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

Edrick Denorris Ellis was stopped by Arkansas State Trooper Dean Pitchford for a hanging taillight. Ellis, a passenger, fled and was pursued by Trooper Cleyton McDonald. During the chase, Ellis threw an object over a fence, which was later found to be a 9mm handgun. Ellis was charged with being a felon in possession of a firearm. At trial, multiple troopers testified, and dashboard camera footage was presented showing Ellis tossing an object. The jury found Ellis guilty.The United States District Court for the Eastern District of Arkansas sentenced Ellis to 120 months’ imprisonment and 2 years of supervised release. Ellis appealed, challenging the sufficiency of the evidence and the classification of his prior Arkansas robbery convictions as crimes of violence under the Sentencing Guidelines.The United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirming the conviction. The court found that the evidence, including the dashboard camera footage, was sufficient for a reasonable jury to conclude that Ellis knowingly possessed the firearm. The court also reviewed the classification of Ellis' prior robbery convictions for plain error, as Ellis did not raise this argument in the lower court. The court held that Arkansas robbery qualifies as a crime of violence under the enumerated offenses clause of the Sentencing Guidelines, referencing previous decisions that align Arkansas robbery with generic robbery. The court concluded that there was no error in the district court's calculation of Ellis' Sentencing Guidelines range or the sentence imposed. The judgment of the district court was affirmed. View "United States v. Ellis" on Justia Law

Larry Bradley was convicted of four gun offenses related to the fatal shooting of Thomas Willett. Bradley admitted to shooting Willett but claimed it was in self-defense as Willett allegedly came at him with a hatchet. Bradley was charged with being a felon in possession of a firearm, stealing a firearm, possession of a stolen firearm, and receiving a firearm while under indictment. He was convicted on all counts.The United States District Court for the Western District of Missouri initially applied the United States Sentencing Guidelines (USSG) cross-reference for voluntary manslaughter, rejecting Bradley's self-defense claim. The court considered witness testimony and the Presentence Investigation Report (PSR), which contained conflicting accounts of the incident. The court found the testimony of Dena Bunger, a witness to the shooting, credible and determined that Bradley did not act in self-defense. Bradley was sentenced to 120 months' imprisonment.Bradley appealed, arguing that the district court erred in applying the cross-reference and that Counts 2 and 3 were multiplicitous. The Government agreed that it had erroneously described Bunger’s testimony and that Counts 2 and 3 were multiplicitous. The United States Court of Appeals for the Eighth Circuit vacated and remanded the case. On remand, the district court dismissed Count 3 and reaffirmed the application of the voluntary manslaughter cross-reference, sentencing Bradley to 108 months' imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no clear error in the district court’s factual findings. The court affirmed the district court’s application of the voluntary manslaughter cross-reference, noting that the district court’s credibility determinations and inferences from the evidence were entitled to deference. The judgment of the district court was affirmed. View "United States v. Bradley" on Justia Law

Sioux Steel Company, a South Dakota corporation, designed and manufactured a new line of hopper bins for grain storage. After selling one of these bins to a distributor in Mexico, the bin failed catastrophically, causing fatalities and property damage. Sioux Steel had an insurance policy with the Insurance Company of the State of Pennsylvania (ISOP), which included a professional services exclusion. ISOP denied coverage based on this exclusion, leading Sioux Steel to settle with the affected party without ISOP's involvement.The United States District Court for the District of South Dakota granted summary judgment in favor of ISOP, finding that the professional services exclusion in the insurance policy was unambiguous and applicable, thus precluding coverage. The court also dismissed Sioux Steel's claims for bad faith, punitive damages, and attorney's fees.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the professional services exclusion was clear and unambiguous. The exclusion applied because the damage arose from professional engineering services provided by Sioux Steel's employee and an external engineering firm. The court also found that ISOP did not breach its duty to defend, as no civil proceeding or alternative dispute resolution process had been initiated with ISOP's consent. Consequently, Sioux Steel's claims for breach of contract and insurance bad faith were dismissed, and the district court's judgment was affirmed. View "Sioux Steel Company v. Ins. Co. of the State of PA" on Justia Law

Kyle Syphax was sentenced to 84 months in prison after pleading guilty to possession of a firearm by a felon, violating 18 U.S.C. § 922(g)(1) and 18 U.S.C. § 924(a)(8). He contested the calculation of his criminal history score, which was based on his prior convictions.The United States District Court for the Eastern District of Missouri calculated Syphax's criminal history score by assigning three points for each of his three state felony cases, resulting in a subtotal of 13 criminal history points. This calculation included points for committing the federal offense while on probation. Syphax argued that his criminal history score should be lower, asserting that only one of his prior sentences should receive three points, while the others should receive one point each, resulting in a total of 10 points.The United States Court of Appeals for the Eighth Circuit reviewed the district court's interpretation of the sentencing guidelines de novo and its factual findings for clear error. The court found that the district court correctly calculated Syphax's criminal history score. The court determined that Note 11 to Section 4A1.2 of the sentencing guidelines, which Syphax relied on, did not apply because the state court had ordered three separate revocations for his three state felony cases. The court concluded that each case should receive three points, as the state court revoked probation and ordered prison sentences in separate cases.The Eighth Circuit affirmed the district court's judgment, upholding Syphax's 84-month prison sentence. View "United States v. Syphax" on Justia Law

LaVance LeMarr Cooper was found guilty of being a drug user in possession of a firearm after officers discovered a Glock 20 pistol in his car during a traffic stop. Cooper admitted to smoking marijuana three to four times a week, including two days before the traffic stop. He was sentenced to 37 months in prison by the United States District Court for the Northern District of Iowa.The district court, referencing the case United States v. Veasley, acknowledged that as-applied challenges to the drug-user-in-possession statute are available but concluded that Congress's decision to disarm drug users as a class left no room for individual assessments. Cooper argued that his prosecution under 18 U.S.C. § 922(g)(3) violated the Second Amendment, but the district court disagreed, maintaining that the statute applied categorically to all drug users.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that while keeping firearms out of the hands of drug users does not always violate the Second Amendment, it can in certain circumstances. The court emphasized that historical analogues, such as the confinement of the mentally ill and going-armed laws, support disarmament only when the individual poses a danger to others. The court found that the district court erred in not considering whether Cooper's marijuana use made him dangerous or induced terror.The Eighth Circuit vacated the district court's judgment and remanded the case for a reexamination of Cooper's motion to dismiss the indictment, instructing the lower court to determine whether Cooper's specific circumstances justified disarmament under the Second Amendment. View "United States v. Cooper" on Justia Law

Charles Hamber was convicted by a jury of being a felon in possession of a firearm after a pistol was found on him during a traffic stop. The incident occurred when Officer William Ware responded to a call about a truck idling at a gas station for over two hours. Upon arrival, Officer Ware found Hamber asleep in the truck. After waking him, Hamber provided his driver's license, and a check revealed he was potentially a convicted felon. Officer Ware asked Hamber to step out of the vehicle and, after obtaining consent, conducted a pat-down search, finding a loaded pistol and a knife. Hamber was arrested and charged.In the United States District Court for the Eastern District of Missouri, Hamber moved to suppress the pistol, arguing it was obtained through an unlawful stop and search. The magistrate judge recommended denying the motion, finding that Officer Ware had reasonable suspicion to search Hamber and that Hamber had voluntarily consented to the search. The district court adopted this recommendation, and Hamber was convicted following a jury trial.The United States Court of Appeals for the Eighth Circuit reviewed the case. Hamber conceded that the initial stop was lawful and did not challenge the voluntary nature of his consent to the search. The primary issue on appeal was whether Officer Ware unlawfully extended the stop after determining Hamber's license was valid. The court held that Officer Ware had reasonable suspicion to extend the stop to ensure Hamber was fit to drive, given the circumstances of finding him asleep at the wheel in an area known for narcotic use. The court concluded that the stop did not end until after Hamber consented to the search and the pistol was found. The court affirmed the district court's denial of the motion to suppress and upheld Hamber's conviction. View "United States v. Hamber" on Justia Law

Keshon Baxter was charged with being an unlawful user of a controlled substance in possession of a firearm. In May 2023, police encountered Baxter in Des Moines, Iowa, and found a loaded pistol and a baggie of marijuana on him. Baxter moved to dismiss the charge, arguing that the statute under which he was charged, 18 U.S.C. § 922(g)(3), violated the Second Amendment as applied to him and was unconstitutionally vague. The district court denied his motion without a hearing, and Baxter entered a conditional guilty plea, preserving his right to appeal.The United States District Court for the Southern District of Iowa rejected Baxter's arguments. The court found that the government had shown adequate historical analogues to reject the Second Amendment challenge and that Baxter had not demonstrated that the statute was vague as applied to his conduct. Baxter then appealed these rulings.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court did not make sufficient factual findings regarding Baxter's drug use and its overlap with his firearm possession to properly address the as-applied Second Amendment challenge. Therefore, the appellate court remanded the case to the district court for the necessary factual findings. The appellate court affirmed the district court's rejection of Baxter's vagueness challenge, noting that Baxter had not shown that the term "unlawful user" was vague as applied to his conduct. The court also affirmed the rejection of any facial Second Amendment challenge, as it was foreclosed by precedent.In conclusion, the Eighth Circuit affirmed the district court's decision on the vagueness and facial Second Amendment challenges, reversed the ruling on the as-applied Second Amendment challenge, and remanded for further proceedings. View "United States v. Baxter" on Justia Law

Betty Grooms, a Missouri clerk of court, filed a lawsuit under 42 U.S.C. § 1983 against Alice Bell and Judge Steven Privette, alleging violations of her First Amendment rights through discrimination and retaliation, and violations of her substantive due process rights. Grooms, a Republican, had defeated Bell, a Democrat, in an election for Circuit Clerk. Bell, who retained her job under Grooms, later married Privette, a Republican judge. Tensions arose when Bell and Privette were uncooperative with Grooms, leading to Bell's resignation and announcement to run for Circuit Clerk. Privette ordered Grooms to prepare detailed spreadsheets, which he repeatedly rejected, and initiated a contempt prosecution against her, which was eventually dismissed by the Missouri Supreme Court.The United States District Court for the Western District of Missouri dismissed Grooms's claims, ruling that the defendants did not violate her clearly established First Amendment rights and did not violate her substantive due process rights. The court found that the defendants' actions did not constitute adverse employment actions under clearly established law and that Grooms did not suffer a serious deprivation of a protected interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Bell and Privette were entitled to qualified immunity on the First Amendment claim, as Grooms failed to show that their actions constituted adverse employment actions under clearly established law. Additionally, the court found that Grooms's substantive due process claim was inadequate, as she did not demonstrate a serious deprivation of a protected interest. The court concluded that the defendants' conduct did not shock the conscience and did not violate Grooms's substantive due process rights. View "Grooms v. Privette" on Justia Law

Wesley T. Vavra was charged with one count of attempted coercion and enticement of a minor after he arrived at a meeting place with items intended for a minor, believing he was meeting a father and his 8-year-old daughter, "Emma." The "father" was an undercover officer, and "Emma" did not exist. Vavra had engaged in explicit communications with the officer, expressing interest in meeting and engaging in sexual activities with the fictitious child.The United States District Court for the District of Nebraska held a jury trial, during which Vavra's motion for a judgment of acquittal was denied. The jury found Vavra guilty, and the district court sentenced him to 235 months in prison. Vavra appealed the conviction and sentence, arguing insufficient evidence and entrapment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a reasonable jury could find Vavra guilty of attempted coercion and enticement of a minor, as he took substantial steps toward committing the crime, including reinitiating contact and planning a meeting. The court also found that Vavra was not entrapped, as he showed predisposition and was not coerced by the undercover officer. The court affirmed the district court's denial of Vavra's motion for a judgment of acquittal.Regarding the sentence, the Eighth Circuit reviewed for procedural and substantive reasonableness. The court found no procedural errors and held that the district court did not abuse its discretion in sentencing Vavra to 235 months, considering the nature of the offense and Vavra's actions. The court affirmed the judgment, concluding that the sentence was reasonable and appropriate given the circumstances. View "United States v. Vavra" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law