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

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to making a false statement to the firearms dealer. The court held that the district court's explanation of why it varied significantly upward, though perhaps testing brevity's acceptable limits, was sufficient. In this case, the district court showed that it had considered the 18 U.S.C. 3553(a) factors, defendant's memorandum, and mitigating factors. Therefore, the court held that the sentence was not substantively unreasonable in light of the uncharged conduct and the danger he posed to the community. View "United States v. Anderson" on Justia Law

The Eighth Circuit reversed a commitment order under 18 U.S.C. 4246, which authorizes commitment proceedings for prisoners whose sentences are about to expire. In this case, due to an error in calculating defendant's release date, the government did not begin the commitment process until months after defendant's sentence had already expired. Therefore, the court held that a necessary condition for his commitment was missing. View "United States v. Clark" 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 previously convicted felon. The court held that defendant's prior conviction for first degree aggravated robbery under Minnesota Statutes 609.245 was a crime of violence under the sentencing guidelines, resulting in a base offense level of 20.The Supreme Court's decision in Stokeling v. United States, 139 S. Ct. 544 (2019), held that the term "physical force" in 18 U.S.C. 924(e)(2)(B)(i) includes the amount of force necessary to overcome a victim's resistance. The court held that Stokeling reinforced its precedent and was consistent with United States v. Libby, 880 F.3d 1011 (8th Cir. 2018), which concluded that first degree aggravated robbery in Minnesota has as an element a threatened use of violent force. View "United States v. Robinson" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate his sentence under 28 U.S.C. 2255, holding that his prior conviction for Indiana burglary was a violent felony under the Armed Career Criminal Act. The court agreed with the Seventh Circuit and held that the definition of burglary in Indiana law is nearly identical to that of generic burglary. View "Faulkner v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate his sentence, holding that his prior Minnesota conviction for simple robbery is a violent felony under the force clause of the Armed Career Criminal Act. Therefore, the district court properly sentenced petitioner to the minimum 180 months in prison as an armed career criminal. View "Taylor v. United States" on Justia Law

The Eighth Circuit affirmed defendant's conviction for conspiracy to distribute and possess with intent to distribute a controlled substance, possession with intent to distribute a controlled substance, and possession of a firearm in furtherance of a drug trafficking crime. The court held that the district court did not abuse its discretion by admitting evidence of firearms in defendant's home because the evidence was probative of the charged drug offenses and was not unfairly prejudicial. The court also held that challenges to the statements made by four potential jurors were not raised during voir dire or after the jury was selected. In this case, the impartiality of the jurors who were seated was adequately supported by the record. View "United States v. Medrano" on Justia Law

Defendant moved to vacate his convictions under 28 U.S.C. 2255, arguing that they were unconstitutional in light of Johnson v. United States, 135 S. Ct. 2551 (2015). The Eighth Circuit affirmed the district court's denial of defendant's motion to vacate his convictions under 28 U.S.C. 2255, and held that his conviction for bank robbery and carjacking both qualified as a crime of violence under 18 U.S.C. 924(c)(3)(A). Furthermore, defendant's convictions and sentences under section 924(c)(1)(A) for using a firearm during and in relation to those crimes were not unconstitutional. View "Estell v. United States" on Justia Law

Defendant appealed his sentence after pleading guilty to being a felon in possession of a firearm. The Eighth Circuit dismissed defendant's appeal, holding that defendant's attempt to contest a sentencing enhancement unrelated to criminal history fell within the plain language of the appeal waiver. The court also held that defendant's waiver was knowing and voluntary where he signed the plea waiver of his own volition and heard the district court read it aloud. Finally, the court rejected defendant's argument that the agreement was void for lack of consideration and held that the mere misapplication of the Guidelines does not render the enforcement of an appeal waiver a miscarriage of justice. View "United States v. Guice" on Justia Law

The Eighth Circuit affirmed defendant's conviction for murder in furtherance of a drug trafficking conspiracy and other related charges. The court held that the district court did not err by admitting evidence of defendant's prior conviction and supervised release status; the district court did not plainly err by admitting a lab report without the analyst's testimony because defendant's substantial rights were not affected in light of the other evidence; the district court's finding that Lorie Ortiz was a coconspirator was neither an abuse of discretion nor clear error; there was no error in admitting a witness's testimony about being motivated to cooperate by someone else's cooperation; and defendant's counsel agreed to swap the juror at issue with the alternate juror and thus the juror substitution claim failed. View "United States v. Torrez" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for possession with intent to distribute cocaine and marijuana, possession of a firearm in relation to a drug trafficking crime, and being a felon in possession of a firearm. The court held that the district court did not abuse its discretion by permitting drug trafficking testimony from a police officer based on the specialist's experience and training; the evidence was sufficient to convict defendant of the second and third counts; the district court did not err by sentencing defendant as an armed career criminal based on his three prior convictions for selling cocaine; the sale of a controlled substance in violation of a Missouri statute is a controlled substance violation under the Armed Career Criminal Act; and defendant's sentence did not violate the Eighth Amendment. View "United States v. McDaniel" on Justia Law