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

Henry Dailey began a ten-year term of supervised release after serving a prison sentence for his involvement in a commercial sex trafficking ring. Four months into his supervised release, his Probation Officer filed a Violation Report alleging numerous violations of his release conditions. Dailey admitted to most of the violations, resulting in an advisory guidelines sentencing range of 6 to 12 months imprisonment. Despite a joint recommendation for 6 months imprisonment followed by ten years of supervised release, the district court sentenced Dailey to 12 months imprisonment followed by 240 months of supervised release.The United States District Court for the Western District of Missouri initially sentenced Dailey to 84 months imprisonment followed by 120 months of supervised release after he pleaded guilty to one count of Interstate Transportation for Prostitution. Upon completing his prison term, Dailey began his supervised release in November 2022. In March 2023, his Probation Officer reported multiple violations, including failing to register internet-capable devices and involvement in drug sales. At a preliminary revocation hearing, the magistrate judge found probable cause to proceed. Dailey later stipulated to most violations but contested some allegations.The United States Court of Appeals for the Eighth Circuit reviewed the case. Dailey appealed the new term of supervised release, alleging procedural errors and a substantively unreasonable sentence. The appellate court found no procedural error, noting that the district court did not base its sentence on unproven allegations and allowed Dailey ample opportunity to defend against the contested violations. The court also found the 240-month term of supervised release substantively reasonable, given Dailey's criminal history and repeated violations. The judgment of the district court was affirmed. View "United States v. Dailey" on Justia Law

Christopher Lockhart, a licensed Arkansas bail bondsman and private investigator, was stopped by Siloam Springs police officer Zachary Ware around 3:30 AM on March 11, 2019, for alleged traffic violations. Lockhart was arrested and charged with DWI, careless driving, and driving left of center. After refusing a plea deal, Lockhart was tried for DWI but was found not guilty. Subsequently, Lockhart filed a § 1983 action against multiple defendants, including claims of unreasonable stop, unlawful arrest, and malicious prosecution.The United States District Court for the Western District of Arkansas granted summary judgment to the defendants on most claims but allowed Lockhart’s illegal stop and false arrest claims against Officer Ware and the malicious prosecution claim against Siloam Springs to proceed. The court found genuine disputes of material fact regarding whether Officer Ware had probable cause to stop Lockhart, as the dashcam video did not conclusively support Ware’s testimony. The court also denied summary judgment on the malicious prosecution claim, finding a material fact dispute about whether the prosecutor had probable cause to try Lockhart for DWI.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that Officer Ware had probable cause to stop Lockhart for careless driving, as Lockhart’s tires touched the centerline, which under Arkansas law constitutes a traffic violation. The court reversed the district court’s decision regarding the initial stop and remanded the case for further proceedings on the remaining issues. The court also affirmed the district court’s denial of summary judgment on the malicious prosecution claim, agreeing that Arkansas statutory immunity does not apply to intentional torts like malicious prosecution. View "Lockhart v. Siloam Springs, Arkansas" on Justia Law

Bruce Alexander and Terrence Gay were charged with conspiracy to distribute and possession with intent to distribute fentanyl. Gay pleaded guilty, while Alexander went to trial and was found guilty by a jury. Alexander appealed, challenging the exclusion of Gay’s exculpatory statement, the handling of government witnesses, and the trial court’s comments.The United States District Court for the Western District of Missouri excluded Gay’s exculpatory statement, ruling it hearsay under Federal Rule of Evidence 804(b)(3). The court found that the statement lacked sufficient corroborating circumstances to indicate its trustworthiness, given Gay’s close relationship with Alexander and Gay’s subsequent fugitive status. The court also held a three-day jury trial where it occasionally interjected to clarify witness testimony and maintain the trial’s pace.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decisions. The appellate court affirmed the exclusion of Gay’s statement, agreeing that it lacked trustworthiness. The court also found no plain error in the handling of government witnesses, noting that the officers’ dual-role testimony was appropriately managed and did not affect the trial’s outcome. Additionally, the court ruled that the district court’s comments during the trial were aimed at clarifying testimony and maintaining order, and did not deprive Alexander of a fair trial.The Eighth Circuit held that the district court did not abuse its discretion in its evidentiary rulings or trial management, and thus affirmed Alexander’s conviction and sentence. View "United States v. Alexander" on Justia Law

In July 2018, a tornado damaged Vermeer Corporation’s facilities in Pella, Iowa. Roger Paul Bradford was hired in January 2019 as the Director of Construction to oversee the reconstruction. Bradford conspired with Viorel Draghia to receive kickbacks in exchange for steering construction contracts to Draghia’s company. Bradford shared confidential information with Draghia, who inflated his bids to include kickbacks for Bradford. Vermeer accepted Draghia’s higher bids despite cheaper alternatives. The FBI investigated in 2020, and Draghia admitted to the kickbacks. Bradford was indicted for Conspiracy to Commit Wire Fraud.The United States District Court for the Southern District of Iowa accepted Bradford’s guilty plea, which included an appeal waiver for his conviction but allowed an appeal of his sentence. The court applied a 10-level enhancement under the United States Sentencing Guidelines, determining a loss of more than $150,000. Bradford was sentenced to 20 months in prison and ordered to pay $23,000 in restitution. Bradford appealed, arguing the district court lacked jurisdiction due to a defect in the indictment and challenged the loss calculation and denial of access to certain documents.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the appeal waiver was enforceable, and Bradford had not shown a miscarriage of justice. The court found no error in the district court’s loss calculation or its denial of access to Draghia’s Presentence Investigation Report and immigration file. The court also upheld the district court’s consideration of uncharged conduct in sentencing. Bradford’s post-sentencing motions were denied as they were based on the same grounds covered by the appeal waiver.The Eighth Circuit dismissed the appeal in part based on the waiver and affirmed the district court’s judgment. View "United States v. Bradford" on Justia Law

Tina Sully, a foster parent for the Yankton Sioux Tribe, was charged with multiple counts of abusing her three adopted children. The charges stemmed from an incident where 13-year-old C.S. ran away from home and reported to neighbors and authorities that Sully had physically abused her and withheld food. An investigation revealed similar allegations from two other foster children, D.F.H. and G.S. Sully was indicted on ten counts, including assault with a dangerous weapon and felony child abuse.The first trial in the United States District Court for the District of South Dakota ended in a mistrial due to a hung jury. The court scheduled a second trial to begin eighteen days later. Sully requested a continuance twice, citing her counsel's scheduling conflicts and the unavailability of key defense witnesses, but both motions were denied. The second trial proceeded, and Sully objected to the admission of several out-of-court statements under Federal Rules of Evidence 803(2) and 807, which the court admitted.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying Sully's motions for a continuance, as she failed to demonstrate how the denial prejudiced her defense. The court also found that even if the admission of the challenged hearsay statements was erroneous, it was harmless error given the overwhelming evidence against Sully, including testimony from C.S., medical professionals, and other witnesses.The Eighth Circuit affirmed the district court's decisions, upholding Sully's convictions on all counts related to C.S. The court concluded that the denial of the continuance and the admission of hearsay evidence did not warrant a new trial. View "United States v. Sully" on Justia Law

Norman Burch was convicted by a jury of attempting to sexually exploit a minor, attempting to receive and receiving child pornography, and committing a felony sex offense involving a minor while required to register as a sex offender. These actions also violated the terms of his supervised release from a prior conviction for possessing child pornography. Burch was sentenced to a combined 420 months of imprisonment for these convictions and violations.Previously, the United States District Court for the Southern District of Iowa presided over Burch’s case. The court admitted evidence of Burch’s 2014 conviction for child pornography under Federal Rules of Evidence 404(b) and 414(d)(2)(B). Burch objected to this evidence, but the court overruled his objection. The jury found Burch guilty on all counts, and the district court sentenced him to 420 months of imprisonment, followed by a lifetime of supervised release. The court also revoked Burch’s supervised release from his previous conviction, imposing an additional 24 months to run concurrently with some counts and consecutively with others.The United States Court of Appeals for the Eighth Circuit reviewed the case. Burch challenged the admission of his prior conviction, the sufficiency of the evidence for all counts, and the revocation of his supervised release. The Eighth Circuit held that the district court did not abuse its discretion in admitting the prior conviction under Rule 414, as it was relevant to show Burch’s propensity to be sexually interested in minors. The court also found sufficient evidence to support Burch’s convictions on all counts, including the attempted sexual exploitation of a minor and the receipt of child pornography. Consequently, the Eighth Circuit affirmed the district court’s judgment, including the revocation of Burch’s supervised release. View "United States v. Burch" on Justia Law

In 2000, Karl Roberts was convicted and sentenced to death in Arkansas state court for the rape and murder of his twelve-year-old niece. Roberts waived his right to challenge his conviction on direct appeal, in state postconviction proceedings, and in federal habeas corpus proceedings. Both the Arkansas state trial court and the Arkansas Supreme Court found the waiver to be knowing and voluntary. On the day of his scheduled execution in 2004, Roberts moved for a stay of execution, which was granted, and subsequently filed a petition for writ of habeas corpus, initiating two decades of litigation.The United States District Court for the Eastern District of Arkansas denied Roberts’s nineteen habeas corpus claims but granted a certificate of appealability (CoA) on three claims: whether Roberts was intellectually disabled, competent to be tried, and competent to waive his direct appeal. The Eighth Circuit expanded the CoA to include two ineffective assistance of counsel claims: failure to investigate and challenge Roberts’s competency to be tried and failure to investigate and present evidence of Roberts’s mental health as mitigating evidence at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s denial of Roberts’s habeas petition. The court held that the Arkansas courts’ findings that Roberts was not intellectually disabled, was competent to stand trial, and was competent to waive his direct appeal were reasonable and supported by the record. The court also found that Roberts’s trial counsel was not ineffective, as the counsel’s performance did not fall below an objective standard of reasonableness, and there was no prejudice to Roberts. The court concluded that Roberts failed to show that the outcome of his trial would have been different but for the alleged errors by his counsel. View "Roberts v. Payne" on Justia Law

Elmarries Harris was serving a term of supervised release following a prison sentence for a firearms offense. In January 2023, the probation office reported several violations of his release conditions, including an allegation that he assaulted his wife, Erica. At a revocation hearing in June 2023, Harris denied the allegations, and the government presented a violation report and a defense investigator’s report stating Erica denied being assaulted. Harris objected to the hearsay evidence, and the court continued the hearing for additional evidence. In August, the government presented medical records of Erica’s injuries and testimony from a police officer who responded to a 911 call reporting the assault. The officer’s body camera footage and testimony from Erica’s neighbor and a 911 caller were also presented, despite Harris’s objections to hearsay.The United States District Court for the Western District of Missouri found Harris committed a Grade A violation by committing a domestic assault in the second degree, supported by medical records and corroborating witness statements. The court also found Harris violated other conditions of his release, including failing to answer the probation officer’s questions truthfully, failing to notify the probation officer before changing his residence, and consuming alcohol. Harris was sentenced to 24 months’ imprisonment, the statutory maximum, with no supervised release to follow.The United States Court of Appeals for the Eighth Circuit reviewed the case. Harris argued that the reliance on hearsay evidence violated Federal Rule of Criminal Procedure 32.1 and due process. The court concluded that the district court’s decision was consistent with due process, noting the reliability of the evidence and the government’s reasonable explanations for the absence of witnesses. The judgment of the district court was affirmed. View "United States v. Harris" on Justia Law

Two high school brothers, Kameron and Noah Evans, were arrested for disorderly conduct after wearing tactical vests to school. The brothers, who had faced racial bullying, wore the vests on a day when the school was screening an active-shooter video. They were searched by school resource officers, who found no weapons. The principal decided to have them arrested, and they were charged with disorderly conduct. The state court later acquitted them, and the brothers filed a lawsuit under § 1983 and state tort claims against the officers, alleging lack of probable cause and excessive force.The United States District Court for the Eastern District of Arkansas denied the officers' motion for summary judgment based on qualified immunity. The officers appealed, arguing they had probable cause or at least arguable probable cause to arrest the brothers for disorderly conduct under Arkansas law.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the officers lacked probable cause to arrest the brothers, as their actions did not disrupt a lawful assembly or constitute threatening behavior. The court also determined that the officers did not have arguable probable cause, as the brothers were cooperative and their attire did not violate the school dress code. The court affirmed the district court's denial of qualified immunity on the unlawful arrest, malicious prosecution, and false imprisonment claims. However, the court reversed the denial of qualified immunity on the excessive force and abuse of process claims, as the plaintiffs failed to respond to these arguments on appeal. The case was remanded for further proceedings. View "Evans v. Dodd" on Justia Law

Derrick Lovell Parker pleaded guilty to possession with intent to distribute heroin, violating 21 U.S.C. §§ 841(a)(1) and (b)(1)(B). The advisory Guidelines range for his sentence was 70 to 87 months. However, the district court varied upward and sentenced Parker to 180 months of imprisonment and 5 years of supervised release. Parker appealed his sentence, arguing that it was substantively unreasonable.The United States District Court for the Eastern District of Arkansas initially reviewed the case. The court considered the nature of Parker's offense, which involved a significant amount of heroin and an incident where Parker, armed with a gun, created a "very scary situation" at a residential re-entry center. The district court expressed concern about Parker's potential to repeat his unlawful conduct and decided on a substantial upward variance from the Guidelines range.The United States Court of Appeals for the Eighth Circuit reviewed the case under a deferential abuse-of-discretion standard. Parker contended that the district court gave undue weight to factors already considered by the Guidelines, such as his offense conduct and criminal history. The appellate court noted that while courts should be cautious when supporting a substantial upward variance with factors already reflected in the Guidelines, such factors can still justify a variance. The appellate court found that the district court did not give undue weight to these factors.Parker also argued that the district court failed to consider the need to avoid sentence disparities and mitigating factors like his mental health issues. The appellate court observed that the district court had considered these factors and recommended substance abuse treatment and mental health counseling for Parker. The appellate court concluded that the district court acted within its discretion and affirmed the 180-month sentence. View "United States v. Parker" on Justia Law