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

After defendant was placed on supervised release, he admitted to violating a term of his supervised release by committing another federal, state, or local crime. The district court sentenced defendant to 25 months imprisonment with no supervised release and defendant appealed. The court concluded that the sentence was substantively reasonable where the district court weighed the appropriate sentencing factors and did not commit clear error. View "United States v. Longs" on Justia Law

Plaintiff, an incarcerated felon, filed suit against defendants, alleging that the Arkansas Freedom of Information Act, Ark. Code Ann. 25-19-105(a)(1)(B), violates the equal protection and due process clauses of the Fourteenth Amendment. An employee of the police department denied plaintiff's request for information regarding an individual plaintiff had assaulted because the Act only permits an incarcerated felon to request information of public record through an attorney. The court concluded that the district court did not err by granting summary judgment to defendants because the Act does not violate the equal protection clause where the Act's limitation on those who many benefit from the law is rationally related to at least two legitimate government purposes: the prevention of unlawful use of the statute like harassing or threatening a witness or victim and conserving government resources; the Act does not violate plaintiff's due process right to access the courts because he has not shown that he will suffer an actual injury as a result of the Act's exclusion; and the district court did not abuse its discretion in denying plaintiff's Rule 60(b) motions because his claims failed on the merits and he was not entitled to additional discovery. Accordingly, the court affirmed the judgment. View "Gregory Holt v. Michelle Howard" on Justia Law

Petitioner, convicted of capital murder, appealed the denial of his petition for habeas relief under 28 U.S.C. 2254. Petitioner argued that his conviction is not supported by sufficient evidence and his constitutional rights were violated by Missouri’s “direct connection rule,” under which the trial court excluded evidence of a third-party’s potential guilt. The court concluded that petitioner has not established grounds for federal habeas relief. However, as the district court noted, the newly presented evidence in this case deserves “serious consideration” in the state courts. Although the court rejected petitioner's gateway claim of actual innocence under Schlup v. Delo, the court noted that Missouri provides a procedure for a prisoner to petition for habeas corpus relief in its courts. The court suggested, without weighing in on the merits, that state court would be a more appropriate forum for petitioner's claims. View "Nash v. Russell" on Justia Law

Defendant appealed his conviction for being a felon in possession of a firearm, contending that the district court erred in denying his motion to suppress evidence gathered from a drug-detection dog sniff, a subsequent search of his apartment, and his post-arrest interview. The court held, pursuant to the factors in United States v. Dunn, that the area sniffed constituted the curtilage of defendant's apartment where the area sniffed was in close proximity to defendant's apartment, defendant made personal use of the area, and there was a bush planted in the area which partially covered his window. In this case, because officers had no license to invade defendant's curtilage and the area the dog sniffed was within the curtilage of defendant's apartment, the court held that the dog sniff was an illegal search in violation of defendant's Fourth Amendment rights under Florida v. Jardines. The court concluded that the exclusionary rule applied and rejected the government's claims that the officers acted in objectively reasonable reliance on binding Eighth Circuit precedent in conducting the dog sniff and that the officers executed the search in good faith. Accordingly, the court reversed the denial of the motion to suppress and remanded for further proceedings. View "United States v. Burston" on Justia Law

Defendants Lee and Haire appealed their convictions for drug-related and weapons-related crimes. The court concluded that the district court did not abuse its discretion in admitting wiretapped phone conversations; the district court did not abuse its discretion in admitting a DEA agent's testimony about the meaning of drug related terms used by Lee and his coconspirators on the recordings; the trial court did not abuse its discretion in admitting portions of Lee's wiretapped statements about "drug cartels and Colombians;" the district court did not abuse its discretion by admitting portions of the wiretapped conversations between Lee and a coconspirator and portions of the DEA agent's testimony regarding the conspiracy; the district court did not abuse its discretion by giving a willful blindness instruction; and the government presented sufficient evidence to convict Haire of conspiracy to launder the proceeds of drug trafficking. Accordingly, the court affirmed the judgment. View "United States v. Haire" on Justia Law

Defendants appealed their sentences and the government filed a motion to dismiss based on defendants' voluntary plea agreements broadly waiving their right to appeal. The court concluded that the narrow exception in United States v. Andis, where the court will not enforce a knowing and voluntary appeal waiver if it will result in a miscarriage of justice, does not apply in defendants' cases. Accordingly, the court granted the motion to dismiss the appeals in all of defendants' cases. View "United States v. Mujica-Aranda" on Justia Law

Petitioner, convicted of being a felon in possession of a firearm and ammunition, seeks authorization to file a successive 28 U.S.C. 2255 motion. Petitioner contends that the Supreme Court established a new rule made retroactive when it held in Johnson v. United States that the “residual clause” of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), is unconstitutional. Based on the government’s concession, the court concluded that petitioner has made a prima facie showing that his motion contains “a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable.” Accordingly, the court granted petitioner's authorization to file a successive section 2255 motion. View "Woods v. United States" on Justia Law

Plaintiff appealed the MDHS Commissioner's decision to the state district court, claiming that Minn. Stat. 256L.07 violates federal laws, as well as Minnesota state law. While his state court action was pending, plaintiff filed his complaint in federal court alleging the same discrimination claims and also an equal protection violation. The state court dismissed his state cases and then the federal court dismissed his federal claims. On appeal, plaintiff challenged the dismissal of his federal claims. The court concluded that claim preclusion bars plaintiff from asserting his discrimination and equal protection claims in federal court and affirmed the judgment. View "Scheffler v. MN Dept. of Human Serv." on Justia Law

Defendant entered a conditional plea of guilty to the charge of felon in possession of a firearm. On appeal, defendant challenged the denial of his motion to suppress evidence. The court concluded that the stop of the SUV in which defendant was riding was supported by the personal observations of the officer which provided her with reasonable suspicion of wrongdoing. Further, the district court did not err in concluding that the officer's seizure of the handgun underneath the front seat fell within the plain view exception to the warrant requirement. Accordingly, the court affirmed the judgment. View "United States v. Vinson" on Justia Law

Defendant was convicted of four felonies after he impersonated an FBI agent and threatened a married couple living in South Dakota as part of a scheme to steal their property. On appeal, defendant challenged the district court's jury instruction on the felon in possession of a firearm charge. The court concluded that defendant's argument is foreclosed by its decision in United States v. Garcia-Hernandez, where the court addressed the same issue and held that the mens rea element requirement in 18 U.S.C. 924(a)(2) does not apply to the interstate-commerce element of 18 U.S.C. 922(g)(1). The court also rejected defendant's contention that the district court erred in admitting the plea agreements and judgments from his Alabama cases. In this case, the plea agreements and the transcript of the hearing were relevant because they contained multiple statements in which defendant implicated his guilt in the crimes charged in South Dakota. Therefore, those statements were admissible as opposing party statements under Federal Rule of Evidence 801(d)(2). Further, the statements are not barred under Rule 410 and 404(b). The court rejected defendant's remaining evidentiary claims because any error was harmless in light of the overwhelming evidence against defendant. Accordingly, the court affirmed the convictions. View "United States v. Thetford" on Justia Law