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

In the case before the United States Court of Appeals for the Eighth Circuit, Jesse and Dustin Sierra, convicted of various charges including kidnapping, interstate domestic violence, and aiding and abetting both offenses, respectively, appealed their convictions. Jesse Sierra challenged the district court’s decision to exclude evidence of the victim’s other traumatic experiences, arguing that it violated his Fifth and Sixth Amendment rights. He also argued that the government suppressed exculpatory or impeachment material, violating the Brady v. Maryland precedent. Dustin Sierra challenged the sufficiency of the evidence for his convictions and argued that his trial should have been severed from Jesse's trial due to the prejudicial nature of the testimony and evidence presented. The Court of Appeals affirmed the district court’s decisions, holding that the exclusion of the victim's other traumatic experiences did not violate Jesse's constitutional rights, and that no Brady violations had occurred. The court also found that the evidence against Dustin was sufficient for the convictions and that there was no severe prejudice warranting a separate trial. View "United States v. Jesse Sierra" on Justia Law

In this breach-of-contract dispute, the United States Court of Appeals for the Eighth Circuit upheld the decision of the District Court of Minnesota, which rejected Reach Companies, LLC's appeal for a new trial after a jury awarded $1,196,364 in damages to Newsert, LLC and David Serata. Reach Companies, a distributor of hand sanitizers, alleged that Newsert, a wholesaler of the same products, continued accepting late shipments despite delays and price fluctuations. Newsert countered that Reach failed to fulfill all but one of its purchase orders, causing Newsert to lose two customers. The court found that the purchase orders were unambiguous with respect to their terms, rejecting Reach’s argument that the "must ship by" dates were simply aspirational. The court also held that the evidence presented at trial was sufficient to prove Newsert's lost profits with reasonable certainty, dismissing Reach's argument that the losses were speculative and didn't account for overhead. Lastly, the court allowed the admission of evidence of prior criminal convictions of Reach’s Vice President for impeachment purposes, as the crimes involved fraud and deceit and were thus relevant to the issues in the case. View "Reach Companies, LLC v. Newsert, LLC" on Justia Law

In this case, Tony Doolin was sentenced to 60 months of imprisonment and four years of supervised release for distribution of crack cocaine. After his release, Doolin lived in Iowa and possessed a medical-marijuana card, which permitted him to obtain medical marijuana under Iowa law. However, his supervised release was revoked due to his ongoing marijuana use and his distribution of medical marijuana to his girlfriend. Doolin appealed this decision, arguing that it violated the Appropriations Clause of the United States Constitution, due to the Consolidated Appropriations Act (CAA) of 2023. This act prohibits the Department of Justice (DOJ) from using funds to prevent states from implementing their own medical marijuana laws.The United States Court of Appeals for the Eighth Circuit affirmed the decision of the District Court for the Northern District of Iowa, holding that the revocation of Doolin's supervised release did not violate the Appropriations Clause or the CAA of 2023. The court noted that marijuana possession remains illegal under federal law, regardless of any state laws or limits on prosecutorial funding. Federal courts are required to impose a prohibition on a defendant’s unlawful possession or use of all controlled substances, including marijuana, as a condition of any term of supervised release. Even if section 531 of the CAA prohibits the DOJ from funding marijuana-related prosecutions or revocations, where doing so prevents a state from implementing its medical marijuana laws, the district court did not abuse its discretion in revoking Doolin’s supervised release. Doolin engaged in unlawful conduct, even under Iowa’s medical-marijuana regime, as private distribution of marijuana is illegal under Iowa law, as is smoking marijuana, even for medical purposes. Therefore, the court found that the revocation of Doolin's supervised release was not prohibited by the CAA, and the district court did not abuse its discretion in revoking Doolin's supervised release. View "United States v. Doolin" on Justia Law

In the case before the United States Court of Appeals for the Eighth Circuit, the defendant Mary Linnell appealed her conviction for possession with intent to distribute a controlled substance. The case arose after a traffic stop during which law enforcement officers found methamphetamine, cocaine, and drug paraphernalia in the vehicle in which she was a passenger. Linnell moved to suppress the evidence, arguing that the patrol officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The district court denied the motion, and Linnell entered a conditional guilty plea, preserving her right to appeal the suppression ruling. She was sentenced to 92 months’ imprisonment with 5 years of supervised release to follow.On appeal, Linnell contended that the district court erred in denying her motion to suppress, asserting that the officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The appellate court disagreed, ruling that the district court did not clearly err in finding that the officer observed three traffic violations (running a stop sign, following another vehicle too closely, and speeding), and therefore had probable cause to conduct the traffic stop. The court gave deference to the lower court's credibility determination of the officer's testimony, noting that the officer had several years of experience and had been involved in hundreds of traffic stops. The judgment of the district court was affirmed. View "United States v. Linnell" on Justia Law

In the case before the United States Court of Appeals for the Eighth Circuit, the defendant, Donavan Jay White Owl, appealed an order of the district court denying his motion to dismiss an indictment based on the Double Jeopardy Clause. White Owl had been indicted for felony murder and arson within Indian Country. A mistrial was declared during the initial trial after a dispute over White Owl’s access to information about a prosecution witness. White Owl argued that a new trial would violate his rights under the Double Jeopardy Clause of the Constitution.The Appeals Court, however, ruled that White Owl had impliedly consented to the mistrial. The court noted that while the defendant did not expressly request a mistrial, his actions and responses during the proceedings indicated his implicit agreement. Specifically, when the district court declared its intention to declare a mistrial and asked the parties for their views, White Owl did not object but instead emphasized the need for more time to prepare for cross-examination of a prosecution witness.In light of this, the court concluded that White Owl's lack of objection amounted to implied consent to a mistrial. Accordingly, the court affirmed the district court's order denying White Owl's motion to dismiss the indictment based on the Double Jeopardy Clause. View "United States v. Donavan White Owl" on Justia Law

Kenneth Blair was convicted by a jury of possessing with intent to distribute and distributing methamphetamine, and was sentenced to 292 months in prison. Blair appealed the conviction to the United States Court of Appeals for the Eighth Circuit, arguing against the denial of two pre-trial motions, refusal to acquit him on both counts, and the calculation of drug quantities for sentencing. Blair's main argument against his conviction was that the evidence against him was insufficient. However, the court found that there was ample evidence linking him to the possession and distribution of meth, including the fact that he was found with marked buy money and drugs at an apartment linked to him. The court stated that the jury could reasonably conclude that Blair had dominion over the apartment and the drugs within it. The court also dismissed Blair's claims against the calculation of drug quantities for sentencing. Blair argued that the court should not have relied on testimony from a confidential informant and a cooperating witness due to their unreliability. However, the court held that it was within the district court's discretion to credit their testimony. The court therefore affirmed Blair's conviction and sentence. View "United States v. Blair" on Justia Law

In this case heard by the United States Court of Appeals for the Eighth Circuit, the appellant, Timothy Eugene Angel, appealed against his sentence for possessing ammunition after having been convicted of a felony. Angel had pleaded guilty to the charge but disagreed with the district court's application of the attempted murder cross-reference from the United States Sentencing Guidelines (USSG) in determining his offense level and consequent sentence. The dispute stemmed from an incident where Angel fired shots at two individuals, Leonard Fisher and Tityana Woodland, outside a club in Davenport, Iowa, after a heated altercation inside the club.The court found that the district court did not err in applying the attempted murder cross-reference. It based this decision on the premise that Angel, by firing five shots at Fisher and Woodland, demonstrated a specific intent to kill. Moreover, the court also found that Angel had enough time after the altercation to be fully conscious of his intent and deliberate about his conduct, thereby satisfying the requirement for premeditation.Angel raised a self-defense argument, contending that he fired his gun in response to Woodland threatening him with a gun. However, the court rejected this argument, finding that Angel had escalated the situation by choosing to leave the club, retrieve a gun, and open fire. Consequently, the court affirmed the judgment of the district court, upholding Angel's sentence. View "United States v. Angel" on Justia Law

This case involves an appeal from the United States District Court for the District of South Dakota filed by the defendant, Nathaniel Crawford. Crawford was involved in a domestic dispute with his ex-girlfriend at an apartment complex, which led to concerned residents calling 911, reporting that Crawford was threatening to shoot a person or burn the complex. After officers arrived at the scene, Crawford fled but returned later to threaten his ex-girlfriend with a firearm. He fled again before officers could arrive; however, they found him and his vehicle in a nearby parking lot. Officers identified a wooden object protruding from the vehicle's center console, which they inferred to be a firearm. Crawford was subsequently charged with being a prohibited person in possession of a firearm due to his prior felony and misdemeanor domestic violence convictions.Crawford moved to suppress the firearm, arguing that officers lacked probable cause to search his vehicle. The district court denied his motion, leading to Crawford's appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision, agreeing that the 911 calls, the ex-girlfriend's statements, and the wooden object established probable cause for the vehicle search. The court ruled that the officers' search was supported by probable cause based on the combination of these factors, establishing probable cause to search Crawford's vehicle for a firearm. The court also rejected Crawford's arguments that the search was unreasonable due to the officers' original investigation of him for a different crime and their lack of knowledge about his status as a prohibited person under federal law. The court maintained that the government can search for evidence of one crime and charge the suspect with a different crime based on what it later learns. The court concluded that the "fruit of the poisonous tree" was admissible because the tree in this case was not poisonous. View "United States v. Crawford" on Justia Law

In this case heard before the United States Court of Appeals for the Eighth Circuit, the appellant, Dewanis Rogers, sought a reduced sentence under the First Step Act of 2018. Rogers had been found guilty in 2008 of conspiracy to distribute 50 grams or more of cocaine within 1,000 feet of a protected location, following two or more prior felony drug convictions. He received a mandatory sentence of life imprisonment, as prescribed by statute. In 2022, Rogers requested that his sentence be reduced under the provisions of the First Step Act. The district court denied this motion, determining that Rogers was ineligible for relief under the Act. Rogers appealed this decision, disputing his ineligibility.Upon review, the United States Court of Appeals for the Eighth Circuit held that even if Rogers was eligible for relief under the First Step Act, the district court could not have lawfully reduced his sentence due to the mandatory term of imprisonment prescribed by statute. The court explained that Congress had not expressly repealed the mandatory punishment for Rogers’s offense in the First Step Act, and that the change in law cited by Rogers did not appear in the sections of the Fair Sentencing Act of 2010 made retroactive by the First Step Act. Therefore, the court affirmed the district court's decision. View "United States v. Rogers" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered an appeal by several Missouri public officials who were denied qualified immunity by a lower court regarding five claims arising from a murder prosecution. The murder case, involving Donald Nash who was eventually convicted for the murder of Judy Spencer, was reopened in 2007, 25 years after the crime occurred. The officials based their case on a theory that DNA evidence found under Spencer's fingernails belonged to Nash, which they asserted could not have remained present if Spencer had washed her hair after their last encounter.Nash was convicted and spent 11 years in prison until the Missouri Supreme Court set aside his conviction in 2020. The charges were dismissed after DNA testing on the shoelace used to strangle Spencer supported Nash’s noninvolvement. Nash and his wife filed a lawsuit against the officials, claiming violations of rights including unlawful arrest and detention, fabrication of evidence, failure to investigate, violations of rights of access to courts, and violation of the right to familial and marital associations.The Eighth Circuit affirmed in part, reversed in part, and dismissed in part the appeals on the denial of qualified immunity. The court held that the officials were not entitled to qualified immunity on the claim of unlawful arrest and detention, finding that the omission of certain exculpatory facts from the probable cause affidavit negated probable cause for Nash's arrest. However, the court reversed the denial of qualified immunity for the claim alleging violation of the right to familial and marital associations, as this was not a clearly established constitutional right in 2008. The court dismissed the officials' appeal on the remaining claims due to lack of jurisdiction, as these involved genuine disputes of material fact to be resolved by a jury. View "Estate of Nash v. Folsom" on Justia Law