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

Leslie Isben Rogge, aged 85, filed a motion for compassionate release in 2022, citing his age, deteriorating health, and need for specialized care as extraordinary and compelling reasons for his release. Rogge argued that his release would be consistent with applicable sentencing policy statements. The district court denied the motion without prejudice, stating that Rogge was not eligible to request relief himself under 18 U.S.C. § 3582(c)(1)(A), as amended by the First Step Act of 2018 (FSA).Rogge was convicted and sentenced in five separate armed bank robbery cases between 1984 and 1997. In July 2021, he filed a pro se motion for compassionate release, which was denied for failure to exhaust administrative remedies. He filed a second motion in July 2022, and the court appointed a Federal Public Defender, who filed an Emergency Motion for Reconsideration. The government opposed the motion, arguing that Rogge failed to show extraordinary and compelling circumstances and that his criminal history weighed against release. The district court concluded that Rogge was an "old law" inmate, ineligible to seek compassionate release under § 3582(c) until at least October 25, 2025, and denied the motion without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that defendants who committed their crimes before November 1, 1987, are not eligible to move for § 3582(c) compassionate release relief on their own behalf. The court affirmed the district court's decision, agreeing with other circuits that the FSA did not alter the exclusion of offenses predating November 1, 1987. Therefore, only the Bureau of Prisons may initiate a compassionate release request for Rogge, and it did not do so in this case. View "United States v. Rogge" on Justia Law

Kevon Spratt was charged with nine counts related to a series of robberies in western Iowa during the fall of 2022. The charges included four robberies or attempted robberies and associated firearm offenses, as well as unlawful possession of a firearm by a felon. Spratt moved to dismiss one count and to suppress evidence seized from his car, but the district court denied both motions. The jury acquitted him on two counts but convicted him on the remaining charges. Spratt appealed his convictions and sentence.The United States District Court for the Northern District of Iowa denied Spratt's motions to dismiss and suppress evidence. The jury found him guilty on seven counts, leading to a total sentence of 432 months and five years of supervised release. Spratt appealed these decisions, arguing errors in the denial of his motions, the admission of evidence, and the sufficiency of the evidence supporting his convictions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not err in denying Spratt's motion to suppress, as the officers had probable cause based on collective knowledge and communication. The court also affirmed the denial of the motion to dismiss Count 8, ruling that attempted bank robbery under 18 U.S.C. § 2113(a) is a crime of violence. Additionally, the court found no abuse of discretion in admitting evidence of uncharged robberies under Rule 404(b) and determined that there was sufficient evidence to support Spratt's convictions. The court also upheld the district court's sentencing decisions, finding no procedural or substantive errors. The Eighth Circuit affirmed Spratt's convictions and sentence. View "United States v. Spratt" on Justia Law

In 1996, Roderick Rankin was sentenced to death for the murders of Zena Reynolds, Ernestine Halford, and Nathaniel Halford. Rankin filed a federal habeas petition, arguing that he was intellectually disabled at the time of the murders, his trial counsel was ineffective for not investigating and presenting evidence that his brother Rodney committed the murders, his trial counsel had conflicts of interest, the penalty-phase jury instructions violated Supreme Court precedents, and his trial counsel was ineffective for not objecting to these instructions. The district court denied habeas relief without an evidentiary hearing.The United States District Court for the Eastern District of Arkansas denied Rankin's habeas petition, finding that he had not exhausted all state court claims and stayed the proceedings to allow him to pursue relief in state court. Rankin's subsequent state court attempts were unsuccessful, and he returned to federal court with an amended habeas petition. The district court denied relief, noting that Rankin had not provided clear and convincing evidence to contradict the state court's determination that he was not intellectually disabled and that his other claims failed on the merits.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Arkansas Supreme Court's rejection of Rankin's intellectual disability claim was not based on an unreasonable determination of the facts. The court also found that Rankin's claims of ineffective assistance of counsel and jury instruction errors were procedurally defaulted and without merit. The court concluded that Rankin was not entitled to an evidentiary hearing on his claims. View "Rankin v. Payne" on Justia Law

In 2018, Detective James Gaddy of the St. Charles County, Missouri Police Department investigated a large-scale drug distributor, Guy Goolsby, and obtained wiretap authorization for Goolsby’s cell phone. The wiretap revealed that Freeman Whitfield IV was involved in the drug distribution. In 2019, Goolsby directed Whitfield to retrieve drugs, and Whitfield was later implicated in the murder of Antonio Boyd, a cooperating witness. Investigators linked Whitfield to the crime scene through cell tower data and intercepted conversations. In 2021, search warrants for Whitfield’s residences led to the discovery of firearms, ammunition, drugs, and drug proceeds.The United States District Court for the Eastern District of Missouri denied Whitfield’s pretrial motions to suppress evidence and to sever counts related to the murder from the drug charges. The court found probable cause for the search warrants and ruled that the wiretap evidence was obtained lawfully. The court also determined that the charges were sufficiently related to be tried together. Whitfield was found guilty on all counts and sentenced to life imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the district court’s denial of Whitfield’s motions to suppress, finding that the affidavits supporting the search warrants established probable cause and that the wiretap evidence met the necessity requirement under 18 U.S.C. § 2518. The court also affirmed the denial of the motion to sever, concluding that the charges were properly joined and that Whitfield failed to demonstrate any resulting prejudice. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Whitfield" on Justia Law

Byron Williams pled guilty to three counts of being a felon in possession of a firearm, violating 18 U.S.C. §§ 922(g)(1) and 924(a)(2). He was found with handguns on three separate occasions between January 2020 and March 2021, despite being prohibited from possessing firearms due to prior felony convictions. The incidents involved a traffic stop, an altercation reported by his ex-girlfriend, and a high-speed chase following a disturbance.The United States District Court for the Western District of Missouri sentenced Williams to 240 months’ imprisonment. Williams appealed, arguing procedural error and the substantive unreasonableness of his sentence. He contended that the district court improperly limited his argument for a downward variance at sentencing and failed to adequately consider his intellectual disabilities.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that while the district court initially interrupted Williams’s counsel, it ultimately allowed her to present arguments regarding Williams’s intellectual disabilities and other mitigating factors. The appellate court determined that the district court did not abuse its discretion in limiting arguments related to Williams’s competency, which had already been decided.Regarding the substantive reasonableness of the sentence, the Eighth Circuit held that the district court did not abuse its discretion. The court justified the upward variance from the Guidelines range based on Williams’s criminal history, high risk of recidivism, and the danger he posed to the community. The appellate court concluded that the district court appropriately weighed the relevant factors and affirmed the 240-month sentence.The Eighth Circuit affirmed the judgment of the district court, finding no procedural error or substantive unreasonableness in the sentence imposed on Williams. View "United States v. Williams" on Justia Law

Marqus Patton was convicted by a Nebraska jury of first-degree murder and using a deadly weapon during a robbery following the attempted robbery and fatal shooting of Kristopher Winters. Patton filed a habeas corpus petition under 28 U.S.C. § 2254(d), alleging that his due process rights were violated because the State failed to disclose tacit plea agreements with two witnesses, Emily Gusman and Drake Northrop, who testified against him at trial.The United States District Court for the District of Nebraska denied Patton’s habeas petition but granted a certificate of appealability. The district court was skeptical about the absence of agreements but concluded that the Nebraska Supreme Court’s finding that no tacit plea agreements existed was not unreasonable. The district court also found that any undisclosed agreements would not have been material to the trial's outcome due to the extensive cross-examination of the witnesses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court noted that the Nebraska Supreme Court had determined there were no tacit plea agreements, and this conclusion was not unreasonable based on the evidence. The court emphasized that under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a state court’s factual determinations are presumed correct unless rebutted by clear and convincing evidence. The Eighth Circuit found that the evidence supported either conclusion regarding the existence of tacit plea agreements and that the state court’s determination was reasonable.The Eighth Circuit affirmed the district court’s denial of Patton’s habeas petition, concluding that the state court’s adjudication did not involve an unreasonable determination of the facts. View "Patton v. Boyd" on Justia Law

In 2015, Shirley Carter was found dead in her home from gunshot wounds. Jason Carter, her son, was later found civilly liable for her wrongful death. Following this, Iowa Division of Criminal Investigation Agent Mark Ludwick and Marion County Deputy Sheriff Reed Kious arrested Jason for first-degree murder. However, Jason was acquitted in a jury trial. Jason then filed a 42 U.S.C. § 1983 action against Ludwick and Kious, alleging violations of his constitutional and state-law rights during the investigation of his mother's murder.The United States District Court for the Southern District of Iowa dismissed Jason's complaint, granting Ludwick and Kious qualified immunity on all federal claims and ruling that Jason failed to state a claim for his state law claims. The court also dismissed Marion County from the suit, as Jason did not allege a pattern of unconstitutional conduct.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Ludwick and Kious were entitled to qualified immunity. The court found that Jason failed to plausibly allege a constitutional violation for false arrest, as the arrest was conducted pursuant to a facially valid warrant. The court also held that Jason's claim of evidence concealment did not constitute a clearly established constitutional violation. Additionally, the court ruled that Jason's failure-to-investigate claim did not meet the threshold for a substantive due process violation. The court also affirmed the dismissal of Jason's state law claims for malicious prosecution and abuse of process, noting the presence of probable cause and the lack of improper motive. View "Carter v. Ludwick" on Justia Law

On March 15, 2022, law enforcement responded to a drug overdose in Rapid City, South Dakota, where they found K.S. conscious but sluggish after receiving Narcan. Officers suspected two individuals, including a woman with purple hair, of distributing fentanyl to K.S. Surveillance at a hotel led to a traffic stop of a red Ford Fiesta, where officers found Anthony Ward in the backseat. Ward was arrested for false impersonation after providing false names. A search of the vehicle revealed drugs, a stolen gun, and cash. Ward was charged with distribution of a controlled substance resulting in serious bodily injury and conspiracy to distribute fentanyl.The United States District Court for the District of South Dakota denied Ward's motions to suppress evidence from the traffic stop and to dismiss the indictment for failure to preserve evidence. After a five-day trial, the jury convicted Ward on both counts, and the court imposed concurrent 360-month sentences. Ward appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the district court's denial of Ward's motions to suppress and dismiss, finding no unreasonable extension of the traffic stop and no bad faith in the handling of evidence. The court also found sufficient evidence to support Ward's convictions. The court concluded that the evidence showed Ward distributed fentanyl that caused K.S.'s serious bodily injury and that Ward was involved in a conspiracy to distribute fentanyl. The judgment of the district court was affirmed. View "United States v. Ward" on Justia Law

A Missouri state trooper stopped the defendant for minor traffic violations, during which the defendant disclosed his status as a registered sex offender. The trooper invited the defendant into his patrol car while checking his license and registration. During this time, the trooper learned that the defendant had not registered any social media accounts as required by Missouri law. The trooper then asked for and received consent to search the defendant’s vehicle. While searching, the trooper picked up the defendant’s cell phone, which illuminated to reveal social media app icons. The trooper questioned the defendant about the phone and, after repeated requests, obtained the defendant’s verbal consent to search the phone. The search revealed images suspected to be child pornography, leading to the defendant’s arrest. After being read his Miranda rights, the defendant made further incriminating statements. A subsequent warrant-based search of the phone uncovered additional illegal material.The United States District Court for the Western District of Missouri denied the defendant’s motion to suppress the evidence from the cell phone and his statements to law enforcement, adopting a magistrate judge’s recommendation. The defendant waived his right to a jury trial, proceeded to a bench trial, and was convicted of receiving child pornography.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the trooper’s brief questioning and request for consent did not unlawfully prolong the traffic stop. The court found that moving the cell phone during a consensual vehicle search did not constitute an unlawful search or seizure, and that the defendant voluntarily consented to the phone search. The court also determined that the defendant was not in custody for Miranda purposes during pre-arrest questioning, so suppression of his statements was not warranted. The district court’s judgment was affirmed. View "United States v. Puckett" on Justia Law

Nicholas Nesdahl, posing as a teenager, used social media to contact several minor girls and solicit sexually explicit images and videos. In one instance, he directed a 13-year-old girl to record herself sexually abusing her 6-year-old stepsister. The abuse was discovered by the older girl’s mother, who notified authorities. Law enforcement identified Nesdahl as the recipient and found he had received similar material from at least seven other minors across the country. Nesdahl was indicted in both the District of North Dakota and the Western District of Pennsylvania, with the latter case transferred to North Dakota. He entered a plea agreement, pleading guilty to two counts from the Pennsylvania indictment (involving receipt of child pornography and sexual exploitation of a minor) and seven counts from the North Dakota indictment (all for sexual exploitation of a minor).The United States District Court for the District of North Dakota adopted the Presentence Investigation Report, which recommended the statutory maximum sentence and identified nine victims, triggering mandatory restitution under 18 U.S.C. § 2259(b)(2). Nesdahl did not object to the restitution order. At sentencing, the court imposed 600 months’ imprisonment and ordered $3,000 in restitution for each of the nine victims.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the restitution order for plain error and found that mandatory restitution under § 2259(b)(2) applies only to certain trafficking offenses, not to convictions under 18 U.S.C. § 2251(a). The court held that restitution was only authorized for the two victims associated with the § 2252(a)(2) conviction, not for the other seven victims. The Eighth Circuit vacated the restitution award and remanded for a new order reflecting only the two qualifying victims. The court affirmed the 600-month sentence, finding it substantively reasonable and within the district court’s discretion. View "United States v. Nesdahl" on Justia Law