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

The Eighth Circuit affirmed the district court's order declining to impose a reduced sentence under the First Step Act of 2018. The court rejected defendant's suggestion that the district court mistakenly deemed him ineligible because it focused on the wrong drug quantity in determining whether the statutory penalties for his offense were modified by the Fair Sentencing Act. To the contrary, the district court properly rejected defendant's argument that he was entitled to a hearing and then acknowledged that the First Step Act vests discretion in the sentencing court to look at the facts and procedural history of each case when deciding whether to exercise discretion to reduce a sentence. In this case, the district court exercised discretion under the First Step Act, but determined that the existing sentence was appropriate. View "United States v. Haynes" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to conspiracy to distribute and possess with intent to distribute 500 grams or more of methamphetamine. The court held that the district court did not err in denying defendant's motion to suppress statements made when police officers, about to conduct a search to which his roommate had consented, asked defendant "if he lived in the house and which bedroom was his."In this case, neither of the two questions at issue constituted interrogation that required Miranda warnings because a request for routine information necessary for basic identification purposes is not interrogation, even if that information later turns out to be incriminating. Furthermore, the officer's follow up question asking defendant to identify his bedroom, although it presents a closer question, was permissible because the officers needed to determine whether defendant occupied the bedroom and, if so, whether he consented to the search. Therefore, the district court properly denied the motion to suppress. View "United States v. Tapia-Rodriguez" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to petitioner, who was convicted of one count of first degree murder and two counts of attempted first degree murder. In this case, the Minnesota Supreme Court issued a list of basic rules for spectators at trial and required spectators to show photographic identification before being allowed entry into the courtroom. On direct appeal, the Minnesota Supreme Court rejected petitioner's argument that the identification requirement violated his Sixth Amendment public right to trial.The court held that petitioner failed to demonstrate that the Minnesota Supreme Court's decision -- that no closure occurred because there was no evidence that the requirement was enforced -- is both contrary to and an unreasonable application of Waller v. Georgia, 467 U.S. 39 (1984), and Presley v. Georgia, 558 U.S. 209 (2010) (per curiam). Finally, the court declined to exercise its discretion by expanding the certificate of appealability. View "Taylor v. Dayton" on Justia Law

After defendant pleaded guilty to one count of conspiring to distribute cocaine base and heroin, he was sentenced to a below-Guidelines sentence of 160 months' imprisonment. The Eighth Circuit held that the district court's competency determination was supported by more than ample evidence, was not clearly erroneous, and was not sufficiently close to consider the burden of proof as a potential source of error. The court also held that there was no error in the district court's drug quantity or firearm-related Guidelines determinations. Finally, the court held that defendant's sentence was substantively reasonable and the district court did not abuse its discretion in weighing defendant's role in the conspiracy and his physical and mental limitations. View "United States v. Washington" on Justia Law

The Eighth Circuit affirmed defendant's eight year sentence imposed after he pleaded guilty to being a felon in possession of a firearm. The court held that the district court did not clearly err in finding that defendant fired the gun by crediting a witness's account in the circumstances. In this case, the record does not refute the witness's account or otherwise offer anything other than emanations of uncertainty, which is not enough to reverse the finding under the court's standard of review. View "United States v. Dock" on Justia Law

The Eighth Circuit affirmed Defendants McSmith and Teagues' sentences for drug-related offenses. The court held that the district court properly calculated the drug quantity under USSG 2D1.1; the district court correctly applied a three-level aggravating role adjustment for McSmith's role as a manager or supervisor under USSG 3B1.1; the district court correctly found that McSmith was under court supervision at the time of the offense in this case, justifying two criminal history points; and defendants' sentences were substantively reasonable where the district court did not abuse its discretion in weighing the 18 U.S.C. 3553(a) factors. View "United States v. McSmith" on Justia Law

The Eighth Circuit affirmed the district court's denial of a sentence reduction under the First Step Act of 2018. Defendant was originally sentenced to 353 months' imprisonment for three counts of Hobbs Act robbery and two counts of using a firearm during and in relation to those robberies.The court held that defendant failed to establish extraordinary or compelling reasons to warrant compassionate release. The court need not decide whether the statute supersedes the policy statement in determining whether a movant qualifies for compassionate release, because the district court's order shows that it considered the circumstances urged by defendant and found them insufficient. The court held that the district court has broad discretion in determining whether proffered circumstances warrant a reduction in sentence and the district court's conclusion was a reasonable exercise of that discretion. View "United States v. Loggins" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to knowingly receiving a visual depiction of a minor engaging in sexually explicit conduct. The court held that the district court did not err by applying a two-level increase for a defendant who knowingly engaged in distribution of material involving sexual exploitation of a minor under USSG 2G2.2(b)(3)(F). In this case, the district court made an express finding of knowledge that was supported by sufficient evidence to meet the government's burden of proof. View "United States v. Martinez" on Justia Law

The Eighth Circuit affirmed defendant's conviction for 14 counts of aiding and abetting wire fraud, one count of conspiracy to commit securities fraud, and six counts of aiding and abetting securities fraud. Defendant's convictions stemmed from his involvement in a market manipulation scheme.The court held that the evidence was sufficient for a reasonable jury to find that defendant's conduct was fraudulent and manipulative within the meaning of the statutes in question; the evidence was sufficient to show nondisclosure or active concealment of a material fact where a jury could easily find that a reasonable investor would have found material the fact that a corporate insider had, through a nominee, purchased more than half of the freely tradeable stock and was directing that nominee and others to trade the stock at pre-arranged prices for the purpose of triggering tens of millions of dollars in bonus payments that would likely cripple the corporation; the district court did not abuse its discretion or plainly err in admitting lay opinion testimony; and the district court did not abuse its discretion in ordering restitution in the amount of $15,135,361. View "United States v. Gilbertson" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion for a new trial based on newly-discovered evidence. The court held that the district court did not clearly err in denying the motion without a hearing, because defendant did not identify any evidentiary support for his allegations and thus they were insufficient to warrant a new trial. In this case, there is no reason to believe that new evidence related to a prior shooting would change the jury's verdict. View "United States v. Glinn" on Justia Law