Justia Criminal Law Opinion Summaries

Police went to arrest Defendant for an incident that happened the day before. Defendant fled first on an ATV and then in a car. Once stopped, Defendant was sent to the hospital to receive medical attention. Meanwhile, officers searched Defendant’s car, finding guns and ammunition. A grand jury indicted Defendant for being a prohibited person in possession of a firearm. Defendant moved to suppress his statements, arguing that his Miranda waiver was invalid. The district court denied the motion. Defendant then moved in limine to exclude testimony that he had or used a gun in connection with the incident that led police to confront him on April 22. The district court granted the motion in part, prohibiting the Government from presenting hearsay testimony about the gun. Defendant also moved in limine to exclude evidence of his second flight from police, which was denied.   The Eighth Circuit affirmed. The court explained that here, the totality of the circumstances suggests that Defendant voluntarily, knowingly, and intelligently waived his rights. He was not intimidated, coerced, or deceived. On the contrary, officers ensured Defendant appreciated the rights he was waiving, told him that it was his decision to talk, and advised him that he could end the interview at any time. The evidence at trial showed that on the day the guns were discovered, police watched Defendant get in a car and drive off. When the pursuit ended, police found two guns in the passenger seat. View "United States v. Patrick Medearis" on Justia Law

Defendant moved to suppress evidence from a traffic stop, claiming that the officers unconstitutionally delayed it to conduct a drug-dog search and that the dog’s alert did not provide probable cause to search. The district court denied most of the motion. A jury convicted Defendant for possession of 50 grams or more of methamphetamine with intent to distribute and conspiracy to distribute 500 grams or more of a mixture and substance containing meth. Defendant appealed the denial of the motion to suppress.   The Eighth Circuit affirmed. The court held that the Troopers here had reasonable suspicion before stopping Defendant, which existed throughout the stop. Only 27 minutes passed from the stop until the dog’s alert. This delay did not violate the Fourth Amendment because the Troopers acted diligently to pursue the mission of the stop: to assist with the investigation of Defendant’s drug-related activity. Further, the court held that based on the totality of the circumstances at the scene of the stop, the dog’s alert provided probable cause to search the vehicles. View "United States v. Larry Rederick" on Justia Law

Defendant was sentenced to 840 months of incarceration following a guilty plea to two counts of producing child pornography (360 months each) and one count of committing an offense while a registered sex offender (mandatory minimum of 120 months). Defendant’s pornography production offense involved the sexual abuse of his ten-year-old nephew and four-year-old niece. In addition to the incarceration, the district court also imposed ten years of supervised release. As a special condition of the supervised release, the district court required that Defendant not contact the victims or the victims’ family without permission from his probation officer. Defendant argued that the district court made three reversible errors during sentencing. Specifically, he asserted that (1) his lengthy sentence is substantively unreasonable; (2) the special condition of supervised release is not narrowly tailored; and (3) the district court failed to make an individualized inquiry when crafting the special condition of supervised release.   The Eighth Circuit affirmed, holding that the district court did not abuse its discretion in either the length of the sentence or in imposing the challenged special condition of supervised release. The court held that the district court considered all the applicable Section 3553(a) factors and committed no clear error of judgment in weighing them. Further, the court found that the district court highlighted the hideousness and destructiveness of Defendant’s crimes. The district court concluded that Defendant “fundamentally violated the trust of these good people and this child, these children.” The court’s statement reflects its individualized inquiry into Defendant’s case and made a sufficient record of the court’s thorough consideration of the circumstances. View "United States v. Andrew Scanlan" on Justia Law

Defendant pleaded guilty to three firearm and controlled-substance offenses. Defendant appealed, arguing that the district court erred in sentencing him as a career offender under United States Sentencing Guidelines Section 4B1.1(a).   The Eighth Circuit affirmed. The court wrote that based on the language and structure of Iowa’s conspiracy statutes, Iowa state court decisions, and Iowa’s model jury instructions, it concludes that Section 706.3(2) is divisible as to the non-forcible felony that serves as the object of a conspiracy. Here, the specific object of Defendant’s Section 706.3(2) conspiracy is not in dispute: the PSR stated that Defendant was convicted of conspiracy to commit the offense of willful injury causing bodily injury, and Defendant does not contend that he conspired to commit a different offense. Further, the court explained that because it “generally interprets the identical ACCA and Guidelines force clauses interchangeably,” willful injury causing bodily injury qualifies as a “crime of violence” under the Guidelines as well. View "United States v. Devon McConnell" on Justia Law

Defendant was charged with thirteen charges related to fraud and tax evasion. Defendant insisted on representing himself, despite the District Court’s thorough colloquy. Ultimately, Defendant was convicted and sentenced to 97 months imprisonment, followed by three years of supervised release.Defendant appealed on several grounds, including insufficiency of the evidence, the district court’s acceptance of his expressed desire to represent himself, evidentiary issues, and sentencing issues. The court rejected Defendant’s appellate issues in turn and affirmed his conviction.However, on the government’s cross-appeal, the court vacated the judgment. The District Court erred in failing to award the government the costs of the prosecution. View "United States v. Jeffrey Kock" on Justia Law

Following her conditional guilty plea to conspiracy to distribute methamphetamine in violation of 21 U.S.C. Sections 841(a)(1) and 846, Defendant appealed from the district court’s denial of her motion to suppress evidence and statements she made in connection with warrantless parole searches of her person and residence.   The Eighth Circuit affirmed. The court held that based on the totality of the information available to the officers, the court agrees with the district court that law enforcement had reasonable suspicion that Defendant was engaged in illegal drug distribution sufficient to justify the warrantless parole searches. The court found that here, law enforcement gathered a variety of information from March 2020 to May 19, 2020, regarding Defendant and her involvement in illegal drug distribution, and officers were permitted to rely on their collective knowledge to support the decision to conduct a parole search. View "United States v. Heather Schaefer" on Justia Law

Defendant was convicted by a jury of two counts of kidnapping and two counts of transporting a minor across state lines for sexual purposes. He now appealed his conviction, challenging several of the district court’s rulings. These include the exclusion of evidence of the victims’ prior sexual activity, the admission of prior misconduct evidence, the admission of a prior sex-offense conviction, the rejection of Defendant’s requested jury instructions, and the denial of his motion for a new trial.   The Eighth Circuit affirmed. The court explained that applying the four-prong test for 404(b) evidence, it found that the district court did not abuse its discretion. As to the first prong, the 2004 conviction is relevant to material issues, including Defendant’s intent or plan to commit the crimes at issue and his identity as the assailant. The kidnapping at the heart of the 2004 conviction took place within a year of the criminal activity alleged here. On the third prong, the 2004 conviction is supported by sufficient evidence. Further, the court explained that the probative value of the evidence is not substantially outweighed by the risk of unfair prejudice. Again, the district court performed the requisite balancing under Rule 403 and included a limiting instruction. Moreover, the court found that the district court did not abuse its discretion in admitting evidence of Defendant’s prior sex-offense conviction under Rule 413. View "United States v. Myron Brandon" on Justia Law

A jury convicted Defendant of possession with intent to distribute 500 or more grams of methamphetamine. The district court sentenced him to 262 months in prison. Defendant appealed the conviction, challenging the denial of a pretrial motion to suppress. Defendant argued the district court erred in denying his motion to suppress because his Miranda waiver was not “voluntarily, knowingly, and intelligently made.”   The Eighth Circuit affirmed. The court explained that the district court found Defendant was “alert, aware of his criminal liability, and appropriately responding to questions” while talking with the officers. It credited the officers’ testimony that he “appeared coherent and did not tell them that he was intoxicated or under the influence of drugs.” His behavior was “consistent with someone who understood the nature of his crimes,” and he “did not appear to be intoxicated.” Accordingly, the court held that the district court did not err in finding “no evidence that Defendant’s alleged intoxication caused his will to be overborne.” Further, the court held that the district court did not err in determining that Defendant did not unequivocally invoke his right to remain silent. Finally, the court found that the district court did not abuse its discretion in not reopening the suppression hearing. View "United States v. Anthony Harris" on Justia Law

Defendant, a Drug Enforcement Administration (DEA) Special Agent, pleaded guilty to accepting bribes. In calculating his offense level, the presentence investigation report (PSR) applied a cross-reference in the Sentencing Guidelines for bribery. The cross-reference applies “[i]f the offense was committed for the purpose of facilitating the commission of another criminal offense.” The PSR found that the bribes were accepted for the purpose of facilitating a conspiracy to distribute between 15 and 45 kilograms of methamphetamine. Over Defendant’s objections, the district court agreed with the PSR and applied the cross-reference in determining Defendant’s offense level.   The Eighth Circuit affirmed. The court explained that despite its stated low regard for the confidential informant’s (“CI”) credibility, the district court credited his testimony over Defendant. That determination is “virtually unreviewable on appeal.” The CI’s testimony recounted acts Defendant undertook that assisted in the CI’s drug-trafficking business. The CI testified that in response to the Postal Service’s interception of one of his drug packages, Defendant advised him to use trucks instead of the mail to transport drugs as well as change both his phone and his address. This occurrence evinced Defendant’s intent to be paid in return for helping the CI avoid detection by law enforcement. The CI presumably wanted to avoid detection for much the same reasons as all drug traffickers: the better quality of life found outside prison and the continued ability to run his illegal business. Defendant helped him remain free; by doing so, he assisted in the CI’s drug-trafficking business. For doing so, he received $31,000. Defendant’s story “just defies logic,” and the district court appropriately chose to disregard it. View "United States v. Nathan Koen" on Justia Law

A jury convicted Defendant of attempted enticement of a minor using the internet, in violation of 18 U.S.C. Section 2422(b). Defendant appealed, asserting three claims: the district court (1) abused its discretion when it allowed the prosecution to impeach him using evidence not disclosed prior to trial; (2) committed plain error when it allowed the prosecutor to attack his credibility during rebuttal closing argument; and (3) imposed a substantively unreasonable sentence.   The Eighth Circuit affirmed. The court explained that even if the evidence should have been excluded, any error was harmless because it neither affected Defendant’s substantial rights nor had more than a slight influence on the verdict. Here, the prosecutor argued that the Agent’s testimony refuted Defendant’s claim that his conduct was an attempt to commit suicide by cop. That said, the prosecutor’s florid language in the rebuttal argument presents a close question related to propriety. Even assuming the argument was improper, there is no reasonable probability that Defendant would have been acquitted without the statements. Given the overwhelming evidence against Defendant, he cannot show the remarks were clearly injurious or that prejudice resulted. Finally, the court wrote that after considering and weighing Section 3553(a) factors, the district court imposed a within-Guidelines sentence, which is presumed to be reasonable. View "United States v. Christopher Truax" on Justia Law