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

Police discovered 788 pounds of marijuana and related paraphernalia in a Minnesota warehouse, where Danny Gehl and five others were present. Gehl was charged with conspiracy to distribute marijuana and possession with intent to distribute marijuana. Evidence included surveillance, searches of Gehl’s home, and his phone, revealing marijuana, cash, and drug paraphernalia. Gehl was convicted and sentenced to 120 months’ imprisonment, the mandatory minimum.The United States District Court for the District of Minnesota handled the initial trial. Gehl was convicted on both counts, and the court sentenced him to the mandatory minimum of 120 months. Gehl appealed, arguing insufficient evidence for his conviction and improper denial of safety-valve relief and a minor-participant downward adjustment at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient to support Gehl’s conviction, noting his involvement in the conspiracy and the substantial amount of marijuana involved. The court also found no error in the district court’s denial of safety-valve relief, as Gehl’s proffer was not truthful. Lastly, the court deemed the issue of the minor-participant adjustment moot, as Gehl’s sentence would remain the same due to the mandatory minimum. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Gehl" on Justia Law

Seven states challenged a rule by the Department of Education that modified an existing income contingent repayment (ICR) plan for federal student loans, known as the Saving on a Valuable Education (SAVE) plan. This plan altered payment thresholds, stopped interest accrual, and forgave loan balances after as little as ten years of repayment. The states argued that the Secretary of Education exceeded statutory authority by forgiving loans through an ICR plan.The United States District Court for the Eastern District of Missouri found that the states were likely to succeed on their claim and issued a preliminary injunction against the rule’s early loan forgiveness provisions. Both parties appealed: the federal officials sought to vacate the preliminary injunction, while the states requested a broader injunction.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the states were likely to succeed in their claim that the Secretary’s authority to promulgate ICR plans does not include loan forgiveness at the end of the payment period. The court held that the statute requires ICR plans to be designed for borrowers to repay their loan balances in full through payments that can fluctuate based on income during the payment term. The court determined that the Secretary had exceeded this authority by designing a plan where loans are largely forgiven rather than repaid.The Eighth Circuit affirmed the entry of the preliminary injunction but concluded that the district court erred by not enjoining the entire rule. The court remanded the case with instructions to modify the injunction to cover the entire SAVE Rule and the revived forgiveness provisions under the previous REPAYE plan. View "State of Missouri v. Trump" on Justia Law

The Ferchichi family, natives and citizens of Algeria, sought asylum in the United States due to their son T.F.'s severe spina bifida condition. After being denied adequate medical treatment in Algeria, they raised funds and traveled to the U.S. for T.F.'s surgery. They filed for asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in 2009, claiming persecution based on T.F.'s disability and fear of future persecution due to their public criticism of the Algerian medical system.The Immigration Judge (IJ) denied their claims in 2011, finding that the lack of treatment was due to Algeria's inadequate healthcare system and not persecution based on T.F.'s condition. The IJ also found no evidence of future persecution, noting that their family members in Algeria had not been harmed. The Board of Immigration Appeals (BIA) affirmed the IJ's decision in 2022, agreeing that the refusal to treat T.F. was due to the government's desire to avoid international treatment costs and not persecution.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the BIA's decision, finding substantial evidence that the lack of medical care was due to Algeria's healthcare inadequacies and not persecution. The court also agreed that the Ferchichis did not demonstrate a well-founded fear of future persecution, as their family members in Algeria had not been harmed and the country condition reports did not directly link to their situation. Consequently, the court denied the Ferchichis' petition for review. View "Ferchichi v. Bondi" on Justia Law

Kira Zielinski took her minor child to Mexico to deprive her ex-husband of his parental rights. Upon returning to the United States, she was indicted for international parental kidnapping under 18 U.S.C. § 1204(a). After a bench trial, the United States District Court for the Southern District of Iowa found her guilty and sentenced her to 36 months in prison. Zielinski appealed, arguing that the district court wrongly prevented her from presenting evidence that she fled to protect her child from sexual abuse by the father.The district court ruled that 18 U.S.C. § 1204(c)(2), which provides an affirmative defense for fleeing domestic violence, did not apply because Zielinski did not claim she was a victim of domestic violence herself. The court interpreted the statute to mean that the defense only applies if the defendant, not a third party like Zielinski’s child, suffered domestic violence. Zielinski contended that the statute should cover situations where the defendant aids a third party in escaping domestic violence, but the district court disagreed.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of § 1204(c)(2) de novo and affirmed the lower court’s decision. The appellate court held that the statute’s plain language does not include defense of a third party and that Congress could have explicitly included such language if intended. The court also rejected Zielinski’s arguments that the statute is void for vagueness and that the district court’s interpretation violated the rule of lenity, finding the statute’s language clear and unambiguous. Consequently, the appellate court affirmed the district court’s judgment. View "United States v. Zielinski" on Justia Law

Clint Schram was convicted by a jury of multiple offenses related to his operation of child pornography websites. He was sentenced by the district court to a life term and four concurrent thirty-year terms of imprisonment. Schram appealed, arguing that the evidence was insufficient to support his convictions, that the district court improperly admitted multiple images of child pornography into evidence, and that the district court erred in calculating his guidelines sentencing range and imposing an overlong sentence.The United States District Court for the Western District of Missouri initially reviewed the case. The court found Schram guilty on five counts: four counts of advertising child pornography and one count of engaging in a child exploitation enterprise. The court admitted multiple images of child pornography into evidence and calculated Schram's guidelines sentencing range, ultimately imposing a life sentence and four concurrent thirty-year terms.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient to support Schram's convictions, as the jury could reasonably determine that the images depicted real children. The court also found no reversible error in the district court's admission of multiple images of child pornography, as they were highly probative and not unduly prejudicial. Additionally, the court upheld the district court's calculation of Schram's guidelines sentencing range and found his sentence to be substantively reasonable, given the seriousness of his offenses and his dangerous behavior.The Eighth Circuit affirmed Schram's convictions and sentence, concluding that there was no reversible error in the district court's decisions. View "United States v. Schram" on Justia Law

Isak Aden's ex-girlfriend called 911 on July 2, 2019, reporting that Aden had pointed a gun at her and ordered her to drive. She escaped, and Aden fled into a wooded area. Officers found Aden holding a gun to his head and began negotiating with him. Despite multiple attempts to get him to surrender, Aden refused and moved closer to his gun. Officers devised a tactical plan involving flashbangs and foam bullets to disorient Aden and arrest him. When the plan was executed, Aden reached for his gun, and officers fired lethal rounds, resulting in his death.The United States District Court for the District of Minnesota partially denied the defendants' motion for summary judgment, finding that the officers were not entitled to qualified or official immunity and that the City of Eagan could be liable under Monell. The court dismissed some claims but allowed others to proceed, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the officers' actions were reasonable under the circumstances and that they did not violate Aden's constitutional rights. The court held that the officers were entitled to qualified immunity because their use of force was not excessive. The court also found that the City of Eagan was not subject to Monell liability because there was no constitutional violation by the officers. Additionally, the court held that the officers were entitled to official immunity under Minnesota law, and thus, the City of Eagan was also entitled to vicarious official immunity.The Eighth Circuit reversed the district court's partial denial of summary judgment and remanded the case for entry of summary judgment based on qualified and official immunity. View "Aden v. City of Eagan" on Justia Law

The Mille Lacs Band of Ojibwe and two tribal officers filed a lawsuit in 2017 against Mille Lacs County, the County Attorney, and the County Sheriff. They sought declaratory and injunctive relief to address alleged interference with the Band’s inherent law enforcement authority. The plaintiffs requested the district court to declare that the Band has the inherent authority to establish a police force and authorize its officers to investigate violations of federal, state, and tribal law within the original boundaries of the Mille Lacs Reservation. They also sought a declaration that the Band’s federally-delegated law enforcement authority permits individual Band officers to investigate violations of federal law and arrest suspects within the Reservation’s original boundaries.The United States District Court for the District of Minnesota granted the Band partial summary judgment, affirming that the Mille Lacs Reservation’s boundaries remain as they were under the 1855 Treaty. The court concluded that subsequent treaties and federal statutes did not disestablish the Reservation. In a subsequent order, the court granted the Band’s request for declaratory relief, declaring that the Band possesses inherent sovereign law enforcement authority within the Reservation and that federal statutes and administrative actions give tribal officers federal authority to investigate violations of applicable federal law within the Reservation. The County defendants appealed these rulings.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court concluded that the appeals were moot due to an amendment to the applicable Minnesota statute, effective July 1, 2023, which resolved the concurrent law enforcement authority dispute under state law. The court determined that the district court orders being appealed should be vacated and remanded the case for further proceedings not inconsistent with its opinion. The court emphasized that the Minnesota Legislature’s amendment to the statute granted the Band unqualified law enforcement jurisdiction over all persons within the Reservation’s 1855 boundaries, rendering the primary issue in the case no longer live. View "Mille Lacs Band of Ojibwe v. Madore" on Justia Law

Jon Thomas Kucharo was convicted of transportation and receipt of explosives with intent, and unlawful receipt and possession of destructive devices. He conditionally pleaded guilty after the district court denied his motion to suppress evidence obtained from searches of his van and cell phone. Kucharo appealed, arguing that the district court erred in denying his motion to suppress evidence from the second search of his van and in determining that a state court harassment conviction was not relevant conduct for sentencing purposes.The Scott County District Court convicted Kucharo of first-degree harassment for threatening an Iowa county prosecutor. On the same day, investigators found a pontoon boat damaged by a homemade pipe bomb. Witnesses linked Kucharo to the explosion, and investigators found incriminating evidence in his van and cell phone. Kucharo moved to suppress evidence from the second search of his van, claiming the warrant was invalid due to a false statement in the supporting affidavit. The district court denied the motion, finding no Fourth Amendment violation and that any procedural sentencing error was harmless.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was no Fourth Amendment violation because the affidavit provided sufficient probable cause for the second search warrant, even without the contested statement. The court also found that any procedural error in sentencing was harmless, as the district court stated that the relevant conduct determination did not affect its ultimate sentencing decision. The court affirmed the district court's judgment, upholding Kucharo's conviction and sentence. View "United States v. Kucharo" on Justia Law

Derrecol Jennings was pulled over by St. Louis police officers for having improperly registered plates. A record check revealed active municipal arrest warrants and past felony convictions. Jennings informed officers of a gun under the middle seat, and they found a loaded semiautomatic pistol and magazines with ammunition. Jennings was indicted on one charge of illegally possessing a firearm. He entered a plea agreement, agreeing to plead guilty in exchange for a joint recommendation of 40 months’ imprisonment.The United States District Court for the Eastern District of Missouri sentenced Jennings to 54 months’ imprisonment, despite the joint recommendation. Jennings argued that the government breached the plea agreement by informing the court of a mistake in calculating his criminal history score and that his sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the government did not breach the plea agreement. The government had made the promised recommendation for 40 months’ imprisonment and only mentioned the miscalculation in response to the court’s skepticism. The court also found that Jennings’s 54-month sentence was substantively reasonable. The district court had adequately considered the relevant factors under 18 U.S.C. § 3553(a) and provided a sufficient explanation for the sentence, emphasizing Jennings’s pattern of legal violations and the need to promote respect for the law.The Eighth Circuit affirmed the 54-month sentence imposed by the district court. View "United States v. Jennings" on Justia Law

In 2022, Theodore Watkins, Jr. approached an elderly woman's home, offering to mow her lawn. After she declined, he returned with a handgun, forced his way inside, and demanded money. He took $40 from her purse and searched the house for valuables while holding her at gunpoint. A neighbor witnessed the forced entry and called the police. When officers arrived, Watkins tried to cover up his crime by instructing the homeowner to lie about his presence. The homeowner heard a noise from the furnace vent and suspected Watkins had hidden the gun there. Police later found the firearm in the furnace.The United States District Court for the Western District of Missouri admitted testimony from Sergeant Jeff Pagel, who had discovered the firearm. Watkins objected to this testimony, claiming it was unnoticed expert testimony. The district court overruled the objection, and the jury convicted Watkins of unlawfully possessing a firearm as a felon. He was sentenced to 120 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. Watkins argued that the district court erred in admitting Sergeant Pagel's testimony and that his trial counsel was ineffective for not seeking a continuance. The Eighth Circuit found that Sergeant Pagel's testimony was proper lay opinion based on his firsthand knowledge and personal experience, not requiring expert disclosure. The court also declined to review the ineffective assistance of counsel claim, as the record was not fully developed for such a review. Consequently, the Eighth Circuit affirmed Watkins's conviction. View "United States v. Watkins" on Justia Law