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

The case involves a defendant, Daryl Stephen Jones, III, who appealed his sentencing after pleading guilty to being a felon in possession of a firearm, which is a violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(8). Jones had absconded from a residential reentry facility where he was serving a previous sentence for possession of a firearm in furtherance of a drug-trafficking crime. He was arrested six months later in Des Moines, Iowa, with a loaded handgun and extra ammunition. The district court sentenced Jones to 84 months’ imprisonment with 3 years of supervised release, to be served consecutively to any term of imprisonment or supervised release imposed for the then-pending escape charge in the District of Kansas.In his appeal, Jones claimed procedural error and argued that the sentence was substantively unreasonable. The United States Court of Appeals for the Eighth Circuit, applying a deferential abuse-of-discretion standard, affirmed the sentence. The court found no clear error in the district court's application of a four-level sentencing enhancement for Jones' possession of a firearm in connection with the escape felony, as well as its calculation of two criminal-history points for Jones' 2013 controlled substance possession offense. The court also determined that because the district court was aware of its authority to depart downward based on the alleged overrepresentation of Jones' criminal history and there was no allegation of an unconstitutional motive, its decision not to depart was unreviewable. Lastly, the court found no abuse of discretion in the district court's determination that Jones' sentence was substantively reasonable, noting that a sentence within the Guidelines range is accorded a presumption of substantive reasonableness on appeal. View "United States v. Jones" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed the sentences of Theodore Browne and Karley Ann Smith, both of whom had pled guilty to conspiring to distribute 50 grams or more of methamphetamine. Browne claimed that the district court erred in determining that he transported 10 pounds of meth, which influenced his base offense level. However, the Appeals Court ruled that the district court's approximation of the drug quantity, based on witness testimonies, was not clearly erroneous. Browne also argued that the district court wrongly applied a 4-level role enhancement, contending that there was insufficient evidence to show he was an "organizer or leader" of the conspiracy. The Appeals Court disagreed, ruling that the district court's finding was not clearly erroneous based on witness testimonies. Smith argued that the district court abused its discretion by considering late-filed evidence in the government’s sentencing memorandum, which resulted in the imposition of an obstruction enhancement and the denial of an acceptance-of-responsibility reduction. The Appeals Court ruled that Smith had sufficient time to review and respond to the challenged exhibits, and that the district court did not err in finding obstruction of justice and rejecting the acceptance-of-responsibility reduction. View "United States v. Browne" on Justia Law

In the case before the United States Court of Appeals for the Eighth Circuit, defendants Antione Deandre Maxwell and Chavee E’Laun Harden were convicted of conspiracy to interfere with commerce by robbery. Maxwell was additionally convicted of being a felon in possession of a firearm. The defendants challenged the sufficiency of the evidence supporting their convictions, and Harden additionally argued that the district court erred in denying his motion to suppress evidence, in denying his request for an implicit bias instruction, and in calculating his sentencing range under the U.S. Sentencing Guidelines.The court affirmed the convictions due to overwhelming evidence of the defendants' involvement in the robbery, including their presence at the scene of the crime, their possession of stolen goods and firearms, and their actions before and after the robbery. The court also held that the district court correctly denied Harden's motion to suppress evidence, finding that the officers' entry into his home without a warrant was justified due to the exigent circumstances surrounding the presence of unattended children and the likely presence of an armed robbery suspect. The court also rejected Harden's request for an implicit bias instruction, stating that it was within the district court's discretion to decide how best to address the risk of racial bias. Finally, the court found no error in the district court’s calculation of Harden’s sentencing range, considering his role in the robbery, his perjury during trial, and his attempts to influence a witness to lie for him. View "United States v. Maxwell" on Justia Law

In this case, Michael Grady and Oscar Dillon, III were convicted of conspiracy to distribute and possession with intent to distribute cocaine and heroin, attempted obstruction of justice, and conspiracy to commit money laundering. They were sentenced to 226 and 187 months’ imprisonment, respectively, and each to 5 years of supervised release. The defendants appealed their convictions, arguing various issues including that their indictments should have been dismissed on Speedy Trial Act grounds, that there was insufficient evidence to support their convictions, and that the court erred in denying their motions to substitute counsel of their choice.The United States Court of Appeals for the Eighth Circuit affirmed the convictions. First, the court found no violation of the Speedy Trial Act, as the delays in the case were justified due to its complexity. Second, the court found that there was sufficient evidence to support the defendants' convictions for drug conspiracy, money laundering conspiracy, and attempted obstruction of justice. Finally, the court held that the trial court did not abuse its discretion in denying the defendants’ motions to substitute counsel of their choice. Specifically, the court found that the potential conflict of interest was unwaivable due to the attorney's previous representation of a key government witness in the case. Therefore, the court affirmed the convictions and sentences of the defendants. View "United States v. Grady" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit affirmed the district court's denial of Chad Betts's motion to suppress evidence obtained from a traffic stop. Betts, a felon, was found in possession of a firearm and ammunition after a drug dog alerted to his vehicle during a traffic stop. He appealed the district court's decision, arguing that reasonable suspicion did not exist to extend the traffic stop.The court found that the officer had reasonable suspicion to extend the stop based on a combination of factors: Betts’s quick speaking, profuse sweating, and rapid, shallow breathing; his possession of a torch-style lighter, which the officer knew was often used to heat drugs like methamphetamine; Betts’s unusual travel plans and his history of drug-related offenses. These factors, viewed as a whole, justified the officer's suspicion that Betts was in possession of illegal drugs by the time the officer left Betts seated in the patrol car and walked back to Betts’s vehicle to question the passenger. As a result, the court concluded that the extended stop was justified, and the district court correctly denied the motion to suppress the evidence obtained during this stop. View "United States v. Betts" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit examined an appeal by John Lee Ralston, who was charged with being a prohibited person in possession of a firearm after a search of his residence. The search was conducted under a warrant that was primarily issued based on criminal activity suspected of another person, Colton Varty, who was believed to be residing on the same piece of property but in a different residence. Ralston argued the warrant did not establish probable cause that evidence would be located inside his house.The district court had denied Ralston’s motion to suppress the evidence obtained from the search of his residence, ruling that even though the warrant lacked probable cause, the officers acted in good faith, relying on the Leon good-faith exception. On appeal, the Court of Appeals for the Eighth Circuit disagreed and reversed the district court's decision.The Court of Appeals held that the Leon good-faith exception did not apply in this case. The court found that the affidavit supporting the warrant was so lacking in evidence connecting Ralston and his residence to the suspected criminal activity of Varty that no reasonable officer would have relied upon a warrant that was issued based on it. The Court of Appeals concluded that without evidence that Varty had access to Ralston’s residence or facts pointing to a fair probability that Ralston’s residence contained stolen property or was being used to fence stolen property, the Leon good-faith exception could not apply. The Court of Appeals remanded the case to the district court with directions to vacate Ralston’s guilty plea and grant his motion to suppress. View "United States v. Ralston" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit upheld the conviction of William Goodman for distribution of fentanyl resulting in death and unlawfully possessing a firearm as a felon. Goodman appealed his conviction on the grounds that the district court improperly admitted hearsay testimony from the deceased user’s girlfriend and wrongly instructed the jury regarding Goodman’s prior convictions.The court rejected Goodman's first argument, ruling that his co-conspirator's statements, relayed through the girlfriend's testimony, fell under the co-conspirator exclusion under Rule 801(d)(2)(E) of the Federal Rules of Evidence as they were made during and in furtherance of a conspiracy to distribute drugs. The court also dismissed Goodman's second argument, finding that the expanded list of uses for evidence of Goodman's prior convictions under Rule 404(b) did not prejudice the defendant and thus did not warrant a new trial. The court affirmed the district court's judgment. View "United States v. Goodman" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit upheld a conviction against Richard Lee David Brown for possession with intent to distribute a controlled substance. Law enforcement found Brown in an apartment during the execution of a search warrant, along with drugs, drug paraphernalia, and a cell phone that Brown admitted was his. Brown appealed his conviction, alleging multiple pre-trial and trial-related errors. However, the court affirmed the conviction, rejecting Brown's claims that he was improperly denied a jury instruction regarding "mere presence," that the court erred in admitting evidence of his prior convictions, and that he received ineffective assistance of counsel, among other issues. The court held that the instructions given to the jury were adequate and that the evidence was sufficient to support the conviction. The court also found that Brown's claims of ineffective assistance were best left for a post-conviction relief proceeding, such as a motion under 28 U.S.C. § 2255. The court concluded that none of the alleged errors either individually or cumulatively warranted reversal of the conviction. View "United States v. Brown" on Justia Law

In this case heard by the United States Court of Appeals For the Eighth Circuit, the appellant, Tiano N. Trice, was appealing against a decision by the United States District Court for the Southern District of Iowa - Eastern. The dispute arose after Trice was arrested while on supervised release, leading to the revocation of his supervised release for domestic assault and child endangerment. Trice was sentenced to a 24-month imprisonment period, followed by 12 months of supervised release.In his appeal, Trice did not challenge the domestic assault violation but contested the child endangerment finding and the district court's factfinding and credibility determinations. The incident involved Trice and the mother of his children, Clareshanda Chamberlain, getting into a heated argument in the presence of their children, during which Trice lifted the bed Chamberlain was in and dropped it to the ground. The children, scared by the altercation, fled from the house or hid.The appellate court affirmed the district court's decision, stating that the district court's factual findings and credibility determinations were not erroneous. The court also rejected Trice's argument that hearing the assault, as opposed to actually seeing it, is insufficient to trigger child endangerment, stating that Iowa law does not make this distinction. The court concluded that Trice was aware his children were present during the assault on their mother, which constitutes child endangerment under Iowa law. Therefore, the district court did not err in finding that Trice committed child endangerment and did not abuse its discretion in revoking Trice's supervised release. The court affirmed the judgment of the lower court. View "United States v. Trice" on Justia Law

The United States Court of Appeals for the Eighth Circuit heard an appeal from Jacob Bermel, who had pleaded guilty to two child pornography offenses following the denial of his motion to suppress evidence that was found on a camera he had hidden in his daughter's bathroom. Bermel argued that the warrantless seizure and subsequent search of the camera and its memory card violated his Fourth Amendment rights. However, the district court found that the seizure was justified by exigent circumstances and that the search was lawful due to the daughter's consent.On appeal, Bermel made three arguments: (1) minor children cannot consent to a search of their parents' property, (2) even if minors can consent, his daughter lacked such authority, and (3) the district court erred in finding that his daughter had consented to the search of the camera and memory card.The Court of Appeals affirmed the district court's decision. It rejected Bermel's first argument, stating that there is no legal precedent for a per se rule that minors cannot consent to a search of their parents' property. The court also found that the daughter had apparent authority to consent to the search given her joint access and control over the camera and its memory card. Finally, the court determined that the daughter had indeed consented to the search of the camera and its memory card. The court noted that lack of verbal response did not negate consent and the scope of her consent reasonably extended to the camera's memory card. View "United States v. Bermel" on Justia Law