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

A homicide occurred in downtown Minneapolis on August 26, 2020, leading to protests and unrest. Leroy Williams Jr. was recorded on Facebook Live making incendiary comments and was later seen on surveillance footage participating in looting and attempting to ignite a cardboard box at the Target Headquarters. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) found no physical evidence of attempted arson. Williams was arrested and initially indicted for conspiracy to commit arson. He was conditionally released but violated terms, leading to his pretrial detention. Williams pleaded guilty to attempted arson but later withdrew his plea, leading to a trial where he was found guilty.The United States District Court for the District of Minnesota sentenced Williams to 120 months’ imprisonment, considering his criminal history, mental illness, substance abuse, and the serious nature of the offense. Williams objected, citing a sentencing disparity with his codefendants, who received lesser sentences despite causing more damage.The United States Court of Appeals for the Eighth Circuit reviewed the case. Williams argued insufficient evidence for his conviction, procedural error in sentencing, and substantive unreasonableness of his sentence. The court held that the evidence was sufficient for a reasonable jury to convict Williams, as his actions and statements supported the verdict. The court found no procedural error, as the district court adequately considered the sentencing factors and provided a reasoned basis for its decision. The court also found the sentence substantively reasonable, given the district court’s thorough consideration of the relevant factors.The Eighth Circuit affirmed the district court’s judgment, upholding Williams’s conviction and sentence. View "United States v. Williams" on Justia Law

In June 2017, an investigator from the Faulkner County Sheriff’s Office in Arkansas, posing as a 15-year-old named "Connor," responded to a Craigslist ad posted by Christopher Harcrow seeking young boys interested in spanking. After initially breaking off contact upon learning "Connor" was 15, Harcrow resumed communication 12 days later, discussing sexual activities and planning a meeting. When Harcrow arrived at the meeting location, he was arrested, and a search of his vehicle revealed personal lubricant purchased just before the meeting. Harcrow was charged with one count of enticement of a minor under 18 U.S.C. § 2422(b).The United States District Court for the Eastern District of Arkansas denied Harcrow's motion for judgment of acquittal and allowed the jury to consider the entrapment defense. The jury found Harcrow guilty, and he was sentenced to 120 months’ imprisonment followed by 10 years of supervised release. Harcrow appealed, arguing insufficient evidence, entrapment as a matter of law, a variance from the indictment, and denial of a fair trial due to a misstatement of law and inflammatory remarks by the prosecution.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that sufficient evidence supported the conviction, since Harcrow's communications and actions demonstrated intent to entice a minor for illegal sexual activity and constituted a substantial step toward committing the offense. The court found that Harcrow waived his entrapment argument and that there was no prejudicial variance from the indictment. Additionally, the court determined that the prosecution's remarks during closing arguments were based on reasonable inferences from the evidence and did not deprive Harcrow of a fair trial. The Eighth Circuit affirmed Harcrow’s conviction and sentence. View "U.S. v. Harcrow" on Justia Law

Anthony Unocic, while incarcerated in a Nebraska detention center, told two fellow inmates that he wanted to kill a federal agent named Tubbs who had investigated him. Unocic's threats were taken seriously by the inmates because he bragged about a previous violent standoff with police, demonstrated stabbing techniques, and mentioned using explosives. The inmates reported the threats to federal agents, leading to Unocic being charged with one count of threatening to assault a federal officer under 18 U.S.C. § 115(a)(1)(B) and (c)(1).Unocic pleaded not guilty, and the case went to trial in the United States District Court for the District of Nebraska. The district court instructed the jury on the elements required to convict Unocic, including that he either knew or intended that others would regard his communication as threatening violence, or recklessly disregarded a substantial risk that others could regard his communication as threatening violence. The jury found Unocic guilty, and he was sentenced to thirty-three months' imprisonment.On appeal to the United States Court of Appeals for the Eighth Circuit, Unocic argued that the district court erred by including the term "carelessly" in the definition of "recklessly disregards" in the jury instructions. He claimed this allowed the jury to convict him for speech protected by the First Amendment. The Eighth Circuit reviewed for plain error and concluded that, taken as a whole, the jury instructions did not mislead the jury to convict Unocic based on an incorrect standard. The court found no obvious error and affirmed the district court's judgment. View "United States v. Unocic" on Justia Law

Julian R. Bear Runner, an enrolled member of the Oglala Sioux Tribe (OST) and its President from December 2018 to December 2020, was convicted of wire fraud, larceny, and embezzlement and theft from an Indian Tribal Organization. He manipulated the Tribe’s travel policies to embezzle over $80,000, which he used for gambling at the Prairie Wind Casino. Bear Runner pressured travel specialists to approve fraudulent travel requests and never repaid the advance payments.The United States District Court for the District of South Dakota sentenced Bear Runner to 22 months in prison and ordered $82,484 in restitution. Bear Runner appealed, arguing that the government failed to prove the requisite criminal intents for his offenses and that the district court committed procedural and substantive errors in sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the jury’s verdict, stating that sufficient evidence supported the finding that Bear Runner intended to defraud, steal, and embezzle. The court noted that fraudulent intent could be inferred from the facts and circumstances surrounding Bear Runner’s actions, including his manipulation of the approval process and his failure to repay the funds.Regarding sentencing, the court found no procedural error, as Bear Runner did not accept responsibility for his actions. The court also found no substantive error, as the district court acted within its discretion in considering similarly situated defendants and determining that Bear Runner’s individual circumstances warranted a different outcome. The judgment of the district court was affirmed. View "United States v. Runner" on Justia Law

Jacqusyn Grubb was charged with unlawful possession of a firearm as an unlawful user of a controlled substance under 18 U.S.C. § 922(g)(3). Grubb moved to dismiss the indictment, arguing that the statute violated his Second Amendment rights, particularly as he was a user of marijuana, not a more dangerous controlled substance. The government contended that Grubb's challenge was premature due to undeveloped facts.The United States District Court for the Northern District of Iowa denied Grubb's motion to dismiss, ruling that the statute was constitutional on its face but held Grubb's as-applied challenge pending trial. The court rejected Grubb's request for an evidentiary hearing, stating it would amount to unauthorized discovery. Grubb then entered a conditional guilty plea, reserving his right to appeal the denial of his motion to dismiss. The district court later reconsidered and requested supplemental briefing but ultimately denied the motion to dismiss, concluding the statute was constitutional as applied to Grubb.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a trial on the merits was necessary to resolve Grubb's pretrial motion to dismiss the indictment. The court emphasized that there is no summary judgment procedure in federal criminal cases and that the government is not required to present all its evidence before trial. The court concluded that the district court should have deferred ruling on the as-applied challenge until trial. Consequently, the Eighth Circuit reversed the district court's order, vacated the judgment, and remanded the case for further proceedings, allowing Grubb to choose whether to adhere to his guilty plea or proceed to trial. View "United States v. Grubb" on Justia Law

Ashley Chacon pled guilty to possession with intent to distribute 50 grams or more of methamphetamine. Emiliano Nava Munoz and Valentin Nava Munoz pled guilty to conspiracy to distribute and distribution of 50 grams or more of methamphetamine. The district court sentenced Chacon to 60 months, Emiliano to 280 months, and Valentin to 180 months in prison. They appealed their sentences.The United States District Court for the Southern District of Iowa denied Chacon's motion to suppress evidence from a car search. Chacon argued that the traffic stop was impermissibly extended and that the drug-detection dog's contact with the car was an unlawful trespass. The district court found that the stop was not prolonged beyond the time reasonably required to complete the original purpose of the stop and that the dog's contact with the car did not violate the Fourth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the officer's questions during the traffic stop were ordinary inquiries and that the stop was not impermissibly extended. The court also held that the drug-detection dog's contact with the car did not violate the Fourth Amendment because the dog acted instinctively. The court affirmed the district court's denial of Chacon's motion to suppress.Emiliano challenged the enhancements to his sentence for maintaining drug premises and for his role as a manager or supervisor. The court found that Emiliano used his residence and another property for substantial drug-trafficking activities and that he had control over the premises. The court also found that Emiliano was a manager or supervisor of the criminal activity. Valentin challenged his role enhancement, but the court found that he directed transactions and recruited others into the offense. The court affirmed the sentences for Emiliano and Valentin. The judgments were affirmed. View "United States v. Munoz" on Justia Law

Armando Angel Cheshier was convicted of distributing a controlled substance resulting in serious bodily injury and possession of a controlled substance with intent to distribute. He was sentenced to 252 months for the first count and 240 months for the second and third counts, to run concurrently. Cheshier appealed his conviction, arguing that the district court erred in rejecting his guilty plea and in instructing the jury on intentional distribution of a controlled substance.The United States District Court for the District of South Dakota rejected Cheshier's guilty plea because he explicitly denied distributing fentanyl to the victim during the plea hearing. Cheshier also challenged the jury instructions, but the district court found that the instructions accurately reflected the law, including the requirement that the government prove he knowingly or intentionally distributed the controlled substance.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not plainly err in rejecting Cheshier's guilty plea, as he denied the factual basis for the plea. The appellate court also found that the district court did not abuse its discretion in instructing the jury, as the instructions were a correct statement of the law. Additionally, the court determined that there was sufficient evidence for a reasonable jury to conclude that Cheshier knowingly or intentionally distributed fentanyl to the victim and that the victim's death resulted from the fentanyl.The Eighth Circuit affirmed the judgment of the district court, upholding Cheshier's conviction and sentence. View "United States v. Cheshier" on Justia Law

Quincy Martez Chambers was convicted by a jury for possession of ammunition by a felon, violating 18 U.S.C. §§ 922(g)(1) and 924(e). The incident involved the shooting of Nairobi Anderson, the mother of Chambers's child, by a masked man. Anderson was shot in the chest and struck in the head. Chambers was sentenced to 360 months in prison by the district court, which found the object of his offense to be first-degree murder, applying relevant sentencing enhancements.The United States District Court for the Eastern District of Arkansas sentenced Chambers, applying a base offense level of 33, with additional enhancements for Anderson's injuries and obstruction of justice. Chambers was also classified as an Armed Career Criminal under 18 U.S.C. § 924(e), leading to a statutory range of 15 years to life imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Chambers challenged the sufficiency of the evidence, the admission of certain evidence, and the application of sentencing enhancements. The appellate court found sufficient evidence to support the jury's verdict, including Anderson's initial identifications and other corroborating evidence. The court also upheld the admission of text messages and video stills as relevant to Anderson's credibility and motive for recanting her identification. The court found no plain error in their admission.The appellate court affirmed the district court's application of the cross-reference to attempted first-degree murder, the enhancements for the severity of Anderson's injuries, and obstruction of justice. The court also upheld Chambers's classification as an Armed Career Criminal, finding his nolo contendere plea to domestic battery constituted a violent felony under the ACCA. The judgment of the district court was affirmed. View "United States v. Chambers" on Justia Law

Jose Rolando Gonzalez entered a conditional guilty plea to one count of conspiracy to distribute a controlled substance, reserving the right to appeal the district court's denial of his motion to suppress evidence. On September 25, 2022, two separate calls were made to law enforcement reporting a black car driving erratically on I-29. South Dakota State Trooper Chris Spielmann and Trooper Mitchell Lang, along with Brookings Police Officer Seth Bonnema, located the car at a gas station. Gonzalez and his passenger, Marquez Gonzalez, were questioned, and their inconsistent and suspicious responses led Officer Bonnema to use a K-9 unit, which indicated the presence of drugs. A search revealed methamphetamine, cash, drug paraphernalia, and cell phones.The United States District Court for the District of South Dakota denied Gonzalez's motion to suppress the evidence, finding that the officers had reasonable suspicion to stop and search the vehicle. Gonzalez appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court applied a mixed standard of review, examining factual findings for clear error and legal conclusions de novo. The court held that the officers had reasonable suspicion for the Terry stop based on the consistent reports of erratic driving, the car's location, and the corroboration of details such as the car's color and behavior. The court also found that the officers did not unlawfully prolong the stop, as Gonzalez's responses and the circumstances provided reasonable suspicion to expand the scope of the stop. The court affirmed the district court's denial of the motion to suppress. View "United States v. Gonzalez" on Justia Law

Joseph Thompson, Sr. was convicted by a jury of voluntary manslaughter under 18 U.S.C. §§ 1153 and 1112. The incident occurred when Thompson was visiting Charmayne Grooms at her home in Lower Brule, South Dakota. Marty LaRoche, the father of Grooms's children, attempted to enter the home through a window, leading to a confrontation outside between Thompson and LaRoche. LaRoche was found with multiple stab wounds and later died from his injuries. Thompson claimed self-defense, stating LaRoche tried to fight him.The United States District Court for the District of South Dakota denied Thompson's motion for judgment of acquittal and his request for a self-defense jury instruction based on South Dakota law. Instead, the court used the federal self-defense instruction. The jury found Thompson guilty of voluntary manslaughter, a lesser-included offense of the original second-degree murder charge.The United States Court of Appeals for the Eighth Circuit reviewed the case. Thompson argued that the district court erred in not using the South Dakota self-defense instruction and that there was insufficient evidence to support the jury's verdict. The Eighth Circuit held that the district court did not abuse its discretion in using the federal self-defense instruction, noting that federal law, not state law, governs self-defense claims in federal criminal trials. The court also found that sufficient evidence supported the jury's verdict, as Thompson left the safety of the home to confront LaRoche and inflicted multiple stab wounds, including fatal injuries.The Eighth Circuit affirmed the district court's judgment, upholding Thompson's conviction and sentence of 128 months' imprisonment. View "United States v. Thompson" on Justia Law