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

The Eighth Circuit affirmed defendant's conviction and sentence for making a false material declaration before a jury. The court held that the district court properly excluded evidence of defendant's duress defense where she failed to present sufficient evidence to support a finding that she faced a present, imminent, and impending threat. She also failed to present sufficient evidence to support a finding that she had no reasonable, legal alternative to giving false testimony.The court also held that the district court did not err in applying a cross-reference under USSG 2X3.1, which resulted in a 20 base level offense for the underlying offense. Furthermore, the district court did not err by applying the four-level specific offense characteristic for the criminal offender's possessing the gun in connection with another felony offense. View "United States v. Myles" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to possessing child pornography. The court held that ample evidence showed that defendant knowingly distributed child pornography and the distribution enhancement was properly applied; defendant's sentence was substantively reasonable where the district court did not err in weighing the 18 U.S.C. 3553(a) factors; and the six special conditions of supervised release were reasonably related to defendant's offense, history, characteristics, and were needed to protect the public from a dangerous child sexual predator. View "United States v. Cramer" on Justia Law

The Eighth Circuit affirmed the district court's denial of movant's motion to vacate his sentence under 28 U.S.C. 2255 based on the alleged ineffective assistance of counsel. Movant was sentenced after he pleaded guilty to receipt and distribution of a visual depiction involving the use of a minor engaging in sexually explicit conduct.The court held that movant's sentencing argument under USSG 2G2.2(b)(1) had no merit, and counsel was not ineffective in declining to advance it. The court held that, in view of the risks involved in pursuing the alternative course, and the limited potential reward, there is ample reason to conclude that counsel's decision to withdraw the objection to the two-level distribution enhancement pursuant to 2G2.2(b)(3)(F) was objectively reasonable. Finally, because the reasonableness of counsel's performance is an objective question, it was permissible for the district court to resolve the motion without testimony from counsel about his subjective reasoning on this point. View "Haney v. United States" on Justia Law

Plaintiffs filed suit alleging that Falcon Jet violated the Fair Labor Standards Act and the Arkansas Minimum Wage Act when it failed to pay team leaders and production liaisons not less than one and one-half times their regular rates for hours worked in excess of forty per week after June 6, 2014. Sixteen other team leaders and production liaisons joined the action. Falcon Jet claimed exemptions for executive or administrative employees and highly-compensated employees. The district court held that the exemptions do not apply and awarded plaintiffs liquidated damages.The Eighth Circuit reversed and held that the district court erred in granting plaintiffs summary judgment on the limited record, because the record did not establish that every plaintiff was not an exempt employee for the entire period at issue. Accordingly, the court remanded for further proceedings. View "Coates v. Dassault Falcon Jet Corp." on Justia Law

The Eighth Circuit reversed defendant's conviction for escaping from custody after he arrived two days late at a halfway house following a blizzard. The court held that the evidence was insufficient to show he willfully left the extended limits of confinement, because a reasonable jury could not infer that defendant willfully failed to call authorities or arrive at the halfway house as the furlough application required. In this case, there is no evidence that defendant had access to a phone at any of his stopover points. Accordingly, the court remanded for further proceedings. View "United States v. Little" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for four counts of sexual abuse, eight counts of aggravated sexual abuse of a child, and three counts of abusive sexual contact for abusing four different victims. The court held that the district court did not abuse its discretion by determining that the statements made by defendant's girlfriend before she died failed to meet the requirement of Federal Rule of Evidence 807(b) for the necessary circumstantial guarantees of trustworthiness.The court also held that the district court did not err by applying a sentencing enhancement for obstruction of justice under USSG 3C1.1 for each of the four charged victims. Finally, the court rejected defendant's argument that the district court's application of the obstruction of justice enhancements made his sentence substantively unreasonable. View "United States v. Bruguier" on Justia Law

Plaintiff, a Satanist, filed suit challenging a Missouri law requiring her to certify that she has had a chance to review certain information before having an abortion. Plaintiff alleged that Missouri's informed-consent law violates the Establishment and Free Exercise Clauses of the First Amendment.The Eighth Circuit affirmed the district court's dismissal of plaintiff's First Amendment claims. As a preliminary matter, the court did not permit plaintiff to plead a new undue burden claim at this stage in the proceedings because Missouri lacked fair notice of the claim based on the complaint itself. On the merits, the court held that the statute's requirement that every woman seeking an abortion in Missouri must first receive a state-authored informed-consent book does not violate the Establishment Clause because alignment to a religious belief alone is not enough to show a violation. The court also held that the requirement that plaintiff certify that she had a chance to view an ultrasound at least 24 hours prior to the procedure and that she received the informed consent booklet does not violate her free-exercise rights. In this case, plaintiff makes no argument that the informed-consent law is anything other than neutral and generally applicable. View "Doe v. Parson" on Justia Law

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court held that defendant's plea was neither knowing nor intelligent because he did not have real notice of the true nature of the charge against him, the first and most universally recognized requirement of due process. Furthermore, defendant's plea also violated Rule 11 because the district court did not advise him of the knowledge-of-status element established by Rehaif v. United States, 139 S. Ct. 2191, 2200 (2019).However, the court held that defendant's constitutionally invalid plea was not structural error and a defendant can only satisfy plain error review by showing that the error affected his or her substantial rights. In this case, defendant has not shown that either the constitutional error or the Rule 11 error affected his substantial rights and therefore he is not entitled to relief on plain error review. View "United States v. Coleman" on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging a claim for unreasonable search in violation of the Fourth and Fourteenth Amendments. The district court granted the officer qualified and official immunity.Reviewing de novo, the Eighth Circuit held that it lacked jurisdiction to review the appeal based on the incomplete record. Accordingly, the court dismissed the appeal and remanded to the district court for further proceedings. View "M.A.B. v. Mason" on Justia Law

The Eighth Circuit affirmed defendant's conviction for one count of conspiracy to distribute 50 grams or more of actual methamphetamine, and some amount of hydromorphone and oxycodone. The court held that the evidence was sufficient to show that defendant conspired to distribute methamphetamine, hydromorphone, or oxycodone.The court rejected defendant's evidentiary challenges, holding that the district court did not abuse its discretion by denying defendant's motion in limine to exclude evidence of his affiliation with a gang, by permitting the government to introduce evidence of his prior convictions under Fed. R. Evid. 404(b), and by limiting his ability to use Fed. R. Evid. 609 evidence to cross examine government witnesses. View "United States v. Shelledy" on Justia Law