Eighth Circuit

United States v. Jeffrey Charles Rodd (8th Cir. July 2020)

The Eighth Circuit affirmed the district court's denial of a motion for sentence reduction under 18 USC 3582(c)(1)(A), holding that the district court did not err in finding that, assuming the defendant had established extraordinary and compelling reasons outside of USSG 1B1.13, his release was not warranted under the 18 USC 3553(a) factors.

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United States v. John Terry Chatman, Jr. (8th Cir. March 2020)

The Court reversed the defendant's conviction for obstruction of justice by attempting to kill a witness where the evidence showed that the defendant shot at an officer "out of frustration and retaliation" and not with the intent of "preventing a communication about the commission of a federal offense" to other other officers.

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United States v. Kevin Jay Mast (8th Cir. September 2019)

The Court reversed the defendant's conviction for "disturbing" federal wildlife property, holding that the statutory provision penalizing anyone who "otherwise violates" the federal wildlife regulations in question does not impose strict liability but rather has an implicit mens rea element requiring proof of criminal negligence.

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