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

After an officer initiated a traffic stop of Defendant and recovered approximately six pounds of methamphetamine from the vehicle Defendant was driving, he was charged with one count of possession with intent to distribute 500 grams or more of methamphetamine. After the district court denied Defendant’s motion to suppress the methamphetamine, Defendant entered a conditional guilty plea. Prior to sentencing, Defendant filed two pro se motions to withdraw his guilty plea, which the district court denied. The district court sentenced Defendant to 168 months imprisonment, followed by five years of supervised release. Defendant appealed the denials of his motion to suppress and his motions to withdraw his guilty plea.   The Eighth Circuit affirmed. The court explained that considering the factors together, the unlawful stop was sufficiently attenuated in this case by the discovery of Defendant’s expired license and lack of insurance. Thus, despite the unlawful stop of Defendant, the “deterrence benefits” of excluding the evidence do not “outweigh its substantial societal costs,” and the district court did not err in denying Defendant’s motion. Further, the court held that given Defendant’s grounds for withdrawal of his guilty plea are contradicted by the record, the court found no error in the district court’s decision to decline an evidentiary hearing before ruling on the motions. Finally, the court found no error that seriously affects the fairness, integrity, or public reputation of the judicial proceedings. View "United States v. Felix Forjan" on Justia Law

While driving under the influence of alcohol one night in Indian country, Defendant crossed the centerline and crashed into another car, killing two people and seriously injuring two others. Defendant pleaded guilty to two counts of involuntary manslaughter, and the district court sentenced him to two consecutive 84-month prison terms. He challenged the sentence on appeal. Defendant maintained on appeal that the district court failed to provide an adequate explanation for its decision to depart upward on the ground that his criminal-history category underrepresented his likelihood of reoffending.   The Eighth Circuit affirmed. The court held that even if the district court's explanation of Section 4A1.3(a)(1) departure was plainly insufficient, Defendant has failed to demonstrate a reasonable probability that he would have received a more favorable sentence absent the court's error. The district court expressly anchored its chosen sentence to the maximum punishment set by Congress, not to the Guidelines. The record shows that the sentence chosen, much like the one the government recommended, was a product of an evaluation of the Section 3553(a) criteria, in particular, the nature and circumstances of the offense and Defendant’s criminal history. Further, the court held that the district court did not abuse its discretion. View "United States v. Moses Runs Against" on Justia Law

Defendant pleaded guilty to one count of being a felon in possession of a firearm. The district court enhanced the sentence under the Armed Career Criminal Act (ACCA). Defendant has one prior conviction for domestic battery and two prior convictions under the Arkansas robbery statute. On appeal, Defendant agreed that his domestic battery conviction is a “violent felony” for purposes of the ACCA but disputes the district court’s holding that his convictions under the Arkansas robbery statute are as well.   The Eighth Circuit affirmed. The court explained that given the close similarity between the terms “violent felony” and “crime of violence,” it follows that an Arkansas robbery conviction would also be a violent felony for the purposes of the ACCA. The court wrote that an Arkansas robbery conviction is a crime of violence under the Guidelines. It thus follows that an Arkansas robbery conviction is a violent felony under the ACCA. View "United States v. Christopher Mallett" on Justia Law

After Defendant pleaded guilty to conspiring to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, the district court at sentencing found that the methamphetamine Defendant possessed was pure, leading to a higher Sentencing Guidelines range than Defendant believed was appropriate. Defendant takes issue with the court's finding and also says that the government breached an agreement not to seek a Guidelines range that was based on pure methamphetamine.   The Eighth Circuit affirmed. The court explained that to obtain a conviction, the government had to prove merely that Defendant’s conspiracy involved a mixture or substance containing methamphetamine, so it makes sense that the government charged him that way. But for sentencing purposes, the Guidelines consider whether that substance was pure methamphetamine or not. The government did not rest merely on Defendant’s guilty plea to demonstrate that the methamphetamine was pure; it had the methamphetamine tested to confirm that it was pure, and Defendant has expressly disavowed any challenge to the accuracy of the laboratory testing. The district court, therefore, did not err. View "United States v. Jason Russell" on Justia Law

In 2002, a jury convicted Defendant of drug-related crimes, including conspiracy to distribute 500 grams or more of methamphetamine. Based on prior felony drug convictions, the district court imposed a mandatory life sentence on the conspiracy count. In the First Step Act, Congress eliminated mandatory life sentences for this offense. However, Congress did not make Section 401(a) sentence reductions retroactively available to persons who were convicted and sentenced before the First Step Act’s enactment. Defendant moved to reduce his sentence through a motion for compassionate release. The district court denied the motion, concluding that Section 3582(c)(1)(A) relief is foreclosed by United States v. Crandall, 25 F.4th 582 (8th Cir. 2022). The issue on this appeal is whether Defendant is eligible for a sentence reduction under Section 3582(c)(1)(A).   The Eighth Circuit affirmed. The court reasoned that in Crandall, the court held that a non-retroactive change in law regarding sentencing, such as Section 401(a)(2) of the First Step Act, “whether offered alone or in combination with other factors, cannot contribute to a finding of ‘extraordinary and compelling reasons’ for a reduction in sentence under Section 3582(c)(1)(A).” The court explained that the Court’s reasoning in Conception would apply when a motion for compassionate release establishes an extraordinary and compelling reason for relief other than a nonretroactive change in the law, such as the defendant’s medical condition, age, or family circumstances, and the court is exercising its discretion to grant relief. But “Concepcion is irrelevant to the threshold question” of whether Defendant has shown an “extraordinary and compelling reason” for Section 3582(c)(1)(A) relief. View "United States v. Rodrigo Rodriguez-Mendez" on Justia Law

A jury convicted Defendant of rioting and aiding and abetting arson for his participation in civil unrest in downtown Minneapolis. The district court sentenced Defendant to concurrent sentences of 60 months of imprisonment for rioting and 100 months of imprisonment for aiding and abetting arson, followed by two years of supervised release. Defendant appealed, challenging the admission of certain surveillance video and the substantive reasonableness of the sentence.   The Eighth Circuit affirmed. The court explained that here, the district court decided the challenged surveillance video was not so unfairly prejudicial, misleading, or confusing so as to substantially outweigh its probative value. The court reasoned that the district court’s explanation belies Defendant’s contention that the district court neglected to conduct the balancing test required by Rule 403. The court wrote it convicted the court the district court did not abuse its discretion by admitting the challenged video. Further, here, the district court provided extensive reasoning, much of which expressly addressed Defendant’s mitigation arguments. The court explained that this explanation is sufficient to satisfy the court that the district court considered Defendant’s arguments and had a reasoned basis for imposing the 100-month sentence. Accordingly, the court found that as to his claim the sentence is substantively unreasonable, Defendant has not articulated any reason for the court to reach such a conclusion in light of the presumption of reasonableness that attaches to the bottom-of-the-Guidelines sentence. View "United States v. Victor Edwards" on Justia Law

Police went to arrest Defendant for an incident that happened the day before. Defendant fled first on an ATV and then in a car. Once stopped, Defendant was sent to the hospital to receive medical attention. Meanwhile, officers searched Defendant’s car, finding guns and ammunition. A grand jury indicted Defendant for being a prohibited person in possession of a firearm. Defendant moved to suppress his statements, arguing that his Miranda waiver was invalid. The district court denied the motion. Defendant then moved in limine to exclude testimony that he had or used a gun in connection with the incident that led police to confront him on April 22. The district court granted the motion in part, prohibiting the Government from presenting hearsay testimony about the gun. Defendant also moved in limine to exclude evidence of his second flight from police, which was denied.   The Eighth Circuit affirmed. The court explained that here, the totality of the circumstances suggests that Defendant voluntarily, knowingly, and intelligently waived his rights. He was not intimidated, coerced, or deceived. On the contrary, officers ensured Defendant appreciated the rights he was waiving, told him that it was his decision to talk, and advised him that he could end the interview at any time. The evidence at trial showed that on the day the guns were discovered, police watched Defendant get in a car and drive off. When the pursuit ended, police found two guns in the passenger seat. View "United States v. Patrick Medearis" on Justia Law

Defendant moved to suppress evidence from a traffic stop, claiming that the officers unconstitutionally delayed it to conduct a drug-dog search and that the dog’s alert did not provide probable cause to search. The district court denied most of the motion. A jury convicted Defendant for possession of 50 grams or more of methamphetamine with intent to distribute and conspiracy to distribute 500 grams or more of a mixture and substance containing meth. Defendant appealed the denial of the motion to suppress.   The Eighth Circuit affirmed. The court held that the Troopers here had reasonable suspicion before stopping Defendant, which existed throughout the stop. Only 27 minutes passed from the stop until the dog’s alert. This delay did not violate the Fourth Amendment because the Troopers acted diligently to pursue the mission of the stop: to assist with the investigation of Defendant’s drug-related activity. Further, the court held that based on the totality of the circumstances at the scene of the stop, the dog’s alert provided probable cause to search the vehicles. View "United States v. Larry Rederick" on Justia Law

Defendant was sentenced to 840 months of incarceration following a guilty plea to two counts of producing child pornography (360 months each) and one count of committing an offense while a registered sex offender (mandatory minimum of 120 months). Defendant’s pornography production offense involved the sexual abuse of his ten-year-old nephew and four-year-old niece. In addition to the incarceration, the district court also imposed ten years of supervised release. As a special condition of the supervised release, the district court required that Defendant not contact the victims or the victims’ family without permission from his probation officer. Defendant argued that the district court made three reversible errors during sentencing. Specifically, he asserted that (1) his lengthy sentence is substantively unreasonable; (2) the special condition of supervised release is not narrowly tailored; and (3) the district court failed to make an individualized inquiry when crafting the special condition of supervised release.   The Eighth Circuit affirmed, holding that the district court did not abuse its discretion in either the length of the sentence or in imposing the challenged special condition of supervised release. The court held that the district court considered all the applicable Section 3553(a) factors and committed no clear error of judgment in weighing them. Further, the court found that the district court highlighted the hideousness and destructiveness of Defendant’s crimes. The district court concluded that Defendant “fundamentally violated the trust of these good people and this child, these children.” The court’s statement reflects its individualized inquiry into Defendant’s case and made a sufficient record of the court’s thorough consideration of the circumstances. View "United States v. Andrew Scanlan" on Justia Law

Defendant pleaded guilty to three firearm and controlled-substance offenses. Defendant appealed, arguing that the district court erred in sentencing him as a career offender under United States Sentencing Guidelines Section 4B1.1(a).   The Eighth Circuit affirmed. The court wrote that based on the language and structure of Iowa’s conspiracy statutes, Iowa state court decisions, and Iowa’s model jury instructions, it concludes that Section 706.3(2) is divisible as to the non-forcible felony that serves as the object of a conspiracy. Here, the specific object of Defendant’s Section 706.3(2) conspiracy is not in dispute: the PSR stated that Defendant was convicted of conspiracy to commit the offense of willful injury causing bodily injury, and Defendant does not contend that he conspired to commit a different offense. Further, the court explained that because it “generally interprets the identical ACCA and Guidelines force clauses interchangeably,” willful injury causing bodily injury qualifies as a “crime of violence” under the Guidelines as well. View "United States v. Devon McConnell" on Justia Law