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

Defendant was convicted of kidnapping Maria Eloiza and her five-year-old son, resulting in the deaths of both. Defendant was 16-years-old at the time he committed the offense, and the district court sentenced him to the statutorily mandated term of life imprisonment. The Supreme Court subsequently held in Miller v. Alabama, 567 U.S. 460, 465 (2012), that a mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments. Based on Miller, the district court granted defendant's motion to vacate, set aside, or correct his sentence under 28 U.S.C. 2255. After the district court sentenced defendant to 50 years' imprisonment, defendant appealed.The Eighth Circuit affirmed, holding that the district court did not clearly err in finding defendant competent to proceed with resentencing. In this case, the district court was entitled to base its competency determination on the BOP doctor's psychological evaluation concluding that defendant had been restored to competency. The court also held that the district court did not plainly err by calculating an advisory Guidelines range of life imprisonment under USSG 2A1.1; the district court considered the 18 U.S.C. 3553(a) sentencing factors, including defendant's youth; and defendant's sentence, a downward variance from the Guidelines range of life, was not substantively unreasonable. View "United States v. Barraza" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence seized from his person and vehicle after his arrest. Defendant conditional pleaded guilty to drug trafficking and firearms offenses. The court concluded that the officers had reasonable suspicion to believe that defendant unlawfully possessed a firearm, which justified an investigative seizure. In this case, the informant's tip contained a detailed description of a weapon allegedly in defendant's possession and the officers were able to corroborate elements of the informant's tip. Furthermore, defendant's furtive behavior in the parking lots further supported reasonable suspicion of criminal activity. View "United States v. LaGrange" on Justia Law

Defendant pleaded guilty in 2008 to conspiracy to distribute at least 50 grams of cocaine base. On appeal, defendant challenged the district court's denial of her motion to reduce her sentence under Section 404 of the First Step Act of 2018. Most of defendant's arguments on appeal were rejected in the Eighth Circuit's recent decisions resolving First Step Act issues.However, the court agreed with defendant's contention that the district court erred in determining her amended guidelines sentencing range under the Act. Because the record does not permit the court to determine whether this error was harmless under the Supreme Court's rigorous standard governing procedural Guidelines errors, the court remanded for resentencing. View "United States v. Holder" on Justia Law

The Eighth Circuit held that, under the fugitive disentitlement doctrine, defendant forfeited his right to have his appeal heard because he escaped from prison. On the Government's request, the appeal will be dismissed thirty days from the date of the filing of this opinion unless defendant submits himself to the jurisdiction of the United States District Court or is found and taken into custody by either state or federal officers. View "United States v. Diaz" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of a firearm. The court held that, in light of the totality of the circumstances, the officer had reasonable suspicion that defendant and his companion were the assailants described in a 911 call so as to have justification to stop them in the first place. In this case, defendant and his companion were two men, they matched the generic description of the assailants, they were in close temporal and geographical proximity to the crime, their clothing partly matched the assailants' clothing, and they were walking away from the crime scene. Having concluded that reasonable suspicion existed to justify the stop, the court had no trouble concluding further that reasonable suspicion existed to justify the frisk. View "United States v. Slater" on Justia Law

The Eighth Circuit affirmed defendant's conviction for five controlled substance offenses. The court held that the evidence was sufficient to support defendant's convictions for conspiring to distribute crack and heroin and distribution of heroin; defendant's Batson challenge failed because the government offered race-neutral reasons for its peremptory strike and the district court did not clearly err in finding that defendant failed to establish that the government's combination of reasons was pretextual; and there was no error in answering the jury's question for clarification of the term "on or about" and there was no abuse of the district court's substantial discretion in formulating jury instructions. View "United States v. Stevenson" on Justia Law

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court held that the district court did not err by denying defendant's motion to suppress where police entry into the residence in response to the call for medical aid for a shooting victim was not constitutionally objectionable.In this case, given the fact of a shooting and the other information known to officers at the time, exigent circumstances made it permissible to look into other rooms to ensure the absence of a shooter or additional victims. Furthermore, the officers almost immediately saw ammunition and suspected narcotics in plain view; officers were permitted to secure the exterior of the residence for the same reasons; and, to the extent defendant takes issue with the officers looking on the adjacent property, any objects found there were abandoned. The court concluded that defendant's arguments do not merit relief where the officers were not "lingering" or "frolicking" in a manner inconsistent with a security sweep. Moreover, no information gleaned through lingering in the home, or re-entering after the ambulance departed, aided in securing the search warrant. Finally, the court held that the district court did not clearly err by finding that defendant possessed the firearms in connection with another felony under USSG 2K2.1(b)(6)(b). View "United States v. Crutchfield" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of being a felon in possession of a firearm. The court held that the district court did not err by applying an enhanced offense level pursuant to USSG 2K2.1(a)(2) based on prior state convictions for a crime of violence and a controlled substance offense. In this case, defendant's prior conviction for threatening to commit a crime which will result in death or great bodily injury to another person, in violation of California Penal Code 422(a), qualified as a crime of violence because the statute's elements necessarily include a threatened use of physical force capable of causing physical pain or injury to another person. The court rejected defendant's contention that his prior California conviction for possession of marijuana for sale does not qualify as a controlled substance offense due to California's reclassification of his conviction. The court has repeatedly rejected similar arguments to the federal effects of state classification. View "United States v. Doran" on Justia Law

The Eighth Circuit affirmed defendant's conviction for extortion, attempted extortion, and receipt of a firearm with intent to commit a felony. Defendant's convictions stemmed from the use of his official position on the Tri-County Drug Task Force to obtain an ATV and firearms from confidential informants. The court held that there was sufficient evidence to convict defendant of the charges.The court also held that the district court did exactly what it should have done after receiving unsolicited, case-related messages from a family member, and thus the district court did not err, plain or otherwise, by failing to sua sponte recuse the judge at sentencing. In this case, while the court did not know why the district judge's brother was interested in the case (nor did the district court), nothing in the text messages disclosed by the district judge revealed any favoritism or antagonism by the judge. Furthermore, none of the parties observed any potential issues or objected. View "United States v. Chastain" on Justia Law

The Eighth Circuit affirmed defendant's conviction for unlawful possession of a firearm as a convicted felon. The court held that the district court did not abuse its discretion in admitting defendant's 2005 conviction for possessing a firearm as a felon where the conviction was sufficiently similar and not too remote in time, it went to the issue of proving knowledge and intent, and it did not unfairly prejudice defendant.The court also held that the district court did not abuse its discretion in denying defendant's objections to the prosecution's closing arguments. In this case, the prosecutor's remarks were invited by defense counsel at closing and, even assuming the remarks were improper, defendant failed to show prejudice. View "United States v. Smith" on Justia Law