which posed a substantial risk of accidental discharge. The court inferred that there was a crowd present during Henry's flight, which increased the potential danger. Henry did not object to this inference.The United States Court of Appeals for the Eighth Circuit reviewed the district court's findings for clear error. The appellate court noted that other circuits have required "something more" than mere possession of a firearm during flight to support the enhancement, such as the firearm being loaded or cocked. The Eighth Circuit found that Henry's case met this criterion because he carried a loaded, chambered, unholstered gun, which created the possibility of accidental discharge. The presence of bystanders further supported the application of the enhancement.The Eighth Circuit affirmed the district court's judgment, concluding that the application of the sentencing enhancement for reckless endangerment during flight was appropriate given the circumstances of Henry's case. View "United States v. Henry" on Justia Law