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

The Eighth Circuit affirmed the district court's denial of defendant's motion to withdraw his guilty plea. The court held that defendant failed to meet his burden of establishing a fair and just grounds for withdrawal and thus the district court did not abuse its discretion in denying his motion. In this case, the plea hearing transcript belies any contention that defendant did not knowingly and voluntarily enter his plea, the record contained no evidence that defendant's medication had an effect on his competency, and the timing of defendant's attempted withdrawal was after the presentencing report was prepared. View "United States v. Eller" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to possessing cocaine with intent to distribute and possessing a firearm in furtherance of a drug trafficking crime. The court held that the district court did not err, plain or otherwise, in applying a criminal offender enhancement under USSG 4B1.1(a).The court held that when a defendant has more than four prior sentences that could be counted, the plain language of the Guideline gives the district court discretion to choose among them. Because there is no ambiguity here, the court held that the rule of lenity is not applicable. View "United States v. Morris" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiring to distribute methamphetamine, money laundering, and two counts of conspiring to launder money. The court held that the evidence was sufficient to support defendant's convictions; the court was not convinced that the district court's drug-quantity finding was mistaken; and there was no error in imposing sentencing enhancements for defendant's role in the offense under USSG 3B1.1(a) and for committing the offense as a part of a pattern of criminal conduct engaged in as a livelihood under USSG 2D1.1(b)(15)(E). View "United States v. Sainz Navarrete" on Justia Law

The Eighth Circuit vacated the district court's denial of defendant's 28 U.S.C. 2255 motion to vacate his sentence on the ground that he received ineffective assistance of counsel during plea negotiations before trial. In this case, defendant alleged that his attorney's performance was constitutionally deficient because counsel advised defendant to decline a plea offer based on a sentencing enhancement that any reasonable counsel should have known was inapplicable. The court held that the record did not conclusively refute defendant's claim at this juncture in the proceedings. Furthermore, the question is not developed on the question of prejudice. Accordingly, the court remanded for further proceedings. View "Mayfield v. United States" on Justia Law

The Eighth Circuit affirmed defendant's sentence for conspiracy to distribute a controlled substance, and possession with intent to distribute a controlled substance. The court held that the district court did not violate defendant's Sixth Amendment right to counsel of choice by denying the motion to continue the trial and to substitute counsel. In this case, there was no evidence of a sudden exigency or unforeseen circumstances which would weigh in favor of continuing the trial. Furthermore, the last-minute nature of defendant's motion, without some compelling justification, undermines the district court's interest in the orderly administration of justice. The court also held that the evidence was sufficient to support defendant's convictions. View "United States v. Bradshaw" on Justia Law

The Eighth Circuit affirmed defendant's conviction for conspiring to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine. The court held that, even if the district court erroneously admitted evidence, the errors did not affect defendant's substantial rights as required by the plain-error standard because the evidence of his guilt was overwhelming. The court also held that the evidence was sufficient to support the jury's verdict. View "United States v. Loomis" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to possess with intent to distribute methamphetamine. The court held that the evidence was sufficient to support defendant's conviction; the district court's jury instructions did not constructively amend, or vary from, count one of the superseding indictment; the district court did not err in refusing to give buyer-seller and mere-presence instructions; the district court did not abuse its discretion by permitting the government to elicit testimony showing that defendant and his coconspirator knew one another when they were incarcerated in state prison and that the coconspirator helped defendant while the two were in prison; the district court did not err in applying the murder cross-reference under USSG 2D1.1(d)(1); and defendant's sentence was not substantively unreasonable. View "United States v. Shavers" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to vacate his sentence under 18 U.S.C. 117 for the crime of domestic assault by a habitual offender in Indian country. The court held that defendant's prior 2013 conviction under Bismarck Municipal Court for simple assault was for an offense which, if subject to federal jurisdiction, would qualify as an assault against an intimate partner under section 117(a)(1). Consequently, defendant cannot show that he is "actually innocent" of the offense to which he pleaded guilty, and his challenge to the sentence is procedurally defaulted. View "Silk v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence recovered during a traffic stop. The court held that the officer had reasonable suspicion based on several specific and interrelated facts to extend the stop. In this case, the officer saw an out-of-state truck with paper tags driving in the middle of the night; he discovered neither adult in the vehicle had a driver's license and the paper tags were expired; there was some confusion as to the name of the owner; the purported purpose for the trip was a two-to-three-day painting job, but no supplies were present other than one can of paint; he learned all of this after having his suspicion piqued by the fact that defendant and his partner gave different names; and he thought it unusual that an unlicensed driver would bring small children and an unlicensed partner/significant other with him for the midnight travel in the unlicensed vehicle for a short term out-of-state job.The court also held that, absent a physical trespass and during an otherwise lawfully extended stop, an officer may look at the undercarriage of a vehicle without probable cause. Finally, the officer had probable cause and had a legal basis for the subsequent seizure of the black plastic bag located above a spare tire. View "United States v. Sanchez" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of child pornography that FBI agents found on his phone. The court held that the warrant supported probable cause and the search of defendant's phone was valid. The court also affirmed defendant's sentencing, rejecting defendant's argument that the word "computer" in USSC 2G2.2(b)(6) is unconstitutionally vague. Finally, the court affirmed the district court's restitution order for nine of the victims. View "United States v. Green" on Justia Law