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

The Eighth Circuit affirmed defendant's 210 month sentence imposed by the district court after determining that he was a career offender under USSG 4B1.1(a). The court concluded that the district court did not abuse its substantial sentencing discretion in this case. The court explained that, in denying a variance and imposing a 210-month sentence, the district court carefully explained that it had considered the 18 U.S.C. 3553(a) sentencing factors, the sentencing guidelines, the seriousness of the offense conduct, the violations defendant committed when granted pretrial release, his troubled childhood and health conditions as mitigating factors, and his extensive criminal history beginning at age 13 and extending nearly four decades as an adult. View "United States v. Rogers" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for assault resulting in serious bodily injury at a place within the special maritime and territorial jurisdiction of the United States. Defendant was serving a sentence at the U. S. Medical Center for Federal Prisoners in Springfield, Missouri when he entered the room of another inmate and attacked him, causing severe injuries, emergency intubation, and facial reconstruction surgery.The court held that a district court may take judicial notice that a place is within the special maritime and territorial jurisdiction of the United States and not submit that issue to the jury, without violating a defendant's Sixth Amendment rights. Consequently, the court need not address whether the evidence at trial was sufficient for a jury to find that the Center is within the special maritime and territorial jurisdiction of the United States. View "United States v. Love" on Justia Law

The Eighth Circuit affirmed the district court's grant of defendant's motion for modification of his sentence under the First Step Act and imposition of a reduced term of imprisonment. Defendant argues that the district court should have reduced his sentence to time served. The court concluded that the district court did not abuse its discretion in assessing the appropriate reduction where it considered the 18 U.S.C. 3553(a) sentencing factors and explained that a sentence reduction to 454 months satisfied the purposes of sentencing. View "United States v. Davis" on Justia Law

The Eighth Circuit affirmed defendant's 102 month sentence imposed after he pleaded guilty to one count of possession of a firearm by a prohibited person. The court concluded that the district court did not abuse its discretion by imposing a sentence above the advisory Guidelines range where the district court expressed the shooting as "appalling and incredibly dangerous" and expressed concern about the fact that defendant had demonstrated a repeated tendency to engage in violent behavior. Furthermore, the district court considered defendant's history of violence, the need for deterrence, and the importance of imposing a sentence that reflects the seriousness of the offense conduct. In this case, the district court had wide latitude in considering the 18 U.S.C. 3553(a) sentencing factors and the court discerned no clear error in the district court's weighing of those factors. View "United States v. Todd-Harris" on Justia Law

The Eighth Circuit affirmed defendant's 96 month sentence imposed after he pleaded guilty to one count of possession of a firearm by a convicted felon. The court concluded that defendant's within-Guidelines sentence was substantively reasonable. In this case, the district court expressly considered defendant's arguments regarding his traumatic upbringing, the median sentence imposed for all types of firearms offenses, and the connection between his firearm possession and his other felony offense. The court explained that the district court had wide lattitude in weighing the relevant sentencing factors and discerned no clear error of judgment in how the district court weighed the factors here. View "United States v. McDaniels" on Justia Law

Officers responded to a shooting in an apartment building's parking lot. Three victims were transported to the hospital. Officers observed a security camera in the window of apartment 1, pointed toward the parking lot. After interviewing two witnesses, Detective Dunn viewed video footage from a business across the street, which corroborated their account. He learned that Haney, an occupant of unit 1, was involved in a dispute with the sister of two shooting victims. Dunn obtain a warrant to search Unit 1; other officers executed the warrant. An officer moved clothes in the bedroom closet and saw a sawed-off shotgun. He also seized a baggie of white powder, a laptop, and cell phones from the bedroom. Other officers seized cameras, a computer monitor, a Kindle, shotgun shells, pieces of a scale with traces of drug residue, photographs, and documents bearing the names of Haney and Saddler.Saddler later unsuccessfully moved to suppress all evidence seized during the search and an incriminating statement she later made concerning the shotgun. The Eighth Circuit affirmed her subsequent conviction as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The affidavit described facts that connected Haney to the shooting and created a fair probability that evidence that would aid in a particular apprehension or conviction would be found. Dunn’s reliance on the issuance of the warrant was objectively reasonable. In addition, the seizure of the shotgun satisfied the “plain view” exception. View "United States v. Saddler" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence and defendant's sentence imposed after he pleaded guilty to one count of sexual exploitation of children. In this case, federal agents, who were concerned that defendant would destroy evidence if he were allowed to go back inside, entered defendant's house without a warrant and took two computers, a cell phone, and a hard drive.The court concluded that the circumstances were suspicious enough that the agents could have reasonably concluded that there was a substantial chance that defendant was involved in criminal activity. The court also concluded that the officers had a sufficient basis to reasonably believe that defendant would imminently destroy evidence, and thus defendant's conduct created an exigency. Therefore, the warrantless search did not violate the Fourth Amendment because the officers had probable cause, the exigency was real, and it was not of the agents' making. Finally, any error in the district court's statement at sentencing was harmless. View "United States v. Meyer" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to mail fraud and involuntary manslaughter. Defendant's conviction stemmed from his intoxication at work while he was Chief of Pathology for the Veterans Health Care System of the Ozarks (VSHO).The court concluded that, because the VHSO ordered the lookback to benefit patients, rather than to help the criminal investigation, the district court did not err by including it in the loss amount calculation. In this case, the district court found that the loss amount caused by defendant's crimes was over two million dollars, including the cost of the lookback, so it imposed a 16-level enhancement. The court also concluded that the district court did not err in imposing an upward departure for disruption of a government function where the lookback was the largest review ever undertaken by the VA system and multiple VA medical centers were burdened by the extra work. Finally, the court concluded that defendant's sentence was procedurally and substantively reasonable where the district court discussed the 18 U.S.C. 3553(a) factors in length and did not abuse its discretion in sentencing defendant to 240 months in prison. View "United States v. Levy" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of appellant's claims in his motion for 28 U.S.C. 2255 relief on the merits. Assuming without deciding that the government's use of false or discredited scientific evidence could violate a criminal defendant's right to due process, the court concluded that the district court did not err in concluding that defendant failed to prove that his trial and conviction were fundamentally unfair. The court also concluded that it need not decide whether a freestanding actual innocence claim is cognizable because, as in Rouse III, appellant's newly discovered victim recantations, medical science evidence, and juror bias evidence do not meet the extraordinarily high burden of proving actual innocence. The court further concluded that the district court properly concluded that appellant's Sixth Amendment claim, filed over 20 years after his conviction, is untimely under section 2255(f)(1), and even if the claim is not time-barred, it fails on the merits. Finally, the court concluded that the district court did not err in denying an evidentiary hearing. View "Feather v. United States" on Justia Law

The Eighth Circuit affirmed defendant's 63-month sentence imposed after he pleaded guilty to being a felon in possession of a firearm and ammunition. The court concluded that the district court did not clearly err in imposing a four-level sentencing enhancement under USSG 2K2.1(b)(6)(B) for possession of the handgun in connection with another felony offense. In this case, the district court found that the government established by a preponderance of the evidence that defendant possessed a firearm in connection with the North Dakota felony offense of preventing arrest. View "United States v. Nilsen" on Justia Law