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

The guardian of John Raines IV's estate filed suit against defendants after Raines was shot at twenty-one times and became paralyzed from his gunshot injuries. The Eighth Circuit dismissed defendants' appeal from the district court's denial of summary judgment based on qualified immunity. The court held that, while it had jurisdiction to determine whether conduct constituted a violation of clearly established law, it lacked jurisdiction to determine whether evidence could support a finding that a particular conduct occurred at all. In this case, whether the officers reasonably believed Raines posed a sufficient threat depended on what occurred, and the district court was unable to make this determination based on the evidence presented. Therefore, the court lacked jurisdiction to determine the key factual question about whether Raines advanced on the officer just before being shot. View "Raines v. Burningham" on Justia Law

The Eighth Circuit affirmed defendant's conviction for unlawful possession of a firearm as a previously convicted felon. The court held that the district court did violate defendant's Fifth and Sixth Amendment right to present testimony in his defense by excluding testimony regarding a detective and officer's presence at his previous federal trial that resulted in mistrial. In this case, the district court's conclusion that the probative value of the testimony was outweighed by the risk of confusion was not arbitrary, unreasonable, or disproportionate. The court also held that the district court did not violate defendant's Sixth Amendment right to confront witnesses and the district court was well within its wide latitude of discretion when it limited cross-examination on this issue. View "United States v. Clay" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for multiple offenses related to a counterfeiting scheme. The court held that the evidence was sufficient to sustain a conviction for making counterfeit securities where the checks at issue qualified as an "implement" under 18 U.S.C. 513(b); the sentencing judge made an independent determination to run the sentence in another case consecutive to the sentence in this case and explained on the record the facts that he believed supported a consecutive sentence; the consecutive nature of the sentences was eminently reasonable given that defendant's additional criminal conduct was committed while he was in custody on the charges in this case; and defendant failed to present any legal or factual basis to support withdrawal of his guilty pleas. View "United States v. Watson" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence discovered during a search following a warrantless car stop. In this case, defendant pleaded guilty to unlawful possession of a firearm as a previously convicted felon. The court held that, given all of the circumstances, the officers had reasonable suspicion that defendant was engaged in criminal activity. In this case, defendant entered a garage officers knew as a drug site at 4:30 a.m. when the drug dealer under surveillance was likely at the location. Therefore, the stop of defendant's vehicle was constitutionally valid. The court declined to reach defendant's argument that the officers did not have reasonable suspicion to stop his vehicle because he did not fail to yield to the patrol vehicle when its lights were activated. View "United States v. Collins" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence seized during a search of his residence while executing an arrest warrant. The court held that the district court properly found that the protective sweep was permissible under the Fourth Amendment. In this case, although the exact timing was unclear, the record established that officers began the protective sweep either contemporaneously with, or immediately following, defendant's arrest. Furthermore, the district court supported its finding with specific and articulable facts from which a reasonable officer could have concluded that another person was in the residence. The court also affirmed defendant's sentence, holding that the district court did not err in weighing the 18 U.S.C. 3553(a) factors and by giving significant weight to defendant's lengthy history of serious and violent crimes. Furthermore, the sentence was substantively reasonable. View "United States v. Waters" on Justia Law

The Eighth Circuit affirmed the district court's sentence imposed after defendant violated the conditions of her probation by participating in an illegal "lottery" scam. The court held that the district court did not abuse its discretion in sentencing defendant where it considered the 18 U.S.C. 3553(a) factors and the guideline range for the probation violations, as well as considered the guideline range of thirty to thirty-seven months' imprisonment for the underlying convictions. In this case, the district court acted within its discretion in considering the nature and circumstances of a defendant's probation violation and defendant's defiance of her probation conditions. Furthermore, the district court gave sufficient weight to her history and characteristics, such as her lack of criminal history; the nature of her underlying convictions; her limited role in the scam; and her poor health. Therefore, the sentence was substantively reasonable. View "United States v. Ryser" on Justia Law

Present lessors sought a declaratory judgment against Unimin Corporation, the present lessee, that the lease at issue created a tenancy at will. The Eighth Circuit affirmed the district court's grant of summary judgment to Unimin, ruling that the lease had created a determinable leasehold, not a tenancy at will, and so Unimin did not unjustly enrich itself by staying in possession. Under Arkansas law, the lease specified that the lessee may stay in possession until certain activities (mining silica in this case) ceased, and thus created a determinable estate. View "Roberts v. Unimin Corp." on Justia Law

Present lessors sought a declaratory judgment against Unimin Corporation, the present lessee, that the lease at issue created a tenancy at will. The Eighth Circuit affirmed the district court's grant of summary judgment to Unimin, ruling that the lease had created a determinable leasehold, not a tenancy at will, and so Unimin did not unjustly enrich itself by staying in possession. Under Arkansas law, the lease specified that the lessee may stay in possession until certain activities (mining silica in this case) ceased, and thus created a determinable estate. View "Roberts v. Unimin Corp." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment on remand in favor of defendants in an action filed by mortgage loan borrowers alleging violation of the Truth in Lending Act (TILA). Specifically, borrowers alleged that the lender did not provide the required number of copies of the required notice and material disclosures, and thus borrowers could rescind their loan on a date just shy of the three-year anniversary of loan execution. The court held that the district court did not err in determining that the signed acknowledgement borrowers had executed created a rebuttable presumption that they received the required number of copies and that borrowers' evidence was insufficient to overcome that rebuttable presumption. View "Jesinoski v. Countrywide Home Loans, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment on remand in favor of defendants in an action filed by mortgage loan borrowers alleging violation of the Truth in Lending Act (TILA). Specifically, borrowers alleged that the lender did not provide the required number of copies of the required notice and material disclosures, and thus borrowers could rescind their loan on a date just shy of the three-year anniversary of loan execution. The court held that the district court did not err in determining that the signed acknowledgement borrowers had executed created a rebuttable presumption that they received the required number of copies and that borrowers' evidence was insufficient to overcome that rebuttable presumption. View "Jesinoski v. Countrywide Home Loans, Inc." on Justia Law