Eighth Circuit

The Federal Docket

United States v. Katie Boll (8th Cir. July 2021)

The Eighth Circuit affirmed a defendant’s sentence and the sentencing court’s application of the enhancement for an offense involving a “large number” of vulnerable victims. The Court held that the defendant’s actions in stealing pain medication from 14 patients warranted the application where the district court found that this was a “large number” relative to similar offenses.

United States v. Andrew Sarchett (8th Cir. July 2021)

The Eighth Circuit vacated a defendant’s sentence for distributing methamphetamine based on the sentencing court improperly calculating the defendant’s drug quantity. The Court held that drugs found in the defendant’s girlfriend’s car should not have been included in the defendant’s total drug quantity where the additional quantity was based solely on a stipulation in the plea agreement that the girlfriend had made certain statements about the drugs. The stipulation did not establish that her statements were true, and there was no additional evidence tying the defendant to the drugs.

United States v. Seneca Harrison (8th Cir. September 2020)

The Eighth Circuit vacated a defendant’s sentence and held that the judge improperly participated in plea negotiations when he excused the prosecutor from the court room, told the defendant that the federal system “sucks” and is “really harsh,” and suggested that the defendant would be sentenced by a more lenient if he went to trial and lost rather than plead guilty. The Court held this was reversible plain error where the defendant proceeded to trial and received a higher sentence than discussed by the parties and the judge at the change of plea hearing.

United States v. Jason Harriman (8th Cir. August 2020)

The Eighth Circuit upheld a defendant’s conviction of murder-for-hire, denying entrapment as an affirmative defense under the de novo standard of review because the defendant did not produce sufficient evidence of inducement. The Court also affirmed the district court’s denial of motions for new counsel and new trial, holding the proper standard of review is for abuse of discretion.

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.

United States v. Mark Ringland (8th Cir. July 2020)

The Eighth Circuit upheld a conviction for receipt of child pornography because Google was not acting as a government agent when it uncovered files of child pornography in the defendant’s email accounts.

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.

United States v. Maurice Jerome McDonald (8th Cir. December 2019)

The Court held that a defendant is eligible to request a sentence reduction under the First Step Act as long as he was convicted of a “covered offense,” regardless of how his sentence was calculated under the Guidelines. What matters is the offense as defined by the statute-of-conviction.

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.

United States v. Sergio Diaz-Ortiz (8th Cir. June 2019)

The Court held that a knock-and-talk violation does not mandate suppression when a valid search warrant exists and the knock-and-announce violation has “nothing to do with the seizure of the evidence.” Here, the warrant was valid, and officers would have executed it and seized the evidence regardless of the alleged violation.

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