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

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

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of unlawful possession of a firearm as a person previously convicted of a misdemeanor crime of domestic violence. The court held that the district court did not err in imposing a two-level enhancement for obstruction of justice under USSG 3C1.1, based on defendant's false testimony at the sentencing hearing; whether defendant assaulted and attacked someone was plainly material to the district court's sentencing determination under 18 U.S.C. 3553(a); the district court did not err in denying defendant's request for a sentence reduction under USSG 3C1.1 based on acceptance of responsibility; and defendant's sentence was not substantively unreasonable where the district court considered proper factors and reached a reasonable judgment. View "United States v. Montano" on Justia Law

Defendant argued on appeal that his possession of a firearm in June 2018 did not render him ineligible for the "safety valve" on his drug offense from April 2018. The court noted that even aside from 18 U.S.C. 3553(f)(2) and possession of a firearm, the parties disagreed on whether defendant met the requirement of section 3553(f)(5) to provide certain truthful information to the government by the time of the sentencing hearing. In this case, the district court did not resolve the dispute and did not address whether it would sentence defendant to a term of less than 120 months even if the statutory minimum did not apply.The court addressed only the meaning of "offense" in section 3553(f)(2) and held that the term unambiguously limited the offense of conviction. Accordingly, the court remanded for further proceedings on whether defendant possessed a weapon in connection with the offense of conviction and was thus ineligible for safety-valve sentencing. View "United States v. Hodgkiss" on Justia Law

Defendant was convicted in 2003 of producing, transporting, and reproducing child pornography and sentenced to 235 months in prison, followed by 5 years of supervised release. After defendant violated three conditions of supervised release, the district court imposed a new condition requiring polygraph testing.The Eighth Circuit affirmed the district court's imposition of the new condition, holding that defendant's unwillingness to obey rules restricting his access to child pornography shows that polygraph testing is necessary to protect the public from further crimes. The court also held that defendant waived any challenges to the district court's denial of his motions for relief in Appeal No. 19-3362. View "United States v. Smith" on Justia Law

The Eighth Circuit affirmed the district court's decision to modify defendant's two conditions of supervised release imposed after he was convicted in 2003 of producing, transporting, and reproducing child pornography. The court held that, although the district court erred by denying defendant a hearing before modifying Conditions 6 and 7, the error was harmless. In this case, Condition 6 concerned defendant's contact with minors and Condition 7 concerned possession and access to pornography. View "United States v. Smith" on Justia Law

The Eighth Circuit affirmed the district court's reduction of defendant's sentence pursuant to the First Step Act. The court held that the district court accurately noted that the sentence sought to be reduced was a substantial downward variance from the applicable guideline range and concluded the initial variance had eliminated excessiveness the First Step Act was intended to remedy. Furthermore, in evaluating the existing sentence, the district court also considered post-sentence rehabilitation and the 18 U.S.C. 3553(a) sentencing factors. The court also held that there was no procedural or legal error in defendant's 216 month sentence, and the district court did not abuse its substantial sentencing discretion or impose a substantively unreasonable sentence by declining to reduce defendant's sentence below 216 months imprisonment. View "United States v. Harris" on Justia Law

The Eighth Circuit affirmed the district court's reduction of defendant's sentence under 18 U.S.C. 3582(c)(2). The court held that there is no constitutionally protected liberty interest in a discretionary sentence reduction and thus the Due Process Clause does not afford procedural protections to those who seek one. Therefore, the court rejected defendant's claim that the district court should have held an evidentiary hearing before it ruled on his motion. The court also held that there is enough information on the record for meaningful appellate review where the district court quoted the eligibility report and described, among other things, that defendant was the leader of a large drug conspiracy and issued multiple threats to codefendants, an attorney, and a government agent in an attempt to obstruct the investigation against him. View "United States v. Alaniz" on Justia Law

In this action brought under 42 U.S.C. 1983, the Eighth Circuit affirmed the district court's grant of summary judgment in favor of the Police Defendants, a probation officer, various Board Defendants, and the City. Plaintiff filed suit after his convictions related to armed robbery were reversed, and the victim of the crime did not want to testify at another trial, the State declined to retry the case, and plaintiff was released.The court held that the district court correctly granted summary judgment to the Police Defendants on the section 1983 Brady claim, because plaintiff failed to establish a genuine dispute of material fact about whether the Police Defendants violated his constitutionally protected federal rights by suppress or destroying evidence in bad faith. The court also held that, because the record evidence does not create a genuine dispute of material fact regarding plaintiff's fabrication-of-evidence claims, the district court did not err in granting summary judgment to the Police Defendants. Furthermore, the district court court did not err in granting summary judgment to the Police Defendants on plaintiff's failure-to-investigate claim. Finally, the court held that plaintiff's conspiracy and Monell claims necessarily failed. View "McKay v. City of St. Louis" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for two counts of assaulting an intimate partner by strangling, one count of assault with a dangerous weapon, and one count of domestic assault by an habitual offender. Assuming without deciding that defendant did not waive his right to appeal the issue, the court held that defendant failed to show justifiable dissatisfaction with his attorney and the magistrate judge did not err in denying his request for substitute counsel.The court also held that the magistrate judge did not err by continuing the trial over defendant's objection and excluding the time from calculations under the Speedy Trial Act; the district court did not err by denying defendant's mid-trial request to proceed pro se; and the district court properly considered the 18 U.S.C. 3553(a) factors and did not abuse its discretion by imposing an within-Guidelines sentence. View "United States v. Harlan" on Justia Law