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

Jason Potter was charged with drug trafficking offenses after police seized drugs from his vehicle during a traffic stop. The stop occurred following an investigation at a motel in Lee’s Summit, Missouri, where police were conducting surveillance due to reports of drug activity and stolen vehicles. Potter and his associate, Daniel Dryden, were arrested after leaving the motel. An inventory search of Potter’s car, conducted after it was towed, revealed methamphetamine. Potter moved to suppress the evidence, arguing that the search and seizure violated his Fourth Amendment rights. The district court denied the motion, and Potter was convicted and sentenced to 360 months’ imprisonment.The United States District Court for the Western District of Missouri denied Potter’s motion to suppress the evidence. A jury subsequently found Potter guilty on both counts of drug trafficking. The district court sentenced him to 360 months’ imprisonment. Dryden, who pleaded guilty, received a 36-month sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the timing of the traffic stop did not make the seizure unreasonable under the Fourth Amendment, as officers had probable cause based on an outstanding arrest warrant. The court also found that the inventory search of Potter’s car was reasonable and conducted according to standardized police procedures. Additionally, the court rejected Potter’s claim of vindictiveness in sentencing, noting that the district court provided valid reasons for the disparity between Potter’s and Dryden’s sentences. The Eighth Circuit affirmed the district court’s judgment and denied Potter’s appeal. View "United States v. Potter" on Justia Law

Four elderly sisters were accused of defrauding the United States by falsely claiming benefits under two federal programs. Each sister pled guilty to one count of conspiracy, preserving the right to appeal two pretrial rulings: the denial of a motion to suppress evidence and the denial of a motion to dismiss the indictment for untimeliness.The United States District Court for the Eastern District of Arkansas denied the motion to suppress, ruling that the sisters lacked standing to challenge the search of a property because they had no possessory interest in it. The court also found that even if the search was unconstitutional, the affidavits supporting the search warrants still provided probable cause. The motion to dismiss the indictment was denied because the court held that the statute of limitations for mail fraud begins on the date of mailing, not the date of the last overt act.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, agreeing that the affidavits were sufficient to support the search warrants even without the contested information. The court also affirmed the denial of the motion to dismiss, stating that the aiding and abetting mail fraud charges were filed within the five-year limitations period. Additionally, the court found no abuse of discretion in the district court's decision not to hold an evidentiary hearing on the motions, as the alleged disputes of fact were immaterial to the legal conclusions.The Eighth Circuit affirmed the district court's rulings, upholding the convictions and sentences of the four sisters. View "United States v. Charles" on Justia Law

Larenzo Burnett pleaded guilty to possession of a firearm by a prohibited person. During sentencing, a dispute arose regarding whether Burnett’s prior conviction under Iowa Code § 708.6(2) was a "crime of violence," which would increase his base offense level. The probation office recommended the increase, but Burnett objected. The parties reached a sentencing agreement where Burnett withdrew his objection and stipulated that the prior conviction was for a crime of violence. The district court imposed a sentence of 99 months and 14 days in prison.Burnett later filed a motion to vacate his sentence under 28 U.S.C. § 2255, claiming ineffective assistance of counsel because his attorney failed to file a notice of appeal. The district court held an evidentiary hearing and found that Burnett had not asked his attorney to file a notice of appeal within the 14-day period allowed by rule. Consequently, the court denied Burnett’s motion to vacate his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. To establish ineffective assistance of counsel, Burnett needed to show that his counsel’s performance was deficient and that the deficiency prejudiced his defense. The court found that Burnett’s defense counsel testified credibly that Burnett never requested an appeal. The district court’s credibility determination was not clearly erroneous, as it was based on the observation of witness demeanor and the consistency of the testimony. The appellate court affirmed the district court’s judgment, concluding that there was no clear error in the finding that Burnett did not ask his attorney to file a notice of appeal. View "Burnett v. United States" on Justia Law

Douglas Turner was convicted of possession of child pornography. He appealed the district court's denial of his motion to suppress evidence, arguing that his statements during a May 2018 interrogation should have been suppressed because he was subjected to custodial interrogation without Miranda warnings. At the time of the interrogation, Turner was an inmate and was interviewed by an FBI agent and a Bureau of Prisons investigator about a cell phone found in his bunk.The United States District Court for the Eastern District of Arkansas denied Turner's motion to suppress, concluding that he was not in custody during the interview. The court found that Turner was informed he did not have to answer questions and was not in custody, and that the interview was conducted in a non-coercive manner. A jury subsequently convicted Turner, and the district court imposed a sentence.The United States Court of Appeals for the Eighth Circuit reviewed the district court's factual findings for clear error and its legal determination on "custody" de novo. The appellate court held that Turner was not in custody for purposes of Miranda during the interview. The court noted that Turner was informed he did not have to answer questions, the interview was conducted in a non-coercive environment, and Turner was returned to his normal prison life afterward. The court concluded that a reasonable inmate in Turner's position would have felt free to terminate the interview and return to his housing unit. Therefore, the district court's denial of the motion to suppress was affirmed, and the judgment was upheld. View "U.S. v. Turner" on Justia Law

In January 2021, an individual wearing a black sweatsuit and a face mask robbed a Steak 'n Shake restaurant, holding the manager, Richard Payne, at gunpoint and taking money from the safe and cash registers. Payne identified the robber as Jonathan Davis, a former employee, based on his attire. Davis was later arrested wearing a similar outfit, and a red iPhone was seized from him. Davis claimed he was at a hotel talking to his girlfriend during the robbery. Investigators obtained a search warrant for the phone, which revealed incriminating evidence.The United States District Court for the Eastern District of Missouri denied Davis's motion to suppress the phone evidence, finding the warrant supported by probable cause and applicable under the good-faith exception. The court also denied Davis's motion to strike Juror No. 40, who had been a victim of a similar crime, and excluded defense testimony about a car Davis received as a gift after the robbery, deeming it irrelevant.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, concluding that the search warrant was supported by probable cause. The court also upheld the decision to retain Juror No. 40, finding no abuse of discretion and rejecting the implied bias argument. Lastly, the court affirmed the exclusion of the defense testimony regarding the car, agreeing that it was not relevant to the case.The Eighth Circuit held that the district court did not err in its rulings and affirmed the judgment, maintaining Davis's conviction and sentence. View "United States v. Davis" on Justia Law

Kujali Strawther was stopped by a South Dakota Highway Patrol officer for speeding. During the stop, the officer claimed to smell burnt marijuana emanating from the vehicle. Strawther admitted to having smoked marijuana in the vehicle while in California. A search of the vehicle revealed over two pounds of raw marijuana and a firearm. Strawther was subsequently arrested and charged with possessing a firearm after being convicted of a felony.In the United States District Court for the District of South Dakota, Strawther filed a motion to suppress the evidence found during the search, arguing that the traffic stop and subsequent search were unlawful. The district court denied the motion, finding that the traffic stop was justified based on the officer's observation of speeding and that the search was lawful due to the smell of marijuana providing probable cause.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, holding that the initial traffic stop was constitutionally sound based on the officer's credible testimony that Strawther was speeding. The court also found that the officer did not unreasonably prolong the stop and that the smell of burnt marijuana provided probable cause for the search. The court concluded that the district court did not err in denying Strawther's motion to suppress the evidence. View "United States v. Strawther" on Justia Law

George Harper, Jr. was indicted for being a felon in possession of ammunition following a shooting incident in Davenport, Iowa. After two unsuccessful suppression motions, he pled guilty. At sentencing, the district court applied the attempted murder cross-reference and sentenced Harper to 67 months’ imprisonment. Harper appealed the application of the cross-reference and the denial of one of his suppression motions.The United States District Court for the Southern District of Iowa denied Harper’s motion to suppress A.H.’s eyewitness identification, concluding that A.H. knew Harper before the incident and that his reluctance to identify Harper initially was due to fear of involvement in a police investigation. The court also found that Detective Reeves’s thumb placement on Harper’s photograph was not impermissibly suggestive. Harper pled guilty but preserved his right to appeal the denial of his motion to suppress and the district court’s sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the identification procedure did not create a substantial likelihood of irreparable misidentification, as A.H. knew Harper and identified him from surveillance footage before the photo array. The court also found that the district court did not err in applying the attempted murder cross-reference, as Harper fired multiple rounds at X.B., demonstrating an intent to kill or callous disregard for human life. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Harper" on Justia Law

In January 2020, Detective Josh Winter of the Clinton, Iowa, Police Department stopped Johnathon Lawrence Rose for having heavily-tinted windows, which violated Iowa law. During the stop, Rose's behavior made Winter nervous, prompting him to request a canine unit. The drug-detection dog alerted to the presence of drugs, leading to a search of Rose's car, where officers found drug paraphernalia and suspected drug residue. Rose was arrested, and further searches at the police department and his residence revealed more drugs, ammunition, and firearms. Rose was indicted for possessing methamphetamine with intent to distribute and unlawfully possessing a firearm as a felon.The United States District Court for the Southern District of Iowa held an evidentiary hearing and denied Rose's motion to suppress the evidence. Rose entered a conditional guilty plea, reserving his right to appeal the denial of the motion to suppress. The district court determined Rose was a career offender and sentenced him to 210 months of imprisonment. Rose appealed, and the United States Court of Appeals for the Eighth Circuit affirmed his sentence. Rose then filed a motion for relief under 28 U.S.C. § 2255, alleging ineffective assistance of counsel. The district court agreed, vacated his sentence, and reimposed it, allowing Rose to appeal again.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's denial of the motion to suppress, finding no constitutional violations in the traffic stop, searches, or Rose's incriminating statements. However, the court reversed Rose's sentence, agreeing with the government's concession that the case must be remanded for resentencing in light of a recent decision in United States v. Daye, which impacted the classification of Rose as a career offender. The case was remanded for further proceedings consistent with this opinion. View "United States v. Rose" on Justia Law

Larry Hayward was convicted by a jury of five counts related to heroin offenses. He subsequently filed a motion for acquittal or a new trial, which was denied. On appeal, Hayward contended that the district court erred by admitting evidence of an uncharged controlled buy involving heroin and fentanyl and argued that the evidence was insufficient to support his convictions for conspiracy to distribute drugs and aiding and abetting drug distribution.The United States District Court for the Western District of Missouri oversaw Hayward's trial. The court admitted evidence of an uncharged controlled buy from August 2019, which involved fentanyl, over Hayward's objections. Hayward was convicted on all counts and sentenced to 240 months in prison. He then appealed the district court's decisions.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 the evidence of the uncharged controlled buy. The court found that the evidence was relevant to Hayward's intent, was sufficiently similar to the charged crimes, was supported by sufficient evidence, and that its probative value was not substantially outweighed by the risk of unfair prejudice.The appellate court also found that there was sufficient evidence to support Hayward's convictions. The court noted that multiple witnesses testified about Hayward's involvement in a heroin distribution operation with his partner, Jasmine Steed. The court concluded that a reasonable jury could infer that Hayward was part of a conspiracy to distribute heroin and that he aided and abetted the distribution of heroin by Steed and another individual, Demario Brown.The Eighth Circuit affirmed the district court's judgment, upholding Hayward's convictions and sentence. View "United States v. Hayward" on Justia Law

Brandon Phillips, who had several Missouri marijuana-possession convictions, pleaded guilty to a federal felon-in-possession charge. Despite Missouri legalizing marijuana and planning to expunge certain convictions, the district court sentenced him to 120 months in prison and imposed a lifetime ban on federal benefits.The United States District Court for the Eastern District of Missouri overruled Phillips's objection that his criminal history was overstated due to Missouri's legalization of marijuana. The court stated it would have imposed the same sentence regardless of the marijuana convictions. Phillips's marijuana convictions were still on record at the time of sentencing, although they were later expunged. Phillips argued that the expungement should require resentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that Phillips did not preserve the expungement issue for appellate review, as he did not clearly state the grounds for his objection in the district court. The court also determined that even if the issue had been preserved, the district court would have imposed the same sentence based on the 18 U.S.C. § 3553(a) factors, considering Phillips's reoffending on parole and possession of a large quantity of fentanyl.However, the Eighth Circuit vacated the federal-benefits ban, finding it was a plain error to apply it to Phillips, as the ban only applies to drug distributors, not gun possessors. The court held that the district court's application of the ban was clearly incorrect and affected Phillips's substantial rights. The court affirmed the 120-month prison sentence but vacated the federal-benefits ban. View "United States v. Phillips" on Justia Law