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

Defendants House and Van Pelt appealed their sentences imposed after pleading guilty to numerous counts related to their participation in a large scale methamphetamine distribution scheme. The Eighth Circuit affirmed defendants' sentences, holding that the district court did not plainly err by conducting a 21 U.S.C. 851(b) inquiry. In this case, defendants failed to show that there was a reasonable probability that their sentences would be different if the district court had engaged in the section 851(b) colloquy. Nor did they show that their prior conviction was invalid or that their rights were otherwise affected.The court also held that House failed to show that any of the three purported Rule 11 errors affected his decision to plead guilty, and thus failed to satisfy the third prong of the plain error standard. Finally, the district court did not err by calculating the drug quantity attributable to Van Pelt, and by applying a leadership role enhancement to his sentence under USSG 3B1.1(c). View "United States v. House" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 alleging that five Iowa State Penitentiary (ISP) employees were deliberately indifferent to plaintiff's serious medical needs. While plaintiff was serving a life sentence at ISP, he suffered a serious hip injury from an assault by a fellow inmate.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants, holding that the district court did not abuse its discretion by failing to consider plaintiff's request for substitute appointed counsel. In this case, appointed counsel did not withdraw, and there was no request for substitute counsel. Furthermore, there was no basis in the summary judgment record to suspect that appointment of new counsel would affect the district court's decision. The court also held that there was no evidence in the record that the treating physician or any other medical provider or prison staff provided substandard care and no evidence that defendants ever acted in deliberate disregard of plaintiff's serious medical needs. View "Cejvanovic v. Ludwick" on Justia Law

The Eighth Circuit affirmed the district court's denial of a successive motion to vacate movant's sentence under 28 U.S.C. 2255. The court held that movant's prior convictions for Missouri second-degree assault convictions under Mo. Rev. Stat. Sec. 560.120 were violent felonies under the Armed Career Criminal Act's force clause. A conviction under section 560.120 that involved putting a victim in fear of immediate injury qualifies as a violent felony because it has as an element the threatened use of physical force against the person of another. View "Jones v. United States" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to distribution of methamphetamine. The court held that the district court did not err in determining that defendant's prior conviction for robbery in violation of Arkansas Code Annotation Section 5-12-102 was a crime of violence for purposes of career offender sentencing under USSG 4B1.1. The court held that Arkansas robbery has the same elements as the generic definition of robbery, which involves the use or threat of physical force upon another. View "United States v. Stovall" on Justia Law

The Eighth Circuit affirmed defendant's motion to suppress evidence after he pleaded guilty to possessing equipment having reasonable cause to believe it would be used to manufacture a controlled substance. The court held that the district court did not err in finding that a glass beaker was in plain view on defendant's deck, and the officer's lawful search was not tainted by a prior officer's earlier illegal entry. The court also held that defendant was not entitled to a Franks hearing because he failed to show that an officer seeking the warrant omitted information in reckless disregard of the truth. Furthermore, the district court properly rejected defendant's argument that the officer falsely stated that the beaker was in plain view. Finally, the court held that, under the totality of circumstances, the warrant application had sufficient information to establish probable cause. View "United States v. Reed" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to five counts of distribution of a controlled substance. The court held that the district court did not err by departing upward due to defendant's extensive criminal history in light of the seriousness of the crimes. Furthermore, the district court did not err by imposing an upward variance based on the seriousness of the instant offenses where the undisputed evidence established that defendant sold heroin on multiple occasions that contained fentanyl analogs unsafe for human consumption. Finally, the district court did not abuse its discretion by imposing a substantively unreasonable sentence. View "United States v. Edmonds" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to being a felon in knowing possession of firearms and ammunition. The court held that the district court did not clearly err by imposing a two-level sentencing increase for possession of three firearms under USSG 2K2.1(b)(1)(A). The court also held that the district court did not clearly err by declining to award a two-level reduction for acceptance of responsibility under USSG 3E1.1 after defendant frivolously contested that enhancement. Finally, the district court did not abuse its discretion by imposing a within-Guidelines sentence after considering the aggravating and mitigating factors, and declining to grant a downward variance. View "United States v. Goodson" on Justia Law

A passport card is "a United States passport" under USSG 2L2.1(b)(5)(A). The Eighth Circuit affirmed defendant's sentence for charges related to the unlawful acquisition and sale of identity documents. The court applied basic rules of statutory interpretation, including the ordinary-meaning rule, and agreed with the district court that defendant's possession of a passport card justified enhancing her sentence for fraudulently obtaining or using a United States passport under section 2L2.1(b)(5)(A). View "United States v. Torres" on Justia Law

The Eighth Circuit affirmed defendant's conviction of four counts of sexual abuse involving three young female relatives. The court held that the district court did not err in allowing the government to play video recordings of the victims' forensic interviews for the jury. In this case, defendant opened the door to the admission of one of the videos, defendant did not object to the admission of the other videos, and the admission did not affect his substantial rights where the videos were cumulative and the evidence of his guilt was strong overall. View "United States v. Lonnie Dale Spotted Bear" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to distribution of heroin to a person under the age of twenty-one. The court held that the district court did not abuse its discretion by departing upward, in light of the applicable policy statements and USSG 5K2.1, because death resulted from the offense of conviction. In this case, the district court found defendant's conduct most akin to involuntary manslaughter, and sentenced him to the maximum punishment available under the federal involuntary manslaughter statute. The district court noted defendant's youth and acknowledged the hardship of addiction during adolescence, but reasonably concluded that other factors such as the seriousness of the offense and the need for deterrence warranted a longer sentence than what defendant proposed. View "United States v. Reif" on Justia Law