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

The Eighth Circuit reversed the district court's denial of qualified immunity to a deputy sheriff in an action brought by plaintiff, alleging that the deputy sheriff failed to safeguard plaintiff's health and safety and had thereby inflicted injuries upon him. In this case, the deputy sheriff was transporting plaintiff from a medical appointment to the Lee County Correctional Center when city police dispatch advised of an armed robbery nearby. The deputy sheriff drove to the bank with the intent of observing the crime in progress, saw the robbery suspect flee on foot through a vacant lot, and drove his cruiser at approximately 20 to 25 miles per hour through the lot to follow the fleeing suspect. During the pursuit, the suspect shot at the cruiser and the deputy sheriff turned sharply to the right and drove away from the scene. Plaintiff, who was shackled and "thrown around" in the back of the cruiser without a seatbelt during these events, alleged that the deputy sheriff subjected him to cruel and unusual punishment in violation of the Eighth Amendment.The court could not say that the deputy sheriff's actions in this quickly evolving emergency situation were anything more than negligent and thus were clearly insufficient to constitute deliberate indifference. In the absence of a showing that he acted with deliberate indifference, plaintiff has failed to establish the existence of an Eighth Amendment violation. Accordingly, the court remanded for the district court to enter an appropriate order. View "Stark v. Lee County" on Justia Law

The Eighth Circuit concluded that the district court did not err in denying petitioner's motion to vacate, set aside or correct his life sentences. The court concluded that, for purposes of 18 U.S.C. 3559(c)(1), his Iowa convictions for robbery and first-degree robbery were serious violent felonies under the section's enumerated-offense clause. In this case, petitioner cannot show that at the time of sentencing, the district court necessarily relied on section 3559's residual clause in ruling that the aggravated robbery conviction and first-degree robbery conviction were serious violent felonies. Therefore, the district court properly refused to vacate the mandatory life sentence under section 3559. View "Langford v. United States" on Justia Law

The Eighth Circuit affirmed defendant's sentence for distributing a controlled substance near a protected location resulting in death and of possession with intent to distribute a controlled substance near a protected location. The court concluded that the district court did not err by denying defendant's motion to suppress statements made to law enforcement where defendant's statements were consensual and he was never seized or detained. In this case, an officer's statement to "just kinda stay here" was not a seizure or a significant restraint on his movement, and latter statements to stay outside the apartment were made to assure the officer and defendant did not get in the way of medical staff and did not amount to a detention. The court explained that none of the other factors suggest that defendant's encounter had ripened into a seizure or custodial arrest. Even if the court assumed that defendant was seized and in custody at the police station, it is clear from the totality of the circumstances that defendant voluntarily waived his Miranda rights.The court also concluded that the district court did not abuse its discretion by denying defendant's request for a lesser-included-offense jury instruction of possession of heroin for Count II, in addition to distribution of heroin; there was sufficient evidence to support defendant's conviction; and the elements necessary to apply the concurrent sentence doctrine are present in this case. View "United States v. Parker" on Justia Law

After the district court denied defendant's motion to suppress video recordings discovered on his laptop, defendant pleaded guilty conditionally to one count of receiving child pornography and unconditionally to one count of wire fraud.The Eighth Circuit concluded that probable cause combined with exigent circumstances justified the warrantless seizure of defendant's laptop. In this case, the investigators had probable cause to believe the laptop contained evidence of a crime based on an interview with defendant's uncle; the investigators had an objectively reasonable belief that exigent circumstances demanded the seizure; and the fifteen-day delay between seizure and application for the search warrant was not unreasonable. The court also concluded that, even under de novo review, the district court provided an adequate explanation of defendant's within-guidelines-range sentence. The court further concluded that the district court did not rely on clearly-erroneous facts in setting the sentence. However, the imposition of certain special conditions concerning computer use, contact with persons under the age of 18, and participation in sex-offender treatment are vacated and remanded so that the district court may conduct the requisite "individualized inquiry" and make sufficient findings on the record. Furthermore, the special condition concerning possession of use of sexually oriented materials is also remanded to permit the district court to amend its written judgment to conform to its oral pronouncement at sentencing. View "United States v. Mays" on Justia Law

The Eighth Circuit affirmed the district court's denial of Defendant Hanel and Clark's motions to suppress all evidence obtained during a traffic stop. The court concluded that, at the time the officers initiated the traffic stop, they had grounds for reasonable suspicion that the vehicle lacked proper registration in violation of Nebraska law. In this case, although the officers cited the lane change as their reason for stopping the vehicle, they already had an objective basis to stop it when the first two NCIC searches failed to indicate proper registration.The court noted that its holding should not be interpreted as justifying all warrantless vehicle stops based on ambiguous results from data searches. Rather, the court emphasized that its holding depends on the express factual findings that: (1) the NCIC database was not inherently unreliable; (2) the officers were competent in the use of their laptop; and (3) the officers were competent in accessing the NCIC database. View "United States v. Hanel" on Justia Law

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm and ammunition. The court concluded that the district court did not err by denying defendant's motion to suppress the guns and ammunition where officers had probable cause to believe defendant was engaged in criminal activity and their subsequent arrest and search of defendant's vehicle did not violate his Fourth Amendment rights.The court also concluded that the district court did not err in denying defendant's motion to dismiss because defendant's police perjury claims fail under either an abuse of discretion or a de novo standard. The court weighed the Barker factors to determine whether defendant's Sixth Amendment right to speedy trial had been violated and concluded that the factors weigh in favor of the government. In this case, defendant caused most of the delay, nearly half of which was due to his competency proceedings. Furthermore, defendant cannot rely on presumptive prejudice alone and has failed to show actual or specific prejudice. Finally, after excluding all times permitted by the Speedy Trial Act, the court concluded that seventy days had not run at the time defendant pleaded guilty. View "United States v. Flores-Lagonas" on Justia Law

The Eighth Circuit affirmed defendant's conviction for attempted enticement of a minor and travel with intent to engage in illicit sexual conduct, in violation 18 U.S.C. 2422(b) and 2423(b). The court concluded that the district court did not abuse its discretion in excluding testimony from defendant's proposed expert that defendant was not attracted to minors and regarding the role of fantasy in chat rooms; the court need not decide whether the testimony violated Federal Rule of Evidence 704(b) because the evidence supporting defendant's convictions is overwhelming; and any error in excluding the testimony was harmless. The court also concluded that the district court did not abuse its discretion by excluding the fantasy chat room testimony because defendant never used a chat room. Finally, the court concluded that the evidence was sufficient to support defendant's conviction. View "United States v. Willins" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence obtained through the government's interception of his wire and electronic communications. The court concluded that, even if the court orders authorizing the interceptions were insufficient, suppression of evidence is not warranted, because investigators reasonably relied in good faith on the court orders. The court explained that, given the state of the law in 2014, and even today in light of United States v. Brunson, 968 F.3d 325 (4th Cir. 2020), it was objectively reasonable for investigators to rely on the court orders at issue to intercept defendant's communications. View "United States v. Friend" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress after he entered a conditional plea of guilty to possession with intent to distribute more than 5 kilograms of cocaine. The court concluded that the trooper's determination that the vehicle was following too closely in violation of the relevant statute was objectively reasonable. In the alternative, the district court did not clearly err in finding that nothing prevented the driver from slowing down sooner and maintaining a reasonable and prudent distance behind the pickup.The court also concluded that the stop was not improperly prolonged once the trooper indicated he did not intend to issue a ticket, because the trooper was clearly conducting routine traffic violation-related tasks. In this case, the trooper asked the two men questions related to their destination, route, and purpose and questions were posed while awaiting dispatch's response to his criminal histories check. Furthermore, the driver of the car consented to a search of the rental vehicle, and defendant, a passenger, posed no objection when informed of the impending search and stood by quietly as it took place. View "United States v. Cox" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of knowingly possessing with intent to distribute at least fifty grams of a mixture or substance containing crack cocaine. The court concluded that the district court did not abuse its discretion in denying a sentence reduction under the First Step Act. In this case, the district court explained that defendant's offense conduct was very serious where his conviction involved possessing 116 grams of cocaine base while in a car with an eleven-year-old child. Furthermore, the district court relied on defendant's extensive criminal history, and noted that while imprisoned, defendant twice fought with other inmates. View "United States v. Black" on Justia Law