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

Kenneth Blair was convicted by a jury of possessing with intent to distribute and distributing methamphetamine, and was sentenced to 292 months in prison. Blair appealed the conviction to the United States Court of Appeals for the Eighth Circuit, arguing against the denial of two pre-trial motions, refusal to acquit him on both counts, and the calculation of drug quantities for sentencing. Blair's main argument against his conviction was that the evidence against him was insufficient. However, the court found that there was ample evidence linking him to the possession and distribution of meth, including the fact that he was found with marked buy money and drugs at an apartment linked to him. The court stated that the jury could reasonably conclude that Blair had dominion over the apartment and the drugs within it. The court also dismissed Blair's claims against the calculation of drug quantities for sentencing. Blair argued that the court should not have relied on testimony from a confidential informant and a cooperating witness due to their unreliability. However, the court held that it was within the district court's discretion to credit their testimony. The court therefore affirmed Blair's conviction and sentence. View "United States v. Blair" on Justia Law

In this case heard by the United States Court of Appeals for the Eighth Circuit, the appellant, Timothy Eugene Angel, appealed against his sentence for possessing ammunition after having been convicted of a felony. Angel had pleaded guilty to the charge but disagreed with the district court's application of the attempted murder cross-reference from the United States Sentencing Guidelines (USSG) in determining his offense level and consequent sentence. The dispute stemmed from an incident where Angel fired shots at two individuals, Leonard Fisher and Tityana Woodland, outside a club in Davenport, Iowa, after a heated altercation inside the club.The court found that the district court did not err in applying the attempted murder cross-reference. It based this decision on the premise that Angel, by firing five shots at Fisher and Woodland, demonstrated a specific intent to kill. Moreover, the court also found that Angel had enough time after the altercation to be fully conscious of his intent and deliberate about his conduct, thereby satisfying the requirement for premeditation.Angel raised a self-defense argument, contending that he fired his gun in response to Woodland threatening him with a gun. However, the court rejected this argument, finding that Angel had escalated the situation by choosing to leave the club, retrieve a gun, and open fire. Consequently, the court affirmed the judgment of the district court, upholding Angel's sentence. View "United States v. Angel" on Justia Law

This case involves an appeal from the United States District Court for the District of South Dakota filed by the defendant, Nathaniel Crawford. Crawford was involved in a domestic dispute with his ex-girlfriend at an apartment complex, which led to concerned residents calling 911, reporting that Crawford was threatening to shoot a person or burn the complex. After officers arrived at the scene, Crawford fled but returned later to threaten his ex-girlfriend with a firearm. He fled again before officers could arrive; however, they found him and his vehicle in a nearby parking lot. Officers identified a wooden object protruding from the vehicle's center console, which they inferred to be a firearm. Crawford was subsequently charged with being a prohibited person in possession of a firearm due to his prior felony and misdemeanor domestic violence convictions.Crawford moved to suppress the firearm, arguing that officers lacked probable cause to search his vehicle. The district court denied his motion, leading to Crawford's appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision, agreeing that the 911 calls, the ex-girlfriend's statements, and the wooden object established probable cause for the vehicle search. The court ruled that the officers' search was supported by probable cause based on the combination of these factors, establishing probable cause to search Crawford's vehicle for a firearm. The court also rejected Crawford's arguments that the search was unreasonable due to the officers' original investigation of him for a different crime and their lack of knowledge about his status as a prohibited person under federal law. The court maintained that the government can search for evidence of one crime and charge the suspect with a different crime based on what it later learns. The court concluded that the "fruit of the poisonous tree" was admissible because the tree in this case was not poisonous. View "United States v. Crawford" on Justia Law

In this case heard before the United States Court of Appeals for the Eighth Circuit, the appellant, Dewanis Rogers, sought a reduced sentence under the First Step Act of 2018. Rogers had been found guilty in 2008 of conspiracy to distribute 50 grams or more of cocaine within 1,000 feet of a protected location, following two or more prior felony drug convictions. He received a mandatory sentence of life imprisonment, as prescribed by statute. In 2022, Rogers requested that his sentence be reduced under the provisions of the First Step Act. The district court denied this motion, determining that Rogers was ineligible for relief under the Act. Rogers appealed this decision, disputing his ineligibility.Upon review, the United States Court of Appeals for the Eighth Circuit held that even if Rogers was eligible for relief under the First Step Act, the district court could not have lawfully reduced his sentence due to the mandatory term of imprisonment prescribed by statute. The court explained that Congress had not expressly repealed the mandatory punishment for Rogers’s offense in the First Step Act, and that the change in law cited by Rogers did not appear in the sections of the Fair Sentencing Act of 2010 made retroactive by the First Step Act. Therefore, the court affirmed the district court's decision. View "United States v. Rogers" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered an appeal by several Missouri public officials who were denied qualified immunity by a lower court regarding five claims arising from a murder prosecution. The murder case, involving Donald Nash who was eventually convicted for the murder of Judy Spencer, was reopened in 2007, 25 years after the crime occurred. The officials based their case on a theory that DNA evidence found under Spencer's fingernails belonged to Nash, which they asserted could not have remained present if Spencer had washed her hair after their last encounter.Nash was convicted and spent 11 years in prison until the Missouri Supreme Court set aside his conviction in 2020. The charges were dismissed after DNA testing on the shoelace used to strangle Spencer supported Nash’s noninvolvement. Nash and his wife filed a lawsuit against the officials, claiming violations of rights including unlawful arrest and detention, fabrication of evidence, failure to investigate, violations of rights of access to courts, and violation of the right to familial and marital associations.The Eighth Circuit affirmed in part, reversed in part, and dismissed in part the appeals on the denial of qualified immunity. The court held that the officials were not entitled to qualified immunity on the claim of unlawful arrest and detention, finding that the omission of certain exculpatory facts from the probable cause affidavit negated probable cause for Nash's arrest. However, the court reversed the denial of qualified immunity for the claim alleging violation of the right to familial and marital associations, as this was not a clearly established constitutional right in 2008. The court dismissed the officials' appeal on the remaining claims due to lack of jurisdiction, as these involved genuine disputes of material fact to be resolved by a jury. View "Estate of Nash v. Folsom" on Justia Law

In 2006, Charles H. Lester, Jr. was sentenced to 188 months' imprisonment and 5 years of supervised release for conspiring to distribute methamphetamine. After serving a portion of his supervised release term, the United States Probation Office filed a report recommending the early termination of Lester's supervision, citing his low risk of recidivism and compliance with the conditions of his supervision. The United States District Court for the Eastern District of Missouri denied this request, asserting that it did not have the authority to terminate Lester's supervised release early due to the requirement in 21 U.S.C. § 841(b)(1)(A) that a five-year term of supervised release be imposed, which the court interpreted as precluding early termination under 18 U.S.C. § 3583(e)(1).Upon appeal, the United States Court of Appeals for the Eighth Circuit disagreed with the district court's interpretation. The appellate court held that the language of § 841(b)(1)(A) requires the imposition of a five-year term of supervised release, but does not impact a district court's ability to later terminate an individual's supervised release after the individual has served at least one year, as provided in § 3583(e)(1). Thus, the district court retained discretion to consider whether Lester's supervised release could be terminated early under § 3583(e)(1). Consequently, the appellate court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "United States v. Lester" on Justia Law

A defendant, John Radermacher, was found guilty of conspiracy to distribute methamphetamine by a jury in the United States District Court for the District of South Dakota. Radermacher appealed his conviction to the United States Court of Appeals for the Eighth Circuit, arguing two main points: firstly, that the district court erred in admitting evidence of his prior drug conviction under Federal Rule of Evidence 404(b), and secondly, that the court wrongly denied his motion for a judgment of acquittal due to insufficient evidence.In reviewing the first argument, the Appeals Court noted that while evidence of past crimes is generally not admissible to prove a person's character, it can be admitted for other purposes, such as proving motive, intent, or knowledge. In this case, Radermacher's prior conviction was relevant to his knowledge of the drug conspiracy and his intent to join it. The court also noted that the prior conviction was sufficiently similar in kind to the crime charged, and although there was a considerable gap of time between the two offenses, most of that time Radermacher was incarcerated. Therefore, the court ruled that the district court did not abuse its discretion in admitting this evidence.As for the second argument, the Appeals Court reviewed the sufficiency of the evidence that led to Radermacher's conviction. In order to establish guilt for conspiracy to distribute a controlled substance, three elements must be present: the existence of a conspiracy, the defendant's knowledge of the conspiracy, and the defendant's intentional joining of it. The court determined that there was enough evidence for a reasonable jury to find Radermacher guilty of the offense beyond a reasonable doubt. Therefore, the Appeals Court affirmed the judgment of the district court. View "United States v. Radermacher" on Justia Law

In this case heard before the United States Court of Appeals for the Eighth Circuit, the defendant Ricky Timothy Williams was convicted of possession with intent to distribute 50 grams or more of methamphetamine, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm. Williams appealed his conviction, arguing that the district court erred by giving a supplemental instruction to the jury that he believed went beyond the scope of the jury's question and was duplicative of instructions already given.The Court of Appeals affirmed the conviction, stating that the district court has the discretion to respond to a jury's request for a supplemental instruction. The Court of Appeals found that the instructions given by the district court, when taken as a whole, fairly and adequately instructed the jurors on the applicable law. They also found that the supplemental instruction was not unnecessarily duplicative, and that district courts are not prohibited from giving duplicative instructions where reinstruction will assist the jury.The Court of Appeals also noted that the jury's note to the court made clear that they were confused about the meaning of a phrase from the final instruction. The district court clarified this confusion by providing a supplemental instruction using language from the final instructions already given, and the Court of Appeals found this to be within the district court's discretion. View "United States v. Williams" on Justia Law

The case concerns the defendant, Roylee Richardson, who was convicted by a jury for witness tampering and possessing a firearm as a felon. After his arrest for attacking his then-girlfriend and shooting at her would-be rescuer, Richardson made several recorded jailhouse calls attempting to persuade her to recant her testimony or refuse to testify. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision, finding that there was sufficient evidence to support Richardson's conviction on both counts of witness tampering.The court explained that witness tampering involves two elements: knowingly intimidating, threatening, or corruptly persuading another person, and intending to influence, delay, or prevent another's testimony in an official proceeding. The court found that Richardson's actions met these elements. In the calls, he attempted to corruptly persuade his ex-girlfriend to lie or refuse to testify, and he feared the impact her testimony would have on his case, demonstrating his intent to influence her testimony.Furthermore, the court addressed Richardson's argument about the admission of his multiple prior felony convictions. The court noted that one element of a felon-in-possession charge requires the possessor to have a prior felony conviction. Richardson refused to formally admit his prior felony convictions, thereby necessitating the government to prove this element. The court found that the government appropriately presented evidence of his multiple prior felony convictions to establish that Richardson was a felon and was aware of his status as a felon at the time. The court concluded there was no abuse of discretion in the government's introduction of multiple prior convictions and three mug shots as evidence. Therefore, the court affirmed the judgment of the district court. View "United States v. Richardson" on Justia Law

In the case before the United States Court of Appeals For the Eighth Circuit, the defendant, Kaycee Heard, appealed his 180-month sentence for involvement in a drug-trafficking conspiracy that transported oxycodone and fentanyl pills from Michigan to North Dakota for distribution. Heard pleaded guilty to conspiring to distribute and possess with intent to distribute controlled substances, and his sentence exceeded his Guidelines range of 135 to 168 months. Heard's appeal centered around three key claims: the district court miscalculated his criminal history score, wrongly applied a Guidelines enhancement for his role in the conspiracy, and issued an unreasonable sentence.The Court of Appeals rejected all three of Heard's claims. First, the court found that the district court was correct to assess a criminal history point for a two-year probation term Heard served under Michigan’s Holmes Youthful Trainee Act. Despite Heard's argument that this sentence should not have counted towards his criminal history score as no conviction was entered and the underlying charges were dismissed, the Appeals Court ruled that Heard's admission of guilt by pleading guilty meant the probation term was correctly counted as a "prior sentence".Second, the Appeals Court upheld the district court's application of a three-level enhancement for Heard's role in the conspiracy, finding that Heard had exhibited sufficient managerial or supervisory authority to warrant this enhancement. The court pointed to evidence that Heard had recruited co-conspirators, used a co-conspirator’s apartment as a stash house, directed a co-conspirator to travel to get pills for distribution, and received proceeds from the pills’ sale.Finally, the court found Heard's sentence to be both procedurally and substantively reasonable. The district court had varied up from the Guidelines range based on Heard's conduct in pretrial detention, including his participation in a prison riot and assaults on two inmates. The Appeals Court found no clear error in the district court's determination that Heard had participated in the riot, and concluded that the 180-month sentence was within the realm of reasonableness given Heard's drug trafficking and pretrial detention misconduct. The court also rejected Heard's claim that his sentence created unwarranted disparities with his co-conspirators, stating that the need to avoid unwarranted sentence disparities refers to national disparities, not differences among co-conspirators. The court therefore affirmed the district court’s judgment. View "United States v. Heard" on Justia Law