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

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

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