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

Gabriel White Plume, Sr. was convicted of multiple charges, including witness tampering and assault, following a violent incident involving his girlfriend, CLS. On January 10, 2023, White Plume, while under the influence of alcohol and methamphetamine, assaulted CLS with the help of his friend, Edison Jumping Eagle. White Plume choked CLS, forced her to perform oral sex, and inflicted severe physical injuries, including a deep laceration in her vagina. CLS was treated at a hospital for extensive injuries, including bruises, bite marks, and cigarette burns. White Plume recorded part of the assault, and these recordings were used as evidence at trial.The United States District Court for the District of South Dakota indicted White Plume on nine counts, including sexual assault, assault, witness tampering, and distribution of a controlled substance. A jury convicted him on eight of the nine counts, and he was sentenced to 480 months of imprisonment. White Plume appealed, arguing insufficient evidence for his convictions on witness tampering and assault, and claimed double jeopardy for three of the charges.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found sufficient evidence to support the jury's verdict on witness tampering, noting that White Plume attempted to persuade CLS to recant her statements through his daughter and direct communication. The court also upheld the assault conviction, determining that the evidence of CLS’s substantial bruising was sufficient to meet the statutory definition of substantial bodily injury. Regarding the double jeopardy claim, the court applied the Blockburger test and concluded that each of the three challenged charges required proof of an element not required by the others, thus rejecting the double jeopardy argument. The Eighth Circuit affirmed the district court’s judgment. View "U.S. v. Plume" on Justia Law

Christopher Edwards was convicted of conspiracy to distribute controlled substances and possession with intent to distribute a controlled substance. Law enforcement began investigating Edwards after receiving tips about his drug activities. They tracked his movements and conducted a controlled buy from his co-conspirator, Chloe Johnson. Multiple search warrants were executed, leading to the discovery of various drugs and cash. A significant amount of cocaine was found in Edwards's rental car, but it was not listed on the search warrant inventory.The United States District Court for the District of Minnesota denied Edwards's motion to suppress the evidence, finding the search warrants were supported by probable cause. Edwards's subsequent motion to suppress the cocaine due to a chain of custody issue was denied as untimely. At trial, the court overruled Edwards's objections regarding the cocaine's chain of custody and its altered appearance in photographs. The jury found Edwards guilty on both counts and attributed specific drug quantities to him. The court applied a career-offender enhancement based on Edwards's prior felony convictions and sentenced him to 220 months' imprisonment and 8 years of supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case. Edwards argued that the district court erred in admitting the cocaine into evidence and in its jury instructions regarding drug quantities and knowledge of specific drug types. The appellate court found no abuse of discretion in admitting the cocaine, noting that any chain of custody defects went to the weight of the evidence, not its admissibility. The court also upheld the jury instructions, stating that the government need not prove Edwards knew the specific drug types involved in the conspiracy. The appellate court affirmed the district court's judgment, including the career-offender enhancement and the imposed sentence. View "United States v. Edwards" on Justia Law

In June 2018, Jonathan Stacy Berrier was indicted for enticing a minor in Arkansas to engage in sexual activity and traveling interstate for illicit sexual conduct. After the government presented incriminating communications between Berrier and the minor, Berrier pleaded guilty to the enticing charge in September 2020. The plea agreement included sentencing stipulations but allowed the government to present additional facts. At the plea hearing, Berrier admitted to one instance of sexual activity with the minor but denied multiple encounters.The United States District Court for the Eastern District of Arkansas initially sentenced Berrier to 180 months, granting an upward variance based on disputed facts in the Presentence Investigation Report (PSR). Berrier appealed, and the Eighth Circuit remanded for resentencing due to procedural errors, including the late submission of the revised PSR. On remand, the district court appointed new counsel for Berrier. Berrier filed a pro se motion to withdraw his guilty plea, citing ineffective assistance of counsel and prosecutorial misconduct, which the court denied without a hearing.The United States Court of Appeals for the Eighth Circuit reviewed the case. Berrier argued that the government breached the plea agreement by seeking an upward variance and that the district court erred in denying his motion to withdraw the plea without a hearing. The Eighth Circuit found that the government did not breach the plea agreement, as it only stipulated to the base offense level and specific increases, not variances. The court also held that Berrier's claims of ineffective assistance were contradicted by his statements at the plea hearing and were insufficient to warrant a hearing. The Eighth Circuit affirmed the district court's denial of Berrier's motion to withdraw his plea and the reimposed 180-month sentence. View "United States v. Berrier" on Justia Law

Marlon Winborn was charged with unlawfully possessing a firearm as a felon after police arrested him following an investigatory stop. The stop was initiated based on multiple 911 calls reporting gunshots in an area known for similar incidents. The third caller provided specific details, including seeing two masked individuals near a red Saturn without a front license plate. When officers arrived at the scene, they found a red Saturn with occupants, including Winborn in the driver’s seat. During the stop, officers observed what they suspected to be marijuana and subsequently found firearms in the vehicle.The United States District Court for the District of Minnesota denied Winborn’s motion to suppress the evidence obtained from the stop, ruling that the officers had reasonable suspicion to conduct the stop. Winborn then pled guilty to the firearm charge but reserved the right to appeal the denial of his motion to suppress.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the officers had reasonable suspicion to make the initial stop based on the totality of the circumstances, including the 911 calls and the observations made at the scene. The court emphasized that the reliability of the third caller’s tip, combined with the officers’ observations and the proximity in time and location to the reported gunshots, justified the investigatory stop. The court concluded that the district court did not err in denying the motion to suppress. View "United States v. Winborn" on Justia Law

Kylee Starr pleaded guilty to three controlled substance offenses in October 2022. She was released to a sober living home while awaiting sentencing. In March 2023, the district court sentenced her to time served and 48 months of supervised release, granting safety-valve relief and a substantial assistance downward departure. Starr relapsed on fentanyl in June 2023 and was terminated from the sober living home. Her probation officer filed a petition to revoke her supervised release, and Starr admitted to committing Grade C violations.The United States District Court for the District of North Dakota revoked her supervised release and imposed a 24-month imprisonment sentence, followed by three years of supervised release. The court varied upward from the advisory guidelines range of 3 to 9 months, citing the seriousness of Starr's violations and the danger she posed to others. The government had requested a 9-month sentence, while Starr's defense counsel argued for a 3-month sentence, emphasizing her previous year of sobriety and the potential negative impact of a long incarceration on her recovery.The United States Court of Appeals for the Eighth Circuit reviewed the substantive reasonableness of the revocation sentence under the deferential abuse-of-discretion standard. The court affirmed the district court's decision, noting that the district court had considered the relevant sentencing factors and the advisory guidelines. The court found that the district court did not abuse its discretion by imposing an above-range sentence, given Starr's repeated inability to adhere to supervised release conditions and the danger she posed to others. The court also noted that the district court had considered mitigating factors but afforded them less weight than Starr would have preferred. View "United States v. Starr" on Justia Law

In 1993, Darrin Rick pleaded guilty to criminal sexual conduct involving four developmentally disabled girls and one seven-year-old boy. After failing to complete sex-offender treatment programs in prison, Hennepin County petitioned to civilly commit him as a "sexually dangerous person." Three psychologists, including two appointed by a Minnesota district court, agreed that Rick met the criteria for commitment. Consequently, he was committed to the Minnesota Sex Offender Program. In 2007, the Minnesota Supreme Court declined further review of his case. Years later, new expert reports suggested that the actuarial tools used to justify his commitment had overestimated his risk of recidivism.Rick filed a federal habeas petition, arguing that the new evidence showed he was "actually innocent" of being a sexually dangerous person. The United States District Court for the District of Minnesota entertained the petition under the actual-innocence exception, finding that the reliance on outdated expert reports and actuarial data violated his due-process rights. The court granted habeas relief, allowing Rick to bypass the one-year statute of limitations for filing the petition.The United States Court of Appeals for the Eighth Circuit reviewed the case and focused on whether the actual-innocence exception could apply to civil commitments. The court concluded that the exception, traditionally used in criminal cases to address wrongful convictions, does not extend to civil commitments. The court emphasized that the exception is meant for cases involving criminal guilt or innocence, not predictions of future dangerousness. Consequently, the Eighth Circuit reversed the district court's grant of habeas relief and remanded the case for denial of Rick's petition. View "Rick v. Harpstead" on Justia Law

Robert Hansen was convicted by two juries of multiple gun and drug crimes. The district court sentenced him to 300 months in prison for the first case and 120 months for the second, to run concurrently. Hansen appealed, seeking to overturn both verdicts and vacate his sentences.In the first case, Hansen was involved in three controlled buys of methamphetamine, which led to search warrants being executed at three locations. Investigators found drugs and guns at these locations, leading to Hansen's indictment on several charges, including conspiracy to distribute methamphetamine and unlawful possession of firearms. The jury convicted him on most charges, but the district court ordered a retrial due to juror misconduct. In the retrial, Hansen was again convicted on most charges. In the second case, Hansen was charged with unlawful possession of firearms found at two different locations. The jury convicted him on both counts.Hansen argued on appeal that there was insufficient evidence to support his convictions, that the district court erred by not including a special interrogatory in the verdict form, and that his counsel was ineffective. He also challenged the admission of certain testimony under Federal Rule of Evidence 404(b) and the denial of his motion for a new trial. Additionally, he contested the drug quantity finding and the use-of-violence enhancement at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions. The court found that the evidence was sufficient to support the convictions and that the jury instructions and verdict form were adequate. The court also held that the admission of testimony under Rule 404(b) was not an abuse of discretion and that the denial of a new trial was justified. Finally, the court upheld the sentencing enhancements, finding no clear error in the district court's factual findings. The Eighth Circuit affirmed the district court's judgments. View "United States v. Hansen" on Justia Law

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