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   Federal Courts - 8th Circuit Court of Appeals - February 27, 2006

  
United States v. Shafer, No. 05-2049, UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT, February 27, 2006, Filed
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Overview: Defendant's sentence for conspiracy to use a minor for purposes of producing an explicit visual depiction of sexual conduct was reversed and remanded because a concurrent sentence combined with a significant downward variance was unreasonable given the aggravating offense factors and defendant's extensive criminal history.

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United States v. Simpson, No. 05-3071, UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT, February 27, 2006, Filed
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Overview: Where police officers chased defendant believing that he was someone else, they did not have probable cause to seize defendant but evidence recovered from the chase route was admissible because it was not fruit of the poisonous tree under the Fourth Amendment where it was obtained through conduct that preceded the illegality.

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