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

Melissa Wanna discovered her profile on MyLife, an information broker, which contained a poor reputation score and references to court records. MyLife offered to provide details or remove the profile for a fee. Believing she lost employment opportunities due to this profile, Wanna filed a class action lawsuit against several Lexis entities, alleging violations of the Fair Credit Reporting Act (FCRA), Driver’s Privacy Protection Act (DPPA), and the federal Racketeer Influenced and Corrupt Organizations Act (RICO), along with several Minnesota state law claims.The United States District Court for the District of Minnesota dismissed Wanna’s claims, concluding that MyLife was not Lexis’s agent. The court found that the data-licensing agreement between Lexis and MyLife explicitly stated that their relationship was that of independent contractors, not principal and agent. As a result, Wanna’s federal claims, which depended on an agency relationship, failed. The district court also declined to exercise supplemental jurisdiction over Wanna’s state law claims and dismissed them without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo and affirmed the dismissal. The appellate court agreed that Wanna’s federal claims required an agency relationship between Lexis and MyLife, which was not established. The court found that MyLife did not have actual or apparent authority to act on Lexis’s behalf, nor did Lexis ratify MyLife’s actions. Additionally, the appellate court held that the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over the state law claims. View "Wanna v. RELX Group, PLC" on Justia Law

Milton Porter pled guilty to being a felon in possession of a firearm, violating 18 U.S.C. § 922(g)(1). The district court sentenced him to 200 months in prison under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), based on three prior violent felony convictions: a 2008 domestic assault in the second degree, a 2018 domestic assault in the second degree, and a 2018 domestic assault in the third degree, all under Missouri law. Porter appealed, arguing he did not have the requisite three prior violent felony convictions to qualify as an armed career criminal.The United States District Court for the Eastern District of Missouri determined that each of Porter's domestic assault convictions qualified as violent felonies under the ACCA. The court did not address whether Porter’s 2018 Missouri conviction for burglary in the second degree qualified as a violent felony, as the domestic assault convictions were sufficient for the ACCA enhancement.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court applied the modified categorical approach to determine that Porter's 2008 and 2018 second-degree domestic assault convictions were violent felonies under the ACCA, as they involved knowingly causing physical injury. The court also determined that Porter's 2018 third-degree domestic assault conviction was a violent felony, as it involved attempting to cause physical injury. The court affirmed the district court's judgment, holding that Porter’s three domestic assault convictions were violent felonies under the ACCA, justifying the sentence enhancement. View "United States v. Porter" on Justia Law

Law enforcement officers suspected Bandak Wiyual Deng of involvement in a shooting at a park on February 10, 2022. Surveillance video showed an individual matching his characteristics exiting a car with what appeared to be a gun. The car, a black Ford Taurus, lacked a license plate or paper registration tag. A confidential informant recorded a conversation with Deng, where Deng mentioned needing a gun for a funeral and a previous shooting. On the day of the funeral, officers stopped Deng, found marijuana and a gun in his car, and Deng admitted to using drugs and touching the gun.The United States District Court for the Southern District of Iowa upheld the government's peremptory strikes of two prospective jurors and refused to admit parts of Deng's interview with law enforcement. Deng's motion for a judgment of acquittal, arguing that 18 U.S.C. § 922(g)(3) violated the Second Amendment, was denied. The jury convicted Deng.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not clearly err in overruling Deng’s objections to the peremptory strikes, as the government provided race-neutral explanations. The court also found that any potential error in the district court's evidentiary rulings was harmless, given the ample evidence supporting Deng’s conviction. Finally, the court affirmed the denial of Deng’s motion for a judgment of acquittal, rejecting his facial challenge to the constitutionality of 18 U.S.C. § 922(g)(3). The judgment was affirmed. View "United States v. Deng" on Justia Law

Edgar Pratt was on supervised release after serving a prison term for possession with intent to distribute fentanyl. He violated the terms of his release multiple times, including accessing a firearm, communicating with a prohibited party, sending threatening messages, and absconding from a residential reentry center. After absconding, he ceased communication with his probation officer and failed to complete the reentry program. He was arrested eight months later.The United States District Court for the Western District of Missouri held a hearing, revoked Pratt's supervised release, and sentenced him to 24 months' imprisonment. Pratt appealed, challenging the procedural soundness and substantive reasonableness of his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court adequately explained its decision, noting Pratt's extensive criminal history and resistance to supervision. The district court's reference to Pratt's "bobbles" while on supervision was not plain error, as the court was familiar with his history. The appellate court also found no abuse of discretion in the district court's consideration of the § 3553(a) factors, including Pratt's criminal history and characteristics. The court held that the district court did not place undue weight on improper factors and acted within its discretion in imposing the statutory maximum sentence.The Eighth Circuit affirmed the judgment of the district court, upholding Pratt's 24-month imprisonment sentence. View "United States v. Pratt" on Justia Law

Louis Rabbitt was convicted by a jury of failing to register as a sex offender, assaulting a federal officer with a deadly weapon, and committing a crime of violence while failing to register as a sex offender. His probation officer testified that Rabbitt missed a scheduled meeting and was not found at his registered address. Deputy U.S. Marshals later found Rabbitt in a parked car, holding a metal baseball bat, and after a chase, he was captured and subdued.The United States District Court for the District of South Dakota denied Rabbitt's motion for a judgment of acquittal, which argued that the evidence was insufficient to support his convictions. The court found that a reasonable jury could conclude that Rabbitt had moved out of his registered residence and failed to update his registration as required. Additionally, the court found that Rabbitt's actions with the baseball bat constituted a threat or display of physical aggression towards the officers.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo, considering the evidence in the light most favorable to the verdict. The appellate court affirmed the district court's decision, holding that sufficient evidence supported Rabbitt's convictions. The court found that Rabbitt knowingly failed to update his registration, used the bat to inspire fear in the officers, and that his actions were intentional. Consequently, the court upheld Rabbitt's convictions for failing to register as a sex offender, assaulting a federal officer, and committing a crime of violence while failing to register. View "United States v. Rabbitt" on Justia Law

In early 2023, investigators conducted six controlled buys of fentanyl pills from Tyran Locure, with Anthony Jackson, Jr. present for two of these buys, which took place in Jackson’s vehicle. A GPS tracker on Jackson’s vehicle showed it frequently parked at an apartment building in Des Moines, Iowa, where both Jackson and Locure were surveilled. A search warrant executed at the apartment found firearms, thousands of fentanyl pills, marijuana, cocaine, cell phones, and a money counter. Jackson’s wallet and documents were also found in the apartment, and $2,263 in cash, including serialized money from a controlled buy, was found on Jackson.The United States District Court for the Southern District of Iowa charged Jackson with conspiracy to distribute controlled substances, possession with intent to distribute fentanyl, possession of firearms in furtherance of a drug trafficking crime, and being a felon in possession of firearms. The jury convicted Jackson on all counts, and the district court sentenced him to 270 months of imprisonment, revoked his supervised release, and added 30 months for violating supervised release terms.The United States Court of Appeals for the Eighth Circuit reviewed Jackson’s appeal, which challenged the admission of a forensic report, evidence of prior bad acts, and the sufficiency of evidence for the conspiracy conviction. The court held that Jackson waived his confrontation rights by stipulating to the forensic report’s findings. The court also found that the admission of evidence of Jackson’s prior conviction and firearm photographs was proper and not unduly prejudicial. Finally, the court concluded that sufficient evidence supported Jackson’s conspiracy conviction, given the controlled buys, GPS data, and items found during the search. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Jackson" on Justia Law

Guy Wilson moved into a residence with his girlfriend and her two minor children, including her daughter B.Z. He installed several cameras throughout the home, some of which were hidden in locations such as vents in B.Z.’s bedroom and the bathroom. These hidden cameras recorded B.Z. in various states of undress, including images of her genitals, pubic area, and breasts. Wilson also took and saved screenshots from this footage that focused on B.Z.’s pubic area and genitals.A grand jury in the United States District Court for the Southern District of Iowa indicted Wilson for both production and attempted production of child pornography, but only the attempt charge was submitted to the jury. At trial, Wilson argued he lacked the intent required for the offense and that the images did not meet the statutory definition of child pornography. He moved for judgment of acquittal at the close of the government’s case and again at the close of all evidence, but both motions were denied. The jury found him guilty of attempted production of child pornography. At sentencing, Wilson sought a reduction for acceptance of responsibility under the Sentencing Guidelines, but the district court denied this request and imposed a 240-month sentence.The United States Court of Appeals for the Eighth Circuit reviewed Wilson’s conviction and sentence. The court held that the district court did not abuse its discretion in instructing the jury on the Dost-plus factors for determining whether an image is a “lascivious exhibition,” nor was it required to explicitly state that these factors are non-exhaustive. The court also found sufficient evidence supported the jury’s verdict and concluded that the district court did not clearly err in denying a reduction for acceptance of responsibility. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Wilson" on Justia Law

In October 2018, Veronica Pineda De Aquino used a false identity to apply for a U.S. passport, submitting fraudulent documents. Investigators, with the cooperation of the real identity holder, A.E., determined Pineda was a Mexican citizen who had entered the U.S. in 1999. In June 2023, a grand jury indicted Pineda for making a false statement in a passport application and using another person’s social security number. Pineda initially pled not guilty but later entered a plea agreement, pleading guilty to the first count in exchange for the dismissal of the second count.The United States District Court for the Western District of Arkansas accepted Pineda’s guilty plea but deferred the decision on the plea agreement until reviewing the presentence investigation report (PSR). The PSR detailed Pineda’s difficult background and calculated an advisory Guidelines range of 0 to 6 months of imprisonment. At sentencing, the district court adopted the PSR without objection but varied upward, sentencing Pineda to 32 months of imprisonment, citing the seriousness of her offense and the need for deterrence. The court dismissed the second count as per the plea agreement.The United States Court of Appeals for the Eighth Circuit reviewed the case. Pineda argued that the district court erred by not expressly accepting or rejecting the plea agreement and by imposing a substantively unreasonable sentence. The appellate court found that the district court constructively accepted the plea agreement and that any error was not plain. The court also held that the district court did not abuse its discretion in sentencing Pineda above the Guidelines range, considering the aggravating factors and the need for deterrence. The Eighth Circuit affirmed the district court’s judgment. View "United States v. De Aquino" on Justia Law

On September 1, 2016, law enforcement officers conducted narcotics raids at a home and shop in Pulaski County, Arkansas. During the raid, officers found contraband in both locations, and an officer shot and injured Lloyd St. Clair, who was holding a shotgun. Lloyd and other occupants of the home and shop filed a lawsuit under § 1983, alleging violations of their Fourth Amendment rights by the officers and the City of Little Rock.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The plaintiffs appealed the decision, arguing that there were genuine disputes of material fact regarding the existence of two separate search warrants and the justification for no-knock entries.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the record included two valid search warrants signed by a state judge, and there was no genuine dispute of material fact regarding their existence. The court also determined that the officers had reasonable suspicion to justify the no-knock entries based on videos of Amy St. Clair shooting firearms, which were seen by Officer Kalmer before the raids.Regarding Lloyd's excessive force claim, the court held that the use of deadly force by Officer Thomas was reasonable, as Lloyd admitted to pointing a gun at Thomas. The court also affirmed the district court's grant of summary judgment on the municipal liability claim, as there was no underlying constitutional violation by the city employees.The Eighth Circuit affirmed the judgment of the district court, upholding the summary judgment in favor of the defendants. View "Davenport v. City of Little Rock" on Justia Law

In January 2023, law enforcement officers from the Rosebud Sioux Tribe responded to a report of a man brandishing a firearm at Benjamin Fool Bull's home. Witnesses identified Tyson Quigley as the man with the firearm and Erwin White Lance as the man with a baseball bat. Both men were later found in a gold Chrysler sedan, which contained a firearm, ammunition, and other items. Quigley declined to speak with investigators, but White Lance admitted to being invited into the residence and claimed responsibility for the firearm before invoking his right to remain silent.Quigley and White Lance were charged with first-degree burglary and using a firearm during a crime of violence. Quigley was also charged with being a felon in possession of a firearm. White Lance died during the proceedings, and the charges against him were dismissed. The district court granted the Government's motion to exclude White Lance's statements as hearsay, ruling that they were not admissible under Rule 804 or Rule 807. At trial, Quigley was found guilty of being a felon in possession of a firearm but acquitted of the other charges. He was sentenced to 90 months in prison and three years of supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that White Lance's statement about taking responsibility for the firearm was not sufficiently trustworthy to be admitted under Rule 804(b)(3) or Rule 807. The court noted that the statement was made under circumstances that suggested a motive to protect Quigley and was contradicted by eyewitness testimony. Therefore, the district court did not abuse its discretion in excluding the statement. View "United States v. Quigley" on Justia Law