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

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of the methamphetamine that an investigator found in defendant's luggage on an Amtrak train. The court held that the district court did not err in finding that the initial encounter with the investigator was consensual and did not constitute an unlawful seizure. Furthermore, the district court did not err in finding that defendant voluntarily consented to the search of his bag. View "United States v. Garcia" on Justia Law

The Eighth Circuit affirmed defendant's conviction and 120 month sentence of being a prohibited person in possession of a firearm and ammunition. The court affirmed the denial of defendant's motion to suppress evidence seized from his home where officers had a reasonable belief that defendant's girlfriend had apparent authority to consent to their entry into the house with her, and that entry to accompany the girlfriend while she collected her belongings to move elsewhere was directly related to the entry that defendant's grandmother authorized in her initial call for assistance; the district court did not abuse its discretion by admitting a jail recording of a telephone conversation between defendant and his girlfriend; the evidence was sufficient to support the jury's verdict; the district court did not abuse its discretion in considering the jail calls and grand jury testimony in finding that defendant was a habitual domestic abuser with a history of displaying weapons; the district court did not clearly err in finding that defendant was a habitual domestic abuser who had brandished firearms on multiple occasions; and the district court did not abuse its substantial sentencing discretion. View "United States v. Cross" on Justia Law

The Eighth Circuit affirmed the district court's order transferring defendant for criminal prosecution as an adult under 18 U.S.C. 5032. The court held that the district court did not abuse its discretion by deciding to transfer where the district court made specific findings with respect to each statutory factor. In this case, the juvenile's age, nature of the offenses, his role in the offenses, and his intellect and maturity weighed in favor of transfer. The court also held that it was not required to hold an evidentiary hearing where the district court accepted the magistrate judge's credibility findings and independently weighed the statutory factors. View "United States v. Juvenile Male" on Justia Law

The Eighth Circuit affirmed defendant's conviction for one count of receiving child pornography and one count of possessing child pornography. The court held that the district court properly admitted defendant's statements that he viewed child pornography; even if the evidence was admitted as prior bad acts, the evidence was relevant and showed that he acted knowingly; and the evidence was sufficient to convict defendant because the existence of thumbnails was sufficient to establish possession of child pornography. View "United States v. Moberg" on Justia Law

The Eighth Circuit vacated defendant's sentence and remanded for resentencing under the Armed Career Criminal Act (ACCA) after he pleaded guilty to being a felon in possession of a firearm. The court held that defendant's prior conviction under Minnesota law for simple robbery qualified as a violent felony for ACCA purposes because it required proof of the use, attempted use or threatened use of violent force. In this case, defendant had three simple robbery convictions and was subject to the enhanced sentence under the ACCA. View "United States v. Pettis" on Justia Law

The Eighth Circuit reversed the district court's grant of defendant's motion to suppress evidence found in his recreational vehicle (RV). The court held that the district court erred by finding that the search of the RV exceeded the scope of an otherwise valid search warrant. In this case, the officers were not objectively unreasonable in their belief that the RV fell within the warrant's authorization to search. The court explained that, although there was some evidence that the RV was being used as a temporary residence, the officers observed facts supporting their conclusion that it was a vehicle. View "United States v. Houck" on Justia Law

The Eighth Circuit affirmed the district court's denial of an 18 U.S.C. 3582(c)(2) sentence reduction based upon Sentencing Guidelines Amendment 782. Amendment 782, in most cases, retroactively reduced the drug quantity determination by two base offense levels. In this case, the district court found that defendant was held accountable for 40 kilograms of cocaine base at his initial sentencing. The court held that the district court properly declined defendant's invitation to revisit that finding and concluded that Amendment 782 did not affect his base offense level of 38. View "United States v. Rashad" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to being a felon in possession of a firearm. The court held that the district court did not abuse its discretion in applying an enhancement under USSG 2K2.1(a)(2) based on defendant's previous Missouri convictions for second-degree assault on a law enforcement officer; the district court did not abuse its discretion by applying an enhancement under 2K2.1(b)(1)(A) based on its finding that defendant possessed between three and seven firearms; any error in imposing an enhancement for defendant's 2009 conviction for assault on a police officer was harmless; and defendant's conviction for second degree burglary under Missouri law was not a qualifying predicate offense under the Armed Career Criminal Act. View "United States v. Goldsberry" on Justia Law

The Eighth Circuit affirmed the trial court's denial of defendant's motion to suppress evidence. The court held that the it was reasonable for officers to believe that defendant was a resident of the home; a protective sweep of the house was justified because the officers had information that defendant was armed; and the scope of the search was reasonable. The court also held that defendant was properly sentenced under the Armed Career Criminal Act because he had three qualifying predicate offenses: assault with a dangerous weapon on a peace officer, manufacturing methamphetamine, and possessing it with intent to distribute. View "United States v. Ford" on Justia Law

Petitioner challenged the district court's denial of his petition for habeas relief after he pleaded guilty to an accomplice to murder charge and was sentenced to life without the possibility of parole. The Eighth Circuit affirmed the district court's judgment and held that petitioner's counsel's initial performance was not deficient under Strickland v. Washington, where counsel's opposition to a state hospital evaluation that could be used against him was an acceptable strategic decision. Furthermore, petitioner failed to prove that counsel was deficient in failing to have a competency evaluation performed prior to the entry of the plea. The court held that, taken as a whole, the evidence was insufficient to establish a reasonable probability that petitioner would have been found incompetent to proceed. Therefore, petitioner could not establish that he was prejudiced by counsel's decisions. View "Camacho v. Kelley" on Justia Law