United States v. Nevatt, No. 18-3555 (8th Cir. 2020)
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The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute methamphetamine and six related gun and money laundering counts. The court held that the inventory search of defendant's motorcycle was lawful and the district court did not err in denying defendant's motion to suppress evidence. In this case, the inventory search was not a pretext for an investigatory search where the district court did not clearly err in crediting the officer's testimony that he towed the motorcycle because defendant lacked the proper endorsement and had no insurance. Furthermore, the officer towed the vehicle because defendant could not lawfully drive the vehicle and the vehicle was a safety hazard on the street.
The court also held that defendant's 460 month sentence was substantively reasonable where the district court discussed the 18 U.S.C. 3553(a) factors. Although the district court did not expressly discuss defendant's mental health and emotional issues as mitigating factors, the court indicated that it had reviewed his sentencing memorandum that identified these mitigating factors.
Court Description: [Per Curiam. Before Chief Judge Smith, Colloton, and Stras, Circuit Judges] Criminal Case - suppression and sentence. On appeal from denial of motion to suppress following a stop of a motorcycle, an inventory search, and impoundment of the motorcycle, the district court did not clearly err in crediting the officer's testimony that he towed the motorcycle because of Nevatt's lack of insurance, the location of the motorcycle on the street, Nevatt's access to the motorcycle and his inability to jail Nevatt or separate him. Based on the testimony, a lawful basis existed for the impoundment. Based on the facts, the district court properly concluded the inventory search was not a pretext for an investigative search. The district court's imposition of a 460-month sentence, below the advisory Guidelines range of life imprisonment, was not substantively unreasonable.
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