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

The Eighth Circuit affirmed the district court's imposition of the career offender enhancement to defendant's sentence after he pleaded guilty to conspiracy to distribute 500 grams or more of methamphetamine and to possession of a firearm in furtherance of a drug trafficking offense. The court concluded that the logic of its circuit precedent dictates that Iowa domestic abuse assault with intent to inflict serious injury is a crime of violence. Accordingly, there was no error in the district court's determination that defendant's prior conviction for Iowa domestic abuse assault qualified as a crime of violence. View "United States v. Tinlin" on Justia Law

The Eighth Circuit affirmed defendant's 28 month sentence imposed after he violated his fourth term of supervised release. Although the district court did not recite the guideline range at the hearing, the record shows that the advisory range was properly calculated in a violation worksheet that the probation office submitted to the court several days before the proceeding. The court has previously said that where the court has before it a revocation packet from the probation office that includes the proper guideline analysis, and the defendant requests a sentence recommended by the probation office, then there is no plain error in the court’s failure to mention the guidelines. In this case, the violation worksheet calculated the correct advisory range and defendant has failed to establish that the district court obviously failed to calculate and consider the guideline range.The court also concluded that there was no obvious error in the adequacy of the district court's sentencing explanation, and defendant has not shown a reasonable probability that a more detailed explanation would have resulted in a more favorable sentence. Finally, the court concluded that defendant's sentence was reasonable given his track record of incorrigibility and it was not unreasonable for the district court to impose a term of imprisonment that exceeded the advisory guideline range, discharging him from supervision. View "United States v. Elbert" on Justia Law

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

Plaintiff filed suit against IML in state court, alleging claims for breach of contract, promissory estoppel, unjust enrichment, equitable estoppel, and fraudulent misrepresentation. After removal to federal court, the district court found that there was a genuine dispute of material fact as to whether the parties had agreed to arbitrate and then denied IML's motion to compel arbitration.The Eighth Circuit remanded to the district court for a trial to determine whether an arbitration agreement exists. In this case, viewing the record in the light most favorable to plaintiff, the district court found that material facts remain in dispute as to whether the parties agreed to arbitrate. The court explained that the next step should have been to hold a trial pursuant to 9 U.S.C. 4. View "Duncan v. International Markets Live, Inc." on Justia Law

The Eighth Circuit affirmed the district court's award of attorney's fees to plaintiffs in an action alleging violations of the McKinney-Vento Act (MVA), the Rehabilitation Act (RA), the Americans with Disabilities Act (ADA), and the Equal Protection Clause of the Fourteenth Amendment. The court declined to take up an issue regarding whether the MVA provides a private right of action for students experiencing homelessness and their families for the first time on appeal. The court explained that the State never raised an argument in the district court that the students and their mothers lacked a cause of action or that they could not recover attorneys' fees for time spent pursuing the claim. The court also concluded that the district court did not abuse its discretion in making the State jointly and severally liable for the fees imposed against the district defendants. View "Scott C. v. Missouri Department of Elementary and Secondary Education" 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 Estate of Willy Fritz filed suit against a police officer and the City of West Union, alleging a claim of recklessness, among other things, after the officer's police cruiser crashed into Fritz's truck which led to Fritz's death. The district court granted defendants' motion for summary judgment.The Eighth Circuit affirmed, concluding that the evidence does not establish recklessness under Iowa law where it failed to show that the officer had conscious knowledge of a dangerous situation as his police cruiser crossed a four-way intersection. In this case, the police cruiser approached the intersection, traffic had stopped, the road was straight, and the "lane ahead" was clear. Therefore, the district court did not err in granting summary judgment. View "Estate of Fritz v. Henningar" on Justia Law

In a previous opinion, the district court affirmed a $34.3 million jury verdict in favor of the class represented by plaintiff and reversed the district court's denial of prejudgment interest. The court then remanded the matter for the district court to reconsider plaintiff's motion for prejudgment interest. State Farm appealed.The Eighth Circuit affirmed the district court's award of prejudgment interest, concluding that plaintiff was entitled to prejudgment interest at the 4% rate contained in the contract, and the district court did not err in calculating the amount of interest due and awarding plaintiff $4,521,674 in prejudgment interest. View "Vogt v. State Farm Life Insurance Co." on Justia Law