Justia Constitutional Law Opinion Summaries
Articles Posted in U.S. 8th Circuit Court of Appeals
Iowa Right To Life Committee v. Tooker, et al.
IRTL challenged the constitutionality of several Iowa campaign-finance laws, an administrative rule, and two forms. The court concluded, inter alia, that IRTL lacked standing to challenge the definitions of "political committee" and "permanent organization" because it faced no credible threat or present or future prosecution; the first two sentences of Iowa Code subsection 68A.404(3), the second sentence of subsection 68A.404(3)(a), the entirety of subsection 68A.404(4)(a), the first and third sentences of Iowa Administrative Code rule 351-4.9(15), and Form Ind-Exp-O were constitutional as applied to IRTL and groups whose major purpose was not nominating or electing candidates; the first and third sentences of subsection 68A.404(3)(a), the second sentence of Iowa Administrative Code rule 351-4.9(15), the entirety of subsections 68A.404(3)(a)(1) and 68A.402B(3), and Form Dr-3 were unconstitutional as applied to IRTL and groups whose major purpose was not nominating or electing candidates; and Iowa Code section 68A.503 was constitutional under the First and Fourteenth Amendments. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Iowa Right To Life Committee v. Tooker, et al." on Justia Law
Muor v. U.S. Bank Nat’l Assoc.
Plaintiff appealed the district court's grant of summary judgment in favor of U.S. Bank on her claims of discrimination and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq. The court concluded that summary judgment in favor of U.S. Bank on plaintiff's discrimination claim was proper where the bank had a legitimate, non-discriminatory basis for issuing a written warning and where plaintiff had not met her burden of demonstrating pretext. The court also concluded that summary judgment in favor of U.S. Bank was proper where plaintiff failed to show a causal connection between her protected activity and the bank's alleged adverse employment action. Accordingly, the court affirmed the judgment. View "Muor v. U.S. Bank Nat'l Assoc." on Justia Law
United States v. Dunlap, Jr.
Defendant appealed his sentence for violating the terms of his supervised release. Defendant was released from custody and his sentence was fully discharged before his appeal was heard. The court dismissed defendant's appeal as moot, concluding that the possibility the supervised release violation might increase defendant's sentence for a future conviction was insufficient to maintain the appeal; defendant lacked any authority in his argument that he would suffer social stigma as a result of the violation; and defendant's appeal did not fall within the exception to mootness cases capable of repetition yet evading review. View "United States v. Dunlap, Jr." on Justia Law
United States v. Capps
Defendant appealed his conviction for possession with intent to distribute fifty grams or more of methamphetamine and sentence of a mandatory term of life in prison. The court concluded that the district court did not err in denying defendant's motion to suppress evidence seized from a vehicle where the absence of a Miranda warning prior to the search did not nullify defendant's otherwise voluntary consent and where an objectively reasonable person would have understood defendant to have consented to a search of the entire vehicle. The court also concluded that defendant's sentence did not violate the Eighth Amendment where, in light of his two prior drug convictions, his sentence was not grossly disproportionate. Accordingly, the court affirmed the conviction and sentence. View "United States v. Capps" on Justia Law
Spirit Lake Tribe of Indians, et al v. The NCAA
The Committee sued the NCAA for interfering with the University of North Dakota's use of the Fighting Sioux name, logo, and imagery. The district court treated the NCAA's motion to dismiss as a motion for summary judgment and granted summary judgment in favor of the NCAA. The court concluded that the Committee had not shown that the NCAA acted with discriminatory intent; the Committee was not denied due process by the NCAA because, as a nonmember, it was entitled to none from the NCAA; and the NCAA's act neither violated the laws of the land nor plainly violated its own constitution and bylaws. Accordingly, the court affirmed the judgment. View "Spirit Lake Tribe of Indians, et al v. The NCAA" on Justia Law
United States v. Brooks, Jr.
Defendant appealed his conviction for offenses related to a bank robbery. The court concluded that, even if the court assumed that the initial search of the cell phone at issue was improper, the subsequent search warrant satisfied both of the independent source requirements; the untainted contents of the search warrant affidavit provided probable cause; the district court did not abuse its discretion in admitting evidence of cell phone photos and video because they were intrinsic to the crimes charged and Federal Rule of Evidence 404(b) did not apply to the photos and video from the cell phone; the admission of the photos and videos did not violate Federal Rule of Evidence 403 because the probative value of the photos and video was not substantially outweighed by the potential for unfair prejudice; the GPS reports were non-testimonial and their admission did not violate defendant's Confrontation Clause rights; the district court did not err in denying defendant's motion for a mistrial based on an alleged violation of the district court's sequestration order; and the evidence presented at trial was more than sufficient for a reasonable jury to conclude that defendant was guilty of the crimes for which he was charged. Accordingly, the court confirmed the convictions. View "United States v. Brooks, Jr." on Justia Law
Robbins, et al v. Becker, Sr., et al
This interlocutory appeal arose out of the district court's denial of summary judgment on defendants' qualified immunity defenses to plaintiffs' 42 U.S.C. 1983 and Sherman Act, 15 U.S.C. 1-2, claims. The court declined to address the merits of defendants' qualified immunity defense because the district court's analysis denying summary judgment was so scant that the court was unable to discern if the district court even applied both steps of the qualified immunity inquiry to all of the summary judgment claims. Accordingly, the court remanded to the district court for further proceedings. View "Robbins, et al v. Becker, Sr., et al" on Justia Law
Geier, et al v. Missouri Ethics Commission, et al
Plaintiff filed this suit in federal court against the Commission, seeking to enjoin a state enforcement proceeding. The district court abstained under the Younger doctrine and subsequently denied plaintiff's motion to amend its complaint as moot, having declined jurisdiction over the case. The court concluded that, even assuming the action was not completely dismissed until the district court filed its order, any error was harmless because plaintiff's proposed amendment to its complaint was futile. Plaintiff failed to carry its burden of proving that it could not adequately raise its constitutional issues in Missouri's administrative proceedings or courts, nor could it meet the narrow exception recognized by Younger. Therefore, the court affirmed the district court's decision to abstain. View "Geier, et al v. Missouri Ethics Commission, et al" on Justia Law
Posted in:
Constitutional Law, U.S. 8th Circuit Court of Appeals
Ulrich v. Pope County, et al
Plaintiff filed suit against two deputy officers, in both their individual and official capacities, and against the county after plaintiff was arrested for violating a restraining order. Plaintiff appealed the district court's dismissal of his case with prejudice pursuant to Rule 12(b)(6). The court concluded that the deputies were entitled to qualified immunity on plaintiff's Fourth Amendment claim where the deputies had at least arguable probable cause to arrest plaintiff for the crime of knowingly violating a valid restraining order; even assuming that plaintiff suffered a constitutional deprivation, the district court properly dismissed plaintiff's 42 U.S.C. 1983 claim against the county where he failed to allege facts in his complaint that would demonstrate the existence of a county policy or custom that caused the deprivation; and the deputies, and by extension the county, were entitled to official immunity on plaintiff's false imprisonment claim, and this claim was properly dismissed by the district court. Accordingly, the court affirmed the judgment in all respects. View "Ulrich v. Pope County, et al" on Justia Law
Doe I, et al v. Nixon, et al
Plaintiffs were each convicted of an offense for which he or she was required to register as a sex offender in Missouri. Each conviction occurred prior to June 30, 2008, when the Missouri Legislature enacted Missouri Revised Statute 589.426 (the Halloween Statute). This appeal stemmed from plaintiffs' challenge to the Halloween Statute. The district court concluded that plaintiffs' claims were moot because there was no reasonable expectation that they would be prosecuted under the Halloween Statute and that consequently plaintiffs no longer had standing to proceed. Thereafter, plaintiffs moved for attorneys' fees and costs as prevailing parties under 42 U.S.C. 1988. The court concluded that the district court's October 27, 2008, order effectively served as a judicial pronouncement without judicial relief and did not confer prevailing party status upon plaintiffs. Because neither basis identified by plaintiffs conferred prevailing party status upon them, the court reversed the district court's grant of attorneys' fees and costs to plaintiffs under section 1988, as well as the district court's amendment of the judgment under Rule 59 to reflect the award of attorneys' fees and costs. Because they were not entitled to attorneys' fees, their appeal of the district court's reduction of fees was dismissed as moot. Further, the district court did not err in determining that plaintiffs lacked standing and in dismissing plaintiffs' second amended complaint for lack of subject matter jurisdiction View "Doe I, et al v. Nixon, et al" on Justia Law