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

Defendant pleaded guilty to being a felon in possession of a firearm and then moved to suppress evidence obtained by a search of a tattoo shop where he worked and the seizure of the handgun. The district court denied the motion to suppress. The Eighth Circuit held that defendant had no reasonable expectation of privacy in the work area and the officers' entrance into the work area did not violate his Fourth Amendment rights. However, the initial seizure of the handgun did not fall within the plain-view exception because, when an officer grabbed the gun off the shelf, the incriminating character of the gun was not immediately apparent. In the alternative, a reasonable officer could not draw specific reasonable inferences from these facts to justify seizure of the handgun and thus the Government failed to carry its burden to show the initial warrantless seizure of the handgun was permitted. Accordingly, the court affirmed in part, reversed in part, and remanded. View "United States v. Lewis" on Justia Law

Plaintiff filed suit on behalf of her son, alleging that VICC's race-based, school-transfer policy violated the Equal Protection Clause of the Fourteenth Amendment. The Eighth Circuit affirmed the district court's dismissal of the complaint, holding that plaintiff lacked standing because the mention of magnet schools and the generalized grievance about VICC's transfer policy for them was insufficient to allege an injury in fact. In this case, VICC had no administrative or supervisory authority over charter schools, which are independent public schools, governed by the state. Even if VICC's policy applied to charter schools, VICC still would not cause the son's injury because VICC does not make or adopt rules or regulations for charter schools. Because the son's injury was not fairly traceable to VICC, he lacked standing. View "E.L. v. Voluntary Interdistrict Choice Corporation" on Justia Law

The Eighth Circuit affirmed the district court's order denying defendant's motion to withdraw his plea, holding that defendant's waiver was knowing and voluntary. In this case, at the change-of-plea hearing, defendant confirmed that he had read the agreement and discussed it with his lawyer. Furthermore, the government summarized the plea agreement and explained that it included an appeal waiver that prevented defendant from withdrawing his plea; defendant acknowledged that the summary fairly described his agreement; and plaintiff voluntarily signed the agreement. View "United States v. Seizys" on Justia Law

Plaintiff, a commercial photographer, filed suit against the Village for injunctive and declaratory relief after the Village passed a municipal ordinance prohibiting all commercial activity in its neighborhood park without a permit. The Eighth Circuit affirmed the district court's denial of her Free Speech rights claims, holding that the ordinance met constitutional scrutiny as applied to plaintiff because it was content neutral, was narrowly tailored to serve the Village's significant government interests, left ample alternatives for her to communicate her message, and did not provide the Village with unbridled discretion. View "Josephine Havlak Photographer, Inc. v. Village of Twin Oaks" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against a former police officer, alleging that the officer violated plaintiff's constitutional rights by deliberately or recklessly giving partially inaccurate testimony in a probable cause hearing. After two prior remands, the district court found that the officer was entitled to qualified immunity. The Eighth Circuit held that, although a reasonable officer would know that it was unlawful to use deliberate or reckless falsehoods in a probable cause hearing, the officer here was entitled to qualified immunity. In this case, ample facts supported the issuance of the arrest warrant for plaintiff without the officer's inaccuracies. Accordingly, the court affirmed summary judgment and dismissal in favor of the officer. View "Odom v. Kaizer" on Justia Law

The Eighth Circuit affirmed defendant's above-Guidelines sentence of 102 months in prison for being a felon in possession of a firearm. The court held that the district court was permitted to conclude that the Guidelines did not adequately account for defendant's prior criminal history or likelihood to reoffend. The district court also recognized that defendant did not technically qualify as an armed career criminal and its passing remark did not undermine this recognition. View "United States v. Sadler" on Justia Law

The Eighth Circuit affirmed defendant's 84 month sentence after he pleaded guilty to possession of a firearm by a prohibited person. The court held that the district court did not commit procedural error by concluding that his Iowa and Nebraska convictions qualified as a "controlled substance offense" under USSG 4B1.2(b). Furthermore, the district court did not erroneously apply a four-level enhancement for possession of a firearm in connection with another felony offense under USSG 2K2.1(b)(6)(B). View "United States v. Maldonado" on Justia Law

The Eighth Circuit affirmed defendant's 120 month sentence after he pleaded guilty to one count of being a felon in possession of ammunition. The court held that defendant failed to show that the district court committed plain error in assigning the burden of proof; the district court did not clearly err in finding that defendant did not accept responsibility for his offense; and the district court did not commit procedural error by failing to consider the guidelines in imposing its sentence and by failing to explain its chosen sentence. The court also held that the sentence was substantively reasonable, and the district court's imposition of the special condition of supervised release prohibiting him from using alcohol or entering bars or taverns was reasonable and not an abuse of discretion. View "United States v. Godfrey" on Justia Law

Plaintiff filed suit against five police officers, three prosecutors, the city of Columbia, and Boone County, alleging numerous violations of his constitutional rights arising from his encounters with police. The Eighth Circuit rejected defendant's argument that the district court erred by failing to transfer his recusal motions to another judge for decision; the district court did not err by denying the recusal motions on the merits because none of the facts singly or in combination would provide an objective, knowledgeable member of the public with a reasonable basis for doubting the judge's impartiality; and the district court did not err, in its thorough and well reasoned opinions, by granting motions to dismiss and summary judgment by defendants and denying plaintiff's motion for partial summary judgment. View "Akins v. Knight" on Justia Law

A case becomes moot when the court can no longer grant any effectual relief to a prevailing party due to a change in circumstances. The Eighth Circuit dismissed as moot James Gretter's appeal of the district court's dismissal of his appeal from a bankruptcy court decision denying debtors' motion to assume and assign certain car-dealership agreements. The court held that the case was moot in the ordinary sense because no court, in reversing the bankruptcy court's order denying the motions to assume and assign, would order the sale of Edwards Auto Plaza to proceed. View "Gretter v. Gretter Autoland, Inc." on Justia Law