United States v. Hill, No. 20-1536 (8th Cir. 2021)
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The Eighth Circuit affirmed defendant's conviction for conspiracy to distribute and possession with intent to distribute 500 grams or more of a methamphetamine mixture. The court concluded that there was no error in the denial of defendant's motion to suppress where defendant failed to preserve this issue when he did not identify the seized items he wanted suppressed, as District of Minnesota Local Rule 12.1(c)(1)(B) requires; the court need not consider whether the district court erred in concluding the automobile exception applied because the officers had probable cause to search the vehicle; and the information provided by the confidential informant was sufficiently reliable to support the presumptively valid warrant.
The court also concluded that defendant's 204 month sentence was not substantively unreasonable where the district court expressly considered the sentences imposed on other conspirators, noted significant ways in which defendant was not similarly situated for sentencing purposes, and granted a substantial downward variance from the advisory guidelines range. Therefore, the district court did not abuse its discretion in sentencing defendant.
Court Description: [Per Curiam - Before Loken, Colloton, and Benton, Circuit Judges] Criminal case - Criminal law and sentencing. Defendant failed to preserve the issue of the warrantless search of his truck by failing to identify the seized items he wanted suppressed, as required by District of Minnesota Local Rule 12.1(c)(1)(B); it was not error to to deny the motion because the search warrant was sufficient to cover vehicles found on the premises; the information accompanying the search warrant application was sufficiently reliable to support the presumptively valid warrant; defendant's below-guidelines range sentence did not create unwarranted sentencing disparities as the court expressly considered the sentences imposed on other conspirators and noted significant ways in which the defendants were not similarly situated for sentencing purposes.
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