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

A jury found Arjune Ahmed guilty of two counts of kidnapping under 18 U.S.C. § 1201(a)(1). The charges stemmed from incidents involving two women, O.B. and A.J. O.B. reported being forcibly taken from a casino in Sioux City, Iowa, to South Sioux City, Nebraska, where she was sexually assaulted. DNA evidence linked Ahmed to the crime. A.J. reported a similar incident where she was taken to a park and sexually assaulted. Ahmed's DNA was also found at the scene of A.J.'s assault.The United States District Court for the Northern District of Iowa denied Ahmed's motion to sever the counts into separate trials, arguing that a single trial would prejudice him. The court also allowed the introduction of evidence of a prior similar offense committed by Ahmed. Ahmed was convicted and sentenced to 480 months' imprisonment. He appealed, challenging the denial of his motion to sever, the admission of prior offense evidence, the sufficiency of the evidence, and the consideration of uncharged conduct at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that severance was not required because evidence of each kidnapping would have been admissible in separate trials under Federal Rule of Evidence 413, which allows evidence of prior sexual assaults to show propensity. The court also found that the district court did not err in admitting evidence of a prior sexual assault under Rule 413 and that the evidence was not unfairly prejudicial under Rule 403.The appellate court affirmed the district court's denial of Ahmed's motion for judgment of acquittal, finding the evidence sufficient to support the convictions. The court also upheld the district court's consideration of uncharged conduct at sentencing, noting that current law permits such consideration. Finally, the court found no clear error in the district court's findings regarding additional sexual assaults by Ahmed. The Eighth Circuit affirmed the district court's judgment. View "United States v. Ahmed" on Justia Law

Joseph Garner pleaded guilty to Receipt/Distribution of Child Pornography, acknowledging a statutory five-year mandatory minimum sentence, which could increase to fifteen years if he had a prior conviction for certain sexual offenses. The government dismissed a second count of Attempted Production of Child Pornography. Garner's Presentence Investigation Report (PSR) noted a 2015 Texas conviction for Indecency with a Child, which the PSR determined qualified as a predicate offense under 18 U.S.C. § 2252(b)(1). Garner objected to this enhancement.The United States District Court for the Eastern District of Arkansas overruled Garner's objection, referencing the Eighth Circuit's decision in United States v. Sonnenberg. The court adopted the PSR without change, determining an advisory guidelines range of 135 to 168 months, adjusted to 180 to 188 months due to the enhanced statutory minimum. Garner was sentenced to 240 months followed by a lifetime of supervised release. Garner appealed, arguing that his Texas conviction should not trigger the fifteen-year mandatory minimum.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation and application of statutory sentencing provisions de novo. The court employed the categorical approach, examining whether the Texas statute criminalized conduct that qualifies for the enhancement. The court referenced prior decisions, including United States v. Weis and Sonnenberg, which interpreted similar statutes. The Eighth Circuit concluded that Garner's Texas conviction for indecent exposure with a child categorically related to abusive sexual conduct involving a minor, affirming the district court's judgment. The court denied the government's motion to dismiss the appeal and Garner's motion to file a pro se supplemental brief. View "United States v. Garner" on Justia Law

Rodrigo Castillo pleaded guilty to conspiracy to distribute and possess with intent to distribute 500 grams or more of methamphetamine. The district court, adopting the Presentence Investigation Report (PSR), determined Castillo’s advisory guidelines sentencing range to be 135 to 168 months and sentenced him to 140 months imprisonment followed by five years of supervised release. Castillo’s co-defendant, Roberto Nava, received a 120-month sentence under a binding plea agreement. Castillo appealed, arguing that the 20-month disparity between his and Nava’s sentences created an unwarranted sentencing disparity, making his sentence procedurally and substantively unreasonable.The United States District Court for the District of Nebraska accepted Castillo’s guilty plea and sentenced him based on the PSR’s recommendations. Castillo objected to the PSR’s base offense level calculation and the two-level increase for the importation of methamphetamine but withdrew these objections at sentencing. He also moved for a downward variance to match Nava’s 120-month sentence, which the court denied, citing the seriousness of Castillo’s offense and the differences in the co-defendants' conduct and plea agreements.The United States Court of Appeals for the Eighth Circuit reviewed Castillo’s appeal, applying a deferential abuse-of-discretion standard. The court found no procedural error, noting that the district court had considered the sentencing disparity and the relevant 18 U.S.C. § 3553(a) factors. The court also held that Castillo’s sentence was substantively reasonable, given the legitimate distinctions between the co-defendants and the presumption of reasonableness for within-guidelines sentences. The Eighth Circuit affirmed the district court’s judgment, upholding Castillo’s 140-month sentence. View "United States v. Castillo" on Justia Law

The case involves a criminal prosecution for a murder in Indian country. Francisco Villanueva and Adan Corona were convicted of first-degree murder and other offenses related to the killing of Vincent Von Brewer III, who owed money to members of the Eastside Oldies gang. Villanueva organized a group, including Corona and Estevan Baquera, to collect the debt. They confronted Brewer at a community center in Pine Ridge, South Dakota, where Villanueva and Corona fatally shot him. Baquera, who acted as an accessory after the fact, helped disguise a getaway car.The United States District Court for the District of South Dakota convicted Villanueva and Corona on all counts, sentencing them to life imprisonment. Baquera pleaded guilty to being an accessory after the fact and received the statutory maximum sentence of 180 months, which was an upward variance from the advisory guideline range of 78 to 97 months. The district court found that Baquera pointed a firearm at the crowd to protect the gang members during the attack.The United States Court of Appeals for the Eighth Circuit reviewed the case. Villanueva challenged the admissibility of an eyewitness identification and the exclusion of a defense expert's testimony. The court found no reversible error, ruling that the identification was not arranged by law enforcement and that the exclusion of the expert's testimony was consistent with precedent. Corona contested the denial of his motion to suppress statements made during a traffic stop, but the court held that the Miranda warnings were not required during the initial detention. Baquera appealed his sentence, arguing it was based on erroneous facts and was unreasonable. The court found no clear error in the district court's findings and upheld the sentence as reasonable.The Eighth Circuit affirmed the judgments of the district court for all three defendants. View "United States v. Villanueva" on Justia Law

Drew Clark committed a series of crimes on May 26, 2021, including three car thefts, home invasions, and brandishing a stolen firearm. He was convicted by a jury of possessing a stolen firearm, three counts of carjacking, and three counts of brandishing a firearm during the carjackings. The district court sentenced him to 339 months in prison. Clark appealed his conviction on two carjacking and associated brandishing charges.The United States District Court for the Eastern District of Missouri initially reviewed the case. At trial, Clark moved for judgment of acquittal on all counts, which the district court denied. After the jury convicted Clark on all counts, the court considered supplemental briefs regarding two specific counts and denied Clark’s motion for acquittal in a written post-trial order.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the jury’s verdict, concluding that the evidence was sufficient for a reasonable jury to find Clark guilty beyond a reasonable doubt. The court found that Clark’s actions during the carjackings, including brandishing a firearm to gain control of the vehicles, met the legal requirements for carjacking and brandishing charges. The court distinguished this case from others by noting that Clark’s use of force was necessary to complete the carjackings. The court also found that Clark’s intent to cause harm was evident from his actions, even if he did not explicitly threaten to kill or seriously harm the victims. The judgment of the district court was affirmed. View "United States v. Clark" on Justia Law

Descart Begay, Jr. was convicted by a jury of sexual abuse and aggravated sexual abuse of S.S., a former coworker. After reconnecting via Facebook, Begay visited S.S. at her home on the Red Lake reservation in Minnesota. During his visit, he forcibly raped her twice, once in her bedroom and again near the front door as she tried to escape with her son. S.S. managed to flee and reported the incident to her mother and the police. Begay was arrested shortly after attempting to hide from the officers.The United States District Court for the District of Minnesota conducted a five-day trial, after which the jury found Begay guilty of two counts each of sexual abuse and aggravated sexual abuse. The district court sentenced him to 200 months in prison. Begay appealed, challenging the evidence presented at trial and the sentence imposed.The United States Court of Appeals for the Eighth Circuit reviewed the case. Begay argued that the jury heard too much from the government and too little from him, particularly objecting to the admission of S.S.'s prior consistent statements. The court found that these statements were admissible under Federal Rule of Evidence 801(d)(1)(B) to rebut charges of recent fabrication and to rehabilitate S.S.'s credibility. The court also addressed Begay's claim that his Sixth Amendment rights were violated by limiting cross-examination about S.S.'s sexual history, concluding that any error was harmless given the overwhelming evidence of guilt.Regarding sentencing, the court upheld the district court's application of enhancements for causing serious bodily injury and physically restraining the victim. The court found that S.S.'s lasting psychological damage justified the serious bodily injury enhancement and that the physical restraint enhancement did not constitute double counting.The Eighth Circuit affirmed the judgment of the district court. View "U.S. v. Begay" on Justia Law

Christian Carrillo Topete was convicted of possessing child pornography, with some images involving minors under 12 years old. The key issue was whether his prior conviction for assault with intent to commit sexual abuse under Iowa law triggered a mandatory minimum sentence of ten years under federal law, which applies if the prior conviction "relates to sexual abuse."The United States District Court for the Northern District of Iowa reviewed Carrillo Topete's criminal history and determined that his prior conviction did indeed relate to sexual abuse. Consequently, the court sentenced him to the mandatory minimum of ten years in prison, which was three years more than he would have received without the prior conviction.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court applied the categorical approach, focusing on the statutory definition of the prior offense rather than the specific facts of the case. The court found that the Iowa statute for assault with intent to commit sexual abuse fits within the federal definition of sexual abuse, which includes physical or nonphysical misuse or maltreatment for sexual gratification. The court also noted that the phrase "relating to" in the federal statute allows for a broader interpretation, encompassing a wider range of prior convictions.The Eighth Circuit affirmed the district court's judgment, holding that Carrillo Topete's prior conviction for assault with intent to commit sexual abuse under Iowa law qualifies as a conviction relating to sexual abuse under federal law, thereby justifying the ten-year mandatory minimum sentence. View "United States v. Topete" on Justia Law

While patrolling Interstate 40 in Lonoke County, Arkansas, State Police Corporal Travis May stopped Tommy Collier for drifting into the shoulder. May noticed Collier's shaking hands, a disorderly car interior, and an unusual travel itinerary, which aroused his suspicion. Collier, a resident of Mississippi, was driving a car rented in Las Vegas with a Utah license plate. After Collier declined a search request, May called a K-9 unit. The drug-detection dog, Raptor, alerted to the presence of drugs, leading to a search that uncovered ten bundles of cocaine. Collier was arrested and later indicted for unlawful possession of cocaine with intent to distribute.The United States District Court for the Eastern District of Arkansas conducted the trial, where Collier was found guilty by a jury. The court imposed a statutory minimum sentence of ten years' imprisonment. Collier appealed, raising several issues, including the reliability of the drug-detection dog, the admission of expert testimony, the standard for a motion to suppress, and the adequacy of Rule 16(a) disclosures.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's judgment on all issues. It held that the drug-detection dog, Raptor, was reliable and that its alert provided probable cause for the search. The court also found no abuse of discretion in admitting expert testimony from Major Roby Rhoads and Senior Forensic Chemist Dan Hedges. The court rejected Collier's argument regarding the standard for a motion to suppress, stating that the district court's evaluation for reasonableness was appropriate. Additionally, the court found no prejudice in the government's Rule 16(a) disclosures and upheld the district court's denial of Collier's motion for a judgment of acquittal based on the cocaine isomer defense. Finally, the court ruled that a curative instruction was sufficient to address the government's brief comment on Collier's post-Miranda silence, and there was no plain error in the instruction given. The judgment of the district court was affirmed. View "United States v. Collier" on Justia Law

Anthony Fisher, while burglarizing a home, encountered the homeowner and shot him multiple times. Fisher, a felon at the time, was charged by the federal government with unlawful possession of ammunition under 18 U.S.C. § 922(g)(1). The jury found Fisher guilty. On appeal, Fisher argued that he lacked knowledge of his prohibited status when he possessed the ammunition, relying on the Supreme Court's decision in Rehaif v. United States.The United States District Court for the Northern District of Iowa oversaw the trial. Fisher contended that he did not know he was a felon when he possessed the ammunition. The jury, however, found sufficient evidence to convict him. Fisher was sentenced to 120 months in prison, the statutory maximum, despite the Sentencing Guidelines suggesting a longer term.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court examined whether the evidence supported the jury's finding that Fisher knew of his felon status when he possessed the ammunition. The court noted that Fisher had pleaded guilty to an Iowa felony in 2020, signed documents acknowledging his felony status, and had a probation agreement that explicitly stated his crime was a felony. Additionally, Fisher's probation officer testified that his felony status affected his employment opportunities. The court concluded that a reasonable jury could find that Fisher knew he was a felon based on this evidence.The Eighth Circuit affirmed the district court's judgment, holding that the evidence sufficiently supported the jury's finding that Fisher knew of his prohibited status when he possessed the ammunition. View "United States v. Fisher" on Justia Law

Marcus Millsap was convicted by a jury of conspiracy to violate the Racketeer Influenced and Corrupt Organizations Act (RICO), aiding and abetting attempted murder in aid of racketeering, and conspiracy to distribute and possess with intent to distribute 500 grams or more of methamphetamine. Millsap was involved with the New Aryan Empire, a white-supremacist organization engaged in drug trafficking. He assisted the organization's president, Wesley Gullett, in drug operations and attempted to retaliate against Bruce Hurley, a police informant, by offering money to have him killed. Gullett attempted to kill Hurley but failed, and Hurley was later murdered by an unknown perpetrator.The United States District Court for the Eastern District of Arkansas sentenced Millsap to life imprisonment. Millsap appealed, arguing that his indictment should have been dismissed due to a violation of the Interstate Agreement on Detainers Act, and that the district court made several errors regarding evidentiary issues and juror intimidation. He also challenged his sentence if the convictions were upheld.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the Interstate Agreement on Detainers Act did not apply because Millsap was transferred to federal custody via a writ of habeas corpus ad prosequendum before a detainer was lodged. The court also held that there was no sufficient showing of juror intimidation to justify a mistrial. The court found the evidence sufficient to support Millsap's convictions on all counts, including his association with the drug-trafficking enterprise and his involvement in the attempted murder of Hurley.The court also ruled that the district court did not err in admitting co-conspirator statements and other evidence, and that any potential errors were harmless. The court upheld the district court's application of sentencing enhancements and the calculation of Millsap's criminal history points. Consequently, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Millsap" on Justia Law