| Stuart v. Global Tel*Link Corp. |
| Dockets: 18-2640, 18-2763 Opinion Date: April 15, 2020 Judge: Steven M. Colloton Areas of Law: Class Action |
| Plaintiff, an inmate who had used Global's services, brought a putative class action alleging that Global's rates and fees were unjust and unreasonable under the Federal Communications Act (FCA) and that Global had unjustly enriched itself in violation of state laws. After the regulatory backdrop for the inmate calling service industry changed, the district court decertified all classes and granted summary judgment for Global on all claims. The Eighth Circuit affirmed the district court's decisions on class decertification and summary judgment in favor of Global. The court held that the district court acted within its discretion in deciding that common questions no longer predominated, and that a class action was not the proper vehicle for resolving this type of claim. The court held that the district court did not err in dismissing plaintiffs' individual claims that the rates were unjust and unreasonable, and plaintiffs' common law unjust enrichment claim. Finally, the district court properly decertified the class action without seeking a determination by the agency on a methodology for segregating ancillary fees. The court dismissed Global's conditional cross-appeal as moot. |
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| United States v. Splettstoeszer |
| Docket: 19-1321 Opinion Date: April 15, 2020 Judge: Grasz Areas of Law: Criminal Law |
| The Eighth Circuit affirmed defendant's conviction and sentence for distribution, possession, and receipt of child pornography. The court held that the district court did not abuse its discretion in admitting evidence of defendant's prior sexual abuse convictions as probative of his interest, intent, and motive for distributing, receiving, and possessing child pornography. The court also held that defendant's 210 month sentence is substantively reasonable, and the district court did not abuse its discretion in sentencing defendant after relying on the 18 U.S.C. 3553(a) factors. |
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| United States v. Castellanos Muratella |
| Docket: 19-1219 Opinion Date: April 15, 2020 Judge: Grasz Areas of Law: Criminal Law |
| The Eighth Circuit affirmed defendant's sentence for participating in a methamphetamine-distribution conspiracy. The court held that the district court correctly designated defendant as a career offender based on his prior conviction for two felony drug crimes under Iowa Code section 124.401. The court held that section 124.401 is no broader than USSG 4B1.2. The court also held that the district court did not abuse its discretion in sentencing defendant where there was no indication that the district court counted his methamphetamine addiction against him. Rather, the generous variance suggests just the opposite. Therefore, defendant's sentence was not substantively unreasonable. |
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| United States v. Espinal |
| Docket: 19-1341 Opinion Date: April 15, 2020 Judge: Bobby E. Shepherd Areas of Law: Criminal Law |
| The Eighth Circuit affirmed defendant's conviction for illegal reentry into the United States. The court declined to reach the issue of whether there is a "ruse exception" to the Speedy Trial Act because, even assuming that the exception exists, the facts in this case do not show that any such ruse occurred. Furthermore, the district court did not abuse its discretion in declining to hold a hearing on the motion to dismiss the indictment before denying it. The court also held that, even assuming without deciding, that there were fundamental procedural errors in the underlying removal proceedings, defendant has not met his burden in demonstrating actual prejudice—that but for those errors, there was a reasonable likelihood he would not have been deported. Finally, the court held that the district court did not abuse its discretion in disposing of this issue without a hearing |
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| United States v. Fortier |
| Docket: 18-3517 Opinion Date: April 15, 2020 Judge: Stras Areas of Law: Criminal Law |
| The Eighth Circuit affirmed defendant's conviction for two counts of child pornography. The court held that the government met its specific-intent requirement by providing sufficient proof that one of defendant's "dominant purposes" was to create a visual depiction of his sexual acts with the victims. The court also held that there was no error in allowing defendant's ex-girlfriend to testify that he recorded them having sex too, and that she was 17 years old and in high school when they started dating. Furthermore, there was no error in allowing an FBI task force officer to describe some of the videos and photos from defendant's collection. Finally, defendant's argument -- that his conduct was beyond the reach of Congress to regulate under the Commerce Clause because every action he took was in Minnesota and neither he nor the images crossed state lines -- was foreclosed by precedent. |
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| United States v. Saucedo |
| Docket: 19-1693 Opinion Date: April 15, 2020 Judge: Bobby E. Shepherd Areas of Law: Criminal Law |
| The Eighth Circuit affirmed defendant's conviction for illegal reentry into the United States. The court rejected defendant's challenge to the indictment on Speedy Trial Act grounds, holding that the indictment was returned within the 30-day statutory period and thus there was no violation of the Act. Furthermore, even assuming without deciding, that there is a "ruse exception," to the Act, the court held that it would not apply in this case because the facts show that no ruse occurred. In this case, immigration authorities undeniably had a lawful basis for their civil detention of defendant, and defendant failed to show that his detention by ICE was for the primary or exclusive purpose of furthering his ultimate prosecution. The court also held that the district court did not abuse its discretion in declining to hold an evidentiary hearing on the motion; defendant failed to exhaust his administrative remedies and is therefore barred from collaterally attacking the underlying removal order; and the district court's finding that defendant's waiver was knowing, voluntary, and intelligent is not clearly erroneous. |
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