Justia Criminal Law Opinion Summaries

Jason Potter was charged with drug trafficking offenses after police seized drugs from his vehicle during a traffic stop. The stop occurred following an investigation at a motel in Lee’s Summit, Missouri, where police were conducting surveillance due to reports of drug activity and stolen vehicles. Potter and his associate, Daniel Dryden, were arrested after leaving the motel. An inventory search of Potter’s car, conducted after it was towed, revealed methamphetamine. Potter moved to suppress the evidence, arguing that the search and seizure violated his Fourth Amendment rights. The district court denied the motion, and Potter was convicted and sentenced to 360 months’ imprisonment.The United States District Court for the Western District of Missouri denied Potter’s motion to suppress the evidence. A jury subsequently found Potter guilty on both counts of drug trafficking. The district court sentenced him to 360 months’ imprisonment. Dryden, who pleaded guilty, received a 36-month sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the timing of the traffic stop did not make the seizure unreasonable under the Fourth Amendment, as officers had probable cause based on an outstanding arrest warrant. The court also found that the inventory search of Potter’s car was reasonable and conducted according to standardized police procedures. Additionally, the court rejected Potter’s claim of vindictiveness in sentencing, noting that the district court provided valid reasons for the disparity between Potter’s and Dryden’s sentences. The Eighth Circuit affirmed the district court’s judgment and denied Potter’s appeal. View "United States v. Potter" on Justia Law

Four elderly sisters were accused of defrauding the United States by falsely claiming benefits under two federal programs. Each sister pled guilty to one count of conspiracy, preserving the right to appeal two pretrial rulings: the denial of a motion to suppress evidence and the denial of a motion to dismiss the indictment for untimeliness.The United States District Court for the Eastern District of Arkansas denied the motion to suppress, ruling that the sisters lacked standing to challenge the search of a property because they had no possessory interest in it. The court also found that even if the search was unconstitutional, the affidavits supporting the search warrants still provided probable cause. The motion to dismiss the indictment was denied because the court held that the statute of limitations for mail fraud begins on the date of mailing, not the date of the last overt act.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, agreeing that the affidavits were sufficient to support the search warrants even without the contested information. The court also affirmed the denial of the motion to dismiss, stating that the aiding and abetting mail fraud charges were filed within the five-year limitations period. Additionally, the court found no abuse of discretion in the district court's decision not to hold an evidentiary hearing on the motions, as the alleged disputes of fact were immaterial to the legal conclusions.The Eighth Circuit affirmed the district court's rulings, upholding the convictions and sentences of the four sisters. View "United States v. Charles" on Justia Law

Larenzo Burnett pleaded guilty to possession of a firearm by a prohibited person. During sentencing, a dispute arose regarding whether Burnett’s prior conviction under Iowa Code § 708.6(2) was a "crime of violence," which would increase his base offense level. The probation office recommended the increase, but Burnett objected. The parties reached a sentencing agreement where Burnett withdrew his objection and stipulated that the prior conviction was for a crime of violence. The district court imposed a sentence of 99 months and 14 days in prison.Burnett later filed a motion to vacate his sentence under 28 U.S.C. § 2255, claiming ineffective assistance of counsel because his attorney failed to file a notice of appeal. The district court held an evidentiary hearing and found that Burnett had not asked his attorney to file a notice of appeal within the 14-day period allowed by rule. Consequently, the court denied Burnett’s motion to vacate his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. To establish ineffective assistance of counsel, Burnett needed to show that his counsel’s performance was deficient and that the deficiency prejudiced his defense. The court found that Burnett’s defense counsel testified credibly that Burnett never requested an appeal. The district court’s credibility determination was not clearly erroneous, as it was based on the observation of witness demeanor and the consistency of the testimony. The appellate court affirmed the district court’s judgment, concluding that there was no clear error in the finding that Burnett did not ask his attorney to file a notice of appeal. View "Burnett v. United States" on Justia Law

Douglas Turner was convicted of possession of child pornography. He appealed the district court's denial of his motion to suppress evidence, arguing that his statements during a May 2018 interrogation should have been suppressed because he was subjected to custodial interrogation without Miranda warnings. At the time of the interrogation, Turner was an inmate and was interviewed by an FBI agent and a Bureau of Prisons investigator about a cell phone found in his bunk.The United States District Court for the Eastern District of Arkansas denied Turner's motion to suppress, concluding that he was not in custody during the interview. The court found that Turner was informed he did not have to answer questions and was not in custody, and that the interview was conducted in a non-coercive manner. A jury subsequently convicted Turner, and the district court imposed a sentence.The United States Court of Appeals for the Eighth Circuit reviewed the district court's factual findings for clear error and its legal determination on "custody" de novo. The appellate court held that Turner was not in custody for purposes of Miranda during the interview. The court noted that Turner was informed he did not have to answer questions, the interview was conducted in a non-coercive environment, and Turner was returned to his normal prison life afterward. The court concluded that a reasonable inmate in Turner's position would have felt free to terminate the interview and return to his housing unit. Therefore, the district court's denial of the motion to suppress was affirmed, and the judgment was upheld. View "U.S. v. Turner" on Justia Law

In January 2021, an individual wearing a black sweatsuit and a face mask robbed a Steak 'n Shake restaurant, holding the manager, Richard Payne, at gunpoint and taking money from the safe and cash registers. Payne identified the robber as Jonathan Davis, a former employee, based on his attire. Davis was later arrested wearing a similar outfit, and a red iPhone was seized from him. Davis claimed he was at a hotel talking to his girlfriend during the robbery. Investigators obtained a search warrant for the phone, which revealed incriminating evidence.The United States District Court for the Eastern District of Missouri denied Davis's motion to suppress the phone evidence, finding the warrant supported by probable cause and applicable under the good-faith exception. The court also denied Davis's motion to strike Juror No. 40, who had been a victim of a similar crime, and excluded defense testimony about a car Davis received as a gift after the robbery, deeming it irrelevant.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, concluding that the search warrant was supported by probable cause. The court also upheld the decision to retain Juror No. 40, finding no abuse of discretion and rejecting the implied bias argument. Lastly, the court affirmed the exclusion of the defense testimony regarding the car, agreeing that it was not relevant to the case.The Eighth Circuit held that the district court did not err in its rulings and affirmed the judgment, maintaining Davis's conviction and sentence. View "United States v. Davis" on Justia Law

The Eighth Circuit affirmed defendant's conviction of distributing methamphetamine, holding that the district court properly excluded evidence related to an entrapment defense. Evidence of a second threat was properly excluded because the threat was unrelated to drug trafficking and was not relevant to defendant's claim that he was coerced into drug trafficking. Furthermore, evidence of the threat was not necessary to show the bias of a confidential informant and his friend. View "United States v. Canales" on Justia Law

The Eighth Circuit affirmed defendant's conviction of attempted enticement of a minor, holding that the evidence was sufficient to support the jury's verdict. Even if some of defendant's text messages indicated that he did not intend to have sex with the minor immediately after their meeting, the evidence would still be sufficient to demonstrate his intent despite such a willingness to delay the sexual activity. The court also concluded that the district court did not abuse its discretion by admitting evidence under FRE 404(b) of defendant's contacts with two other minors. In this case, the evidence related to defendant's plan, knowledge, and preparation; the district court gave a limiting instruction; and the introduction of the evidence ultimately did not have a substantial and injurious effect or influence in determining the jury's verdict. View "United States v. Riepe" on Justia Law

The district court granted in part petitioner's motion to vacate his drug-related conviction and sentence under 28 U.S.C. 2255, based on ineffective assistance of counsel. The district court ordered the government to reoffer an earlier plea deal. The Eighth Circuit held that the district court clearly erred in finding that petitioner suffered from mental illness that impaired his ability to understand legal advice and make reasoned decisions; the district court erred in finding that counsel should have known that petitioner was not able to understand legal advice or make reasoned decisions; the district court's finding that counsel's communication style did not mesh well with petitioner's difficulties did not provide a basis for ineffective assistance of counsel; the district court did not err in finding counsel deficient in failing to explain the safety-valve exception; and the district court erred in directing the government to reoffer the five-year deal. Accordingly, the court vacated and remanded for the district court to determine whether petitioner was prejudiced by the safety-valve advice. View "Davis v. United States" on Justia Law

Petitioner appealed the denial of his 28 U.S.C. 2255 motion to vacate, set aside, or correct his criminal sentence. Petitioner was sentenced under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), based on predicate offenses for possession with intent to distribute crack cocaine and two Nebraska felony convictions for making terroristic threats (one as a juvenile and one as an adult). The Eighth Circuit affirmed and held that the Nebraska statute qualifies under the ACCA force clause; an act of juvenile delinquency cannot qualify as a violent felony under any clause of the ACCA, including the residual clause, unless the court first determines that it involved the use or carrying of a firearm, knife, or destructive device; that question is completely separate from the question of whether the juvenile conviction is an enumerated offense or qualifies under the force clause; the court sua sponte determined that petitioner's claim that his juvenile offense did not involve the use or carrying of a firearm, knife, or destructive device is procedurally defaulted; and even if the theoretical possibility exists that the Nebraska statute could encompass threats only to property, petitioner has not demonstrated a realistic probability that Nebraska would apply the statute in that manner. View "Fletcher v. United States" on Justia Law

Defendant appealed his 235 month sentence after pleading guilty to possession with intent to distribute 50 grams or more of methamphetamine. The Eighth Circuit affirmed, holding that the district court committed no procedural error where it specifically addressed the 18 U.S.C. 3553(a) factors raised by defendant; the within-Guidelines sentence was presumptively reasonable; and the district court did not abuse its discretion in sentencing defendant where the sentencing practices of one district court are not a reference point for other courts. View "United States v. Soliz" on Justia Law