Justia Criminal Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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In the case before the United States Court of Appeals for the Eighth Circuit, the defendant Nolan Ryan Morin, who had pleaded guilty to a false-statements charge, a class D felony, faced the revocation of his supervised release multiple times. After his initial violation of supervised release, he was sentenced to 12 months' imprisonment and 3 years of supervised release. After two more violations, his supervised release was revoked and he was sentenced to 18 months' and then 24 months' imprisonment, respectively.Morin appealed his most recent 24-month revocation term of imprisonment, arguing that the "all or part" clause in 18 U.S.C. § 3583(e)(3), which governs the revocation of supervised release, requires a sentencing court to credit previous revocation terms of imprisonment up to a maximum of the term of supervised release authorized by statute for the underlying offense. In Morin's case, he claimed that the total length of all revocation imprisonment he may serve based on his false-statements conviction was capped at 3 years, and as he had already served 30 months on his first two revocations, the district court was only authorized to impose a maximum of 6 months on the present revocation.The Eighth Circuit disagreed with Morin's interpretation. The court held that the "all or part" clause imposed a per-revocation limit and did not require the court to consider or aggregate prior revocation terms of imprisonment. Moreover, the court opined that the clause expanded the sentencing court's authority by removing the limitation that a prison term imposed could never be longer than the term of the revoked supervised release. Thus, the court affirmed the 24-month term of revocation imprisonment Morin received as it was authorized by statute. View "United States v. Morin" on Justia Law

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The petitioner, Loing Yar, a native and citizen of South Sudan who entered the United States as a refugee, appealed an order of the Board of Immigration Appeals (BIA) that denied his claim under the Convention Against Torture for deferral of his removal to South Sudan. Yar was convicted of distributing methamphetamine in the United States, which is considered an aggravated felony, leading to the initiation of removal proceedings against him. Yar sought relief from removal, claiming he would be likely tortured if he was returned to South Sudan due to his membership in the minority Nuer tribe and his relationship to his father, an advocate for South Sudanese independence who died under suspicious circumstances.An immigration judge initially granted deferral of removal under the Convention Against Torture, but the BIA vacated this decision, concluding that the potential harm identified by the immigration judge did not rise to the level of torture, as defined by the law. The BIA further asserted that the likelihood of detention or imprisonment alone does not amount to torture, and the indeterminate "chance" of future upheaval or ethnic cleansing did not meet the legal standard of "more likely than not" under the regulations implementing the Convention.The United States Court of Appeals for the Eighth Circuit denied Yar's petition for review, affirming the BIA's decision. The court found no error in the BIA's legal conclusion that Yar failed to establish a likelihood of torture upon return to South Sudan. The court agreed with the BIA's interpretation of the Convention Against Torture, emphasizing that the definition of torture is a legal issue and whether a predicted factual outcome meets the definition of "torture" is a question of law. View "Yar v. Garland" on Justia Law

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Thomas Springs was convicted by an Arkansas jury for the capital murder of his wife, Christina, and sentenced to death. The conviction and sentence were affirmed on direct review by the Arkansas Supreme Court. Later, Springs filed a federal habeas corpus petition under 28 U.S.C. § 2254, arguing, among other points, that his trial counsel was ineffective for failing to investigate and present his son Matthew’s testimony during the trial's penalty phase.The United States Court of Appeals for the Eighth Circuit upheld the district court's denial of Springs' § 2254 petition. The court noted that Springs needed to show both that his counsel’s representation fell below an objective standard of reasonableness and that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. However, the court found that even if Matthew had testified, Springs failed to demonstrate a reasonable probability that the outcome of the trial would have been different given the extensive evidence against him and the nature of his crime. The court also declined to expand the certificate of appealability to include Springs's challenge to his competency to stand trial and participate in the appellate process. Therefore, the court affirmed the district court's judgment and denied Springs’s request to expand the certificate of appealability. View "Springs v. Payne" on Justia Law

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In the United States Court of Appeals for the Eighth Circuit, Defendant Ledra Craig appealed his conviction for various counts related to the distribution of fentanyl. On August 2, 2020, Craig sold fentanyl to two men, R.P. and N.B., at a casino in Missouri. R.P. and N.B. were later found unconscious and R.P. ultimately died. Craig was then arrested and made a statement to officers after waiving his Miranda rights, which was later used as evidence during his trial.Craig raised three main points of contention in his appeal. First, he argued that text messages between him and an unidentified co-conspirator, "Glenn," were wrongly admitted under Federal Rule of Evidence 801(d)(2)(E). The court disagreed, stating that the texts, which discussed drug deals, were made during and in furtherance of a conspiracy. Second, Craig claimed that the court improperly denied him the right to present a complete defense by restricting his ability to question an officer about the circumstances surrounding his inculpatory statement. The court also rejected this argument, noting that Craig had been able to conduct a thorough cross-examination of the officer. Finally, Craig contended that evidence of his prior drug conviction was erroneously admitted under Federal Rule of Evidence 404(b) as it was irrelevant to the current case and served as improper propensity evidence. The court disagreed, stating that the prior conviction was relevant to his intent to engage in the charged conspiracy to distribute drugs. Based on these reasons, the court affirmed Craig's conviction. View "United States v. Craig" on Justia Law

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In the United States Court of Appeals for the Eighth Circuit, the court considered an appeal by Whitehorse Ducharme, who had pleaded guilty to abusive sexual contact with a child and was sentenced to life in prison. Ducharme challenged his sentence on two grounds. First, he asserted that the district court failed to consider the offense level used to calculate his recommended sentencing range. Second, he argued that the court imposed a substantively unreasonable sentence.The Court of Appeals rejected both arguments. Regarding the first, the court noted that the district court had indeed meticulously calculated Ducharme's offense level, and the assertion that it failed to consider the applicable offense level was untenable. Ducharme's actual issue appeared to be with the court's reliance on the § 3553(a) considerations to impose a sentence above what the Guidelines recommended. The appellate court pointed out that once courts have correctly calculated the Guidelines range, they may find a sentence outside that range "appropriate irrespective of the Guidelines range."On the second point, Ducharme argued that a life sentence was substantively unreasonable because the court did not weigh the § 3553(a) sentencing considerations properly. He highlighted his limited criminal history and the fact that a life sentence far exceeded his Guidelines range. However, the court noted that its review of the substantive reasonableness of a sentence is narrow and deferential. The district court had considered the relevant sentencing criteria and given several convincing reasons for the sentence it chose, leading the Court of Appeals to conclude that it did not commit "a clear error of judgment" in varying upward to a life sentence.Thus, the court affirmed the life sentence given to Ducharme. View "United States v. Ducharme" on Justia Law

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In the case before the United States Court of Appeals for the Eighth Circuit, Jesse and Dustin Sierra, convicted of various charges including kidnapping, interstate domestic violence, and aiding and abetting both offenses, respectively, appealed their convictions. Jesse Sierra challenged the district court’s decision to exclude evidence of the victim’s other traumatic experiences, arguing that it violated his Fifth and Sixth Amendment rights. He also argued that the government suppressed exculpatory or impeachment material, violating the Brady v. Maryland precedent. Dustin Sierra challenged the sufficiency of the evidence for his convictions and argued that his trial should have been severed from Jesse's trial due to the prejudicial nature of the testimony and evidence presented. The Court of Appeals affirmed the district court’s decisions, holding that the exclusion of the victim's other traumatic experiences did not violate Jesse's constitutional rights, and that no Brady violations had occurred. The court also found that the evidence against Dustin was sufficient for the convictions and that there was no severe prejudice warranting a separate trial. View "United States v. Jesse Sierra" on Justia Law

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In this breach-of-contract dispute, the United States Court of Appeals for the Eighth Circuit upheld the decision of the District Court of Minnesota, which rejected Reach Companies, LLC's appeal for a new trial after a jury awarded $1,196,364 in damages to Newsert, LLC and David Serata. Reach Companies, a distributor of hand sanitizers, alleged that Newsert, a wholesaler of the same products, continued accepting late shipments despite delays and price fluctuations. Newsert countered that Reach failed to fulfill all but one of its purchase orders, causing Newsert to lose two customers. The court found that the purchase orders were unambiguous with respect to their terms, rejecting Reach’s argument that the "must ship by" dates were simply aspirational. The court also held that the evidence presented at trial was sufficient to prove Newsert's lost profits with reasonable certainty, dismissing Reach's argument that the losses were speculative and didn't account for overhead. Lastly, the court allowed the admission of evidence of prior criminal convictions of Reach’s Vice President for impeachment purposes, as the crimes involved fraud and deceit and were thus relevant to the issues in the case. View "Reach Companies, LLC v. Newsert, LLC" on Justia Law

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In this case, Tony Doolin was sentenced to 60 months of imprisonment and four years of supervised release for distribution of crack cocaine. After his release, Doolin lived in Iowa and possessed a medical-marijuana card, which permitted him to obtain medical marijuana under Iowa law. However, his supervised release was revoked due to his ongoing marijuana use and his distribution of medical marijuana to his girlfriend. Doolin appealed this decision, arguing that it violated the Appropriations Clause of the United States Constitution, due to the Consolidated Appropriations Act (CAA) of 2023. This act prohibits the Department of Justice (DOJ) from using funds to prevent states from implementing their own medical marijuana laws.The United States Court of Appeals for the Eighth Circuit affirmed the decision of the District Court for the Northern District of Iowa, holding that the revocation of Doolin's supervised release did not violate the Appropriations Clause or the CAA of 2023. The court noted that marijuana possession remains illegal under federal law, regardless of any state laws or limits on prosecutorial funding. Federal courts are required to impose a prohibition on a defendant’s unlawful possession or use of all controlled substances, including marijuana, as a condition of any term of supervised release. Even if section 531 of the CAA prohibits the DOJ from funding marijuana-related prosecutions or revocations, where doing so prevents a state from implementing its medical marijuana laws, the district court did not abuse its discretion in revoking Doolin’s supervised release. Doolin engaged in unlawful conduct, even under Iowa’s medical-marijuana regime, as private distribution of marijuana is illegal under Iowa law, as is smoking marijuana, even for medical purposes. Therefore, the court found that the revocation of Doolin's supervised release was not prohibited by the CAA, and the district court did not abuse its discretion in revoking Doolin's supervised release. View "United States v. Doolin" on Justia Law

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In the case before the United States Court of Appeals for the Eighth Circuit, the defendant Mary Linnell appealed her conviction for possession with intent to distribute a controlled substance. The case arose after a traffic stop during which law enforcement officers found methamphetamine, cocaine, and drug paraphernalia in the vehicle in which she was a passenger. Linnell moved to suppress the evidence, arguing that the patrol officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The district court denied the motion, and Linnell entered a conditional guilty plea, preserving her right to appeal the suppression ruling. She was sentenced to 92 months’ imprisonment with 5 years of supervised release to follow.On appeal, Linnell contended that the district court erred in denying her motion to suppress, asserting that the officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The appellate court disagreed, ruling that the district court did not clearly err in finding that the officer observed three traffic violations (running a stop sign, following another vehicle too closely, and speeding), and therefore had probable cause to conduct the traffic stop. The court gave deference to the lower court's credibility determination of the officer's testimony, noting that the officer had several years of experience and had been involved in hundreds of traffic stops. The judgment of the district court was affirmed. View "United States v. Linnell" on Justia Law

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In the case before the United States Court of Appeals for the Eighth Circuit, the defendant, Donavan Jay White Owl, appealed an order of the district court denying his motion to dismiss an indictment based on the Double Jeopardy Clause. White Owl had been indicted for felony murder and arson within Indian Country. A mistrial was declared during the initial trial after a dispute over White Owl’s access to information about a prosecution witness. White Owl argued that a new trial would violate his rights under the Double Jeopardy Clause of the Constitution.The Appeals Court, however, ruled that White Owl had impliedly consented to the mistrial. The court noted that while the defendant did not expressly request a mistrial, his actions and responses during the proceedings indicated his implicit agreement. Specifically, when the district court declared its intention to declare a mistrial and asked the parties for their views, White Owl did not object but instead emphasized the need for more time to prepare for cross-examination of a prosecution witness.In light of this, the court concluded that White Owl's lack of objection amounted to implied consent to a mistrial. Accordingly, the court affirmed the district court's order denying White Owl's motion to dismiss the indictment based on the Double Jeopardy Clause. View "United States v. Donavan White Owl" on Justia Law