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

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court held that defendant's plea was neither knowing nor intelligent because he did not have real notice of the true nature of the charge against him, the first and most universally recognized requirement of due process. Furthermore, defendant's plea also violated Rule 11 because the district court did not advise him of the knowledge-of-status element established by Rehaif v. United States, 139 S. Ct. 2191, 2200 (2019).However, the court held that defendant's constitutionally invalid plea was not structural error and a defendant can only satisfy plain error review by showing that the error affected his or her substantial rights. In this case, defendant has not shown that either the constitutional error or the Rule 11 error affected his substantial rights and therefore he is not entitled to relief on plain error review. View "United States v. Coleman" on Justia Law

The Eighth Circuit affirmed defendant's conviction for one count of conspiracy to distribute 50 grams or more of actual methamphetamine, and some amount of hydromorphone and oxycodone. The court held that the evidence was sufficient to show that defendant conspired to distribute methamphetamine, hydromorphone, or oxycodone.The court rejected defendant's evidentiary challenges, holding that the district court did not abuse its discretion by denying defendant's motion in limine to exclude evidence of his affiliation with a gang, by permitting the government to introduce evidence of his prior convictions under Fed. R. Evid. 404(b), and by limiting his ability to use Fed. R. Evid. 609 evidence to cross examine government witnesses. View "United States v. Shelledy" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of unlawful possession of a firearm as a person previously convicted of a misdemeanor crime of domestic violence. The court held that the district court did not err in imposing a two-level enhancement for obstruction of justice under USSG 3C1.1, based on defendant's false testimony at the sentencing hearing; whether defendant assaulted and attacked someone was plainly material to the district court's sentencing determination under 18 U.S.C. 3553(a); the district court did not err in denying defendant's request for a sentence reduction under USSG 3C1.1 based on acceptance of responsibility; and defendant's sentence was not substantively unreasonable where the district court considered proper factors and reached a reasonable judgment. View "United States v. Montano" on Justia Law

Defendant argued on appeal that his possession of a firearm in June 2018 did not render him ineligible for the "safety valve" on his drug offense from April 2018. The court noted that even aside from 18 U.S.C. 3553(f)(2) and possession of a firearm, the parties disagreed on whether defendant met the requirement of section 3553(f)(5) to provide certain truthful information to the government by the time of the sentencing hearing. In this case, the district court did not resolve the dispute and did not address whether it would sentence defendant to a term of less than 120 months even if the statutory minimum did not apply.The court addressed only the meaning of "offense" in section 3553(f)(2) and held that the term unambiguously limited the offense of conviction. Accordingly, the court remanded for further proceedings on whether defendant possessed a weapon in connection with the offense of conviction and was thus ineligible for safety-valve sentencing. View "United States v. Hodgkiss" on Justia Law

Defendant was convicted in 2003 of producing, transporting, and reproducing child pornography and sentenced to 235 months in prison, followed by 5 years of supervised release. After defendant violated three conditions of supervised release, the district court imposed a new condition requiring polygraph testing.The Eighth Circuit affirmed the district court's imposition of the new condition, holding that defendant's unwillingness to obey rules restricting his access to child pornography shows that polygraph testing is necessary to protect the public from further crimes. The court also held that defendant waived any challenges to the district court's denial of his motions for relief in Appeal No. 19-3362. View "United States v. Smith" on Justia Law

The Eighth Circuit affirmed the district court's decision to modify defendant's two conditions of supervised release imposed after he was convicted in 2003 of producing, transporting, and reproducing child pornography. The court held that, although the district court erred by denying defendant a hearing before modifying Conditions 6 and 7, the error was harmless. In this case, Condition 6 concerned defendant's contact with minors and Condition 7 concerned possession and access to pornography. View "United States v. Smith" on Justia Law

The Eighth Circuit affirmed the district court's reduction of defendant's sentence pursuant to the First Step Act. The court held that the district court accurately noted that the sentence sought to be reduced was a substantial downward variance from the applicable guideline range and concluded the initial variance had eliminated excessiveness the First Step Act was intended to remedy. Furthermore, in evaluating the existing sentence, the district court also considered post-sentence rehabilitation and the 18 U.S.C. 3553(a) sentencing factors. The court also held that there was no procedural or legal error in defendant's 216 month sentence, and the district court did not abuse its substantial sentencing discretion or impose a substantively unreasonable sentence by declining to reduce defendant's sentence below 216 months imprisonment. View "United States v. Harris" on Justia Law

The Eighth Circuit affirmed the district court's reduction of defendant's sentence under 18 U.S.C. 3582(c)(2). The court held that there is no constitutionally protected liberty interest in a discretionary sentence reduction and thus the Due Process Clause does not afford procedural protections to those who seek one. Therefore, the court rejected defendant's claim that the district court should have held an evidentiary hearing before it ruled on his motion. The court also held that there is enough information on the record for meaningful appellate review where the district court quoted the eligibility report and described, among other things, that defendant was the leader of a large drug conspiracy and issued multiple threats to codefendants, an attorney, and a government agent in an attempt to obstruct the investigation against him. View "United States v. Alaniz" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for two counts of assaulting an intimate partner by strangling, one count of assault with a dangerous weapon, and one count of domestic assault by an habitual offender. Assuming without deciding that defendant did not waive his right to appeal the issue, the court held that defendant failed to show justifiable dissatisfaction with his attorney and the magistrate judge did not err in denying his request for substitute counsel.The court also held that the magistrate judge did not err by continuing the trial over defendant's objection and excluding the time from calculations under the Speedy Trial Act; the district court did not err by denying defendant's mid-trial request to proceed pro se; and the district court properly considered the 18 U.S.C. 3553(a) factors and did not abuse its discretion by imposing an within-Guidelines sentence. View "United States v. Harlan" on Justia Law

Plaintiff filed suit against several prison officials in their individual capacities under 42 U.S.C. 1983, challenging a disciplinary adjudication, conditions of confinement, adequacy of medical treatment, and alleged retaliatory acts. The district court denied motions to dismiss and for summary judgment.The Eighth Circuit held that officials were entitled to a ruling on their defense of qualified immunity as to the Eighth Amendment claims in Count II. Because the order granting the motion for reconsideration effectively denied the officials' motion to dismiss without ruling on qualified immunity, the court remanded the case for further proceedings to address the question of qualified immunity on Count II. As to the remaining claims, the court held that the district court did not abuse its discretion by determining that the officials failed to properly plead or carry their burden of proof as to any defenses of privileges and immunities. Accordingly, the court rejected the challenge to the order denying summary judgment on the remaining counts. View "Spann v. Lombardi" on Justia Law