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

Marquice Morris was convicted by a jury of conspiracy to distribute fentanyl. The case involved Morris and his co-defendant, Brandon Johnson, who conspired to distribute at least 400 grams of fentanyl in Minnesota. Evidence presented at trial showed that Morris arranged a trip to Phoenix, Arizona, where he purchased fentanyl and provided it to Johnson for transport back to Minnesota. Johnson was apprehended in Texas with the drugs and a firearm, leading to recorded calls implicating Morris.The United States District Court for the District of Minnesota denied Morris's motions for acquittal or a new trial, sentenced him to 190 months of imprisonment, and revoked his supervised release. Morris appealed his conviction, revocation, and sentence. The district court found that Morris had attempted to bribe Johnson and pressured him to sign an affidavit exonerating Morris, leading to an obstruction of justice enhancement in his sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was sufficient evidence to support the jury's verdict, including corroborated testimony from Johnson and law enforcement officers. The court also found that venue was proper in Minnesota, as the conspiracy involved actions taken in the state. The court rejected Morris's arguments for a new trial, finding no abuse of discretion by the district court. Lastly, the court upheld the obstruction of justice enhancement, noting sufficient circumstantial evidence linking Morris to attempts to influence Johnson.The Eighth Circuit affirmed the judgments of the district court, including Morris's conviction, sentence, and the revocation of his supervised release. View "United States v. Morris" on Justia Law

Luke LeFever was involved in a series of criminal activities following a roadside encounter with Deputy Castellanos of the Dawson County Sheriff’s Department. LeFever lunged at the deputy, was tased twice, and fled the scene. He attempted to steal multiple vehicles, broke into a home, assaulted a resident, and led officers on a high-speed chase, driving recklessly and endangering public safety. The chase ended when officers fired 60 to 70 rounds at LeFever’s vehicle, resulting in serious injuries.The United States District Court for the District of Nebraska denied LeFever’s requests for appointed counsel and granted summary judgment in favor of the defendants. The court found that Deputy Castellanos had probable cause for the initial arrest and that the use of force, including the tasings and the shot fired at the utility vehicle’s wheel, was reasonable. The court also found that the report of “shots fired” by Deputy Castellanos did not rise to the level of a constitutional violation. Additionally, the court ruled that the actions of the other officers during the chase and subsequent shooting were reasonable under the circumstances and that qualified immunity applied.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that the use of force by Deputy Castellanos and the other officers was reasonable and that qualified immunity protected the officers from liability. The court also found no abuse of discretion in the district court’s denial of LeFever’s requests for appointed counsel, noting that the facts and legal issues were clear and uncomplicated, and that the district court had provided adequate assistance to LeFever in managing his case. View "LeFever v. Castellanos" on Justia Law

Izeall Collins was convicted by a jury of possession of heroin with intent to distribute and possession of a firearm in furtherance of drug trafficking. Collins was apprehended at the Kansas City Greyhound bus terminal after law enforcement officers observed his suspicious behavior and conducted a search that revealed heroin and a firearm. Collins appealed, arguing that the district court erred in denying his motion to suppress evidence and his motion for acquittal due to insufficient evidence.The United States District Court for the Western District of Missouri denied Collins's motion to suppress, finding that the initial encounter between Collins and the officers was consensual and that the officers had probable cause to arrest him after he admitted to possessing marijuana. The court also denied Collins's motion for acquittal, concluding that the evidence presented at trial was sufficient to support his convictions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, agreeing that the initial encounter was consensual and that the officers had probable cause to arrest Collins. The court also upheld the sufficiency of the evidence, noting that the quantity of heroin found on Collins was sufficient to establish intent to distribute and that the firearm found in the cooler, along with other items linking it to Collins, supported the conviction for possession of a firearm in furtherance of drug trafficking.The Eighth Circuit concluded that the evidence was sufficient to support Collins's convictions and affirmed the judgment of the district court. View "United States v. Collins" on Justia Law

Tyrell Gaston was on probation following a deferred judgment for a robbery that resulted in a gunfight, leaving him injured and his cousin dead. Shortly after, he was involved in two more violent incidents involving firearms, leading to charges of attempted murder and other offenses. Despite these charges being dismissed, Gaston continued to violate probation terms, including being out past curfew. During his arrest for these violations, a probation officer found keys to his truck and, upon questioning, Gaston mentioned a backpack in the truck, which led to a search revealing a loaded gun.The United States District Court for the Northern District of Iowa denied Gaston's motion to suppress the evidence found in the truck, concluding that the search was supported by reasonable suspicion. Gaston had consented to searches as part of his probation agreement, which allowed searches based on reasonable grounds. The district court found that the probation officer had reasonable suspicion to search the truck based on Gaston's history and his reaction to the questioning about the backpack.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the search was justified under the Fourth Amendment's reasonable suspicion standard. The court noted that Gaston's history of violent conduct and his immediate disclaimer of the backpack provided a particularized and objective basis for the search. The court also upheld the district court's credibility determination that the probation officer's decision to search was based on Gaston's suspicious response. The judgment of the district court was affirmed. View "United States v. Gaston" on Justia Law

The State of South Dakota charged Ronald Lee Neels with multiple sex-related offenses, including rape, sexual contact, and incest, for the sexual abuse of his adopted daughter over a 14-year period. During the trial, the prosecutor made an opening statement that asked the jury to imagine themselves in the victim's position, which is considered a "Golden Rule" argument and is generally condemned. Neels did not object to this statement at the time. Following his conviction, Neels filed a pro se petition for a writ of habeas corpus, claiming ineffective assistance of counsel for not objecting to the prosecutor's opening statement.The South Dakota Supreme Court summarily affirmed Neels's conviction on direct appeal, stating that the issues raised were without merit. Neels then filed a state habeas corpus petition, which was denied on the grounds of res judicata, as the court found that the issue of prejudice had already been decided on direct appeal. The South Dakota Supreme Court affirmed this decision, holding that the same standard of prejudice applied in both plain error review and ineffective assistance of counsel claims.Neels subsequently filed a federal habeas corpus petition under 28 U.S.C. § 2254. The district court granted the petition, concluding that Neels suffered prejudice from his attorneys' failure to object to the prosecutor's opening statement, despite acknowledging the overwhelming evidence of Neels's guilt. The court reasoned that the magnitude of the prosecutorial misconduct required vacating the conviction to ensure a fair trial.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision. The appellate court held that Neels did not suffer Strickland prejudice from his counsel's failure to object to the prosecutor's opening statement, given the overwhelming evidence of his guilt. The court emphasized that the jury instructions and the strength of the evidence against Neels mitigated any potential prejudice from the prosecutor's improper remarks. View "Neels v. Fluke" on Justia Law

On December 26, 2019, Officers Rozeboom and Malone responded to a shoplifting report at Dick’s Sporting Goods in Papillion, Nebraska. The suspects were described as a black male and black female in a silver four-door sedan. Malone spotted a similar vehicle and conducted a traffic stop. Storrs, a black male, was driving, and Smith, a white female, was the passenger. Despite the discrepancy in the suspect description, the officers detained Storrs and Smith. During the encounter, Storrs and Smith were uncooperative, leading to their arrest and a search of their vehicle, which allegedly smelled of marijuana.The United States District Court for the District of Nebraska granted summary judgment in favor of the officers, finding they were entitled to qualified immunity on all claims. The court determined that the officers had reasonable suspicion for the initial stop and probable cause for the continued detention and search based on the alleged odor of marijuana. The court also found no evidence of excessive force or First Amendment retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision in part, agreeing that the officers had probable cause to arrest Storrs and Smith for obstructing a peace officer and that there was no evidence of excessive force or First Amendment retaliation. However, the court reversed the summary judgment on the claim of unlawful continued detention, finding that the officers lacked reasonable suspicion once they saw Smith was white. The court also found a genuine dispute of fact regarding the alleged odor of marijuana, precluding summary judgment on the illegal search claim. The case was remanded for further proceedings consistent with these findings. View "Storrs v. Rozeboom" on Justia Law

Kenneth Hunt arrived at the Lee County Courthouse to testify in a criminal case. Directed outside due to courtroom scheduling, Hunt re-entered and sat on a staircase. Officer Dale Acosta confronted Hunt, leading to a heated exchange. Despite Hunt's explanation of his courthouse business, Acosta arrested him for obstruction, claiming Hunt disrupted the county tax office.The United States District Court for the Eastern District of Arkansas dismissed most of Hunt's claims but allowed his Fourth Amendment claim against Acosta, a failure to train or supervise claim against Mayor Jimmy Williams and Chief of Police Martin Wilson, and a Monell claim against the City of Marianna. The court denied qualified and quasi-judicial immunity for Acosta and qualified immunity for Williams and Wilson. Acosta, Williams, and Wilson appealed the denial of immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court's denial of quasi-judicial immunity for Acosta's initial stop of Hunt, as Acosta acted under a judge's directive. However, the court affirmed the denial of quasi-judicial and qualified immunity for Acosta's arrest of Hunt, finding no probable cause for obstruction. The court also reversed the denial of qualified immunity for Williams and Wilson, ruling that Hunt failed to show a pattern of unconstitutional acts by Acosta that would have put them on notice. The case was remanded for further proceedings consistent with these findings. View "Hunt v. Acosta" on Justia Law

Colton Bagola was convicted of first-degree murder and discharge of a firearm during a crime of violence after shooting Sloane Bull Bear in the back of the head at a gathering in Pine Ridge, South Dakota. Witnesses testified that Bagola shot Bull Bear from approximately one inch away. Following the incident, Bagola and others fled the scene, and Bull Bear's body was found in the exterior doorway. Bagola was indicted on multiple charges, including first-degree murder and tampering with evidence. The district court severed the conspiracy count and granted a motion for acquittal on the tampering charge. The jury convicted Bagola of first-degree murder and discharge of a firearm during a crime of violence, and he was sentenced to life imprisonment.The United States District Court for the District of South Dakota handled the initial trial. After the jury's guilty verdict, Bagola filed a motion for judgment of acquittal, which the district court denied. Bagola then appealed his conviction, raising several challenges, including the admission of expert testimony, the adequacy of jury instructions regarding his "Indian" status, the sufficiency of evidence for premeditated first-degree murder, and whether premeditated first-degree murder qualifies as a crime of violence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that any error in admitting expert testimony was harmless due to the overwhelming evidence against Bagola. The court also determined that the district court's failure to properly instruct the jury on the "Indian" status element did not affect Bagola's substantial rights, given the uncontroverted evidence of his tribal membership. Additionally, the court held that there was sufficient evidence to support the jury's finding of premeditation. Finally, the court ruled that premeditated first-degree murder is categorically a "crime of violence" under 18 U.S.C. § 924(c). The Eighth Circuit affirmed Bagola's convictions. View "United States v. Bagola" on Justia Law

Dalonte Foard and his uncle, Thomas Holbert, picked up two foster youths, M.D. and M.J., from their foster home. M.D. and M.J. were taken to a motel where Holbert took provocative photos of them to include in online prostitution advertisements. Holbert attempted to set up the minors with sex buyers but was unsuccessful. Eventually, M.D. left, leaving M.J. at the motel with Foard and his girlfriend, Tashian Hickman. Foard pressured M.J. to engage in sex acts and later created an online prostitution advertisement for her. A sex buyer, Michael Blue, paid for sex acts with M.J., and Foard took a portion of the money. M.J. was later returned to her foster home, and her foster mother called the police.A grand jury indicted Foard for conspiracy to engage in sex trafficking and sex trafficking of M.J. and M.D. The jury found Foard guilty of conspiracy to engage in sex trafficking and sex trafficking of M.J. but acquitted him of sex trafficking M.D. The United States District Court for the District of Nebraska sentenced Foard to 45 years of imprisonment followed by lifetime supervision.The United States Court of Appeals for the Eighth Circuit reviewed the case. Foard raised several challenges, including issues with jury instructions, admission of out-of-court statements, denial of his motion for acquittal, sentencing adjustments, and the substantive reasonableness of his sentence. The court found that the jury instructions permissibly narrowed the indictment, the out-of-court statements were admissible under the co-conspirator exclusion to hearsay, and there was sufficient evidence to support the jury's verdict. The court also upheld the sentencing enhancements for undue influence of a minor, use of electronic communications, vulnerable victim, and obstruction of justice. The court found no error in the district court's denial of a mitigating role reduction and concluded that the 45-year sentence was substantively reasonable. The Eighth Circuit affirmed the district court's judgment. View "U.S. v. Foard" on Justia Law

Jackie Davidson was convicted of assaulting federal officers with a deadly weapon and discharging a firearm during a crime of violence after he shot at an SUV, mistakenly believing it was driven by a man named Omar, who Davidson suspected of criminal activities. The SUV was actually driven by federal law enforcement officers. Davidson fired at the vehicle after it passed him, thinking he was in imminent danger.The United States District Court for the Eastern District of Arkansas barred Davidson from arguing self-defense at trial, concluding that he did not act out of a reasonable belief of imminent harm. The court also ruled that under United States v. Feola, the government did not need to prove that Davidson knew his victims were federal officers. At trial, the jury found Davidson guilty of assaulting federal officers and discharging a firearm during a crime of violence, but acquitted him of other charges. Davidson was sentenced to 120 months and 1 day in prison and 3 years of supervised release.The United States Court of Appeals for the Eighth Circuit reviewed Davidson's appeal, which raised three arguments: the district court erred in prohibiting his self-defense claim, the government needed to prove he knew his victims were federal officers, and the jury instructions were flawed. The appellate court affirmed the district court's decisions, holding that Davidson did not meet the burden of production for a self-defense claim, Feola was still binding precedent, and the jury instructions were adequate. The court concluded that Davidson's conviction should be upheld. View "United States v. Davidson" on Justia Law