Justia Constitutional Law Opinion Summaries

Defendant was convicted of being a felon and an unlawful drug user in possession of a firearm. Pursuant to a conditional plea agreement, Defendant appealed the district court's denial of his motion to suppress as well as a condition of supervised release that the district court imposed. The Eighth Circuit Court of Appeals affirmed, holding (1) no Fourth Amendment violation occurred when a law enforcement officer extended the duration of the traffic stop to inquire as to Defendant's warrant status; and (2) the district court did not abuse its discretion when it recognized the threat of cross addiction and responded by imposing a special condition of supervised release that prohibited Defendant from the use of alcohol and from entering establishments whose primary source of income is derived from the sale of alcohol.

Defendant pleaded guilty to possession with intent to distribute 100 kilograms or more of marijuana. The plea agreement recited that Defendant was subject to a mandatory minimum sentence of five years in prison but that he could be eligible for a safety valve reduction upon the condition that he truthfully provide to the government all information he had concerning the offense. At sentencing, the district court concluded the safety value reduction did not apply and imposed a sixty-month sentence. The Eighth Circuit Court of Appeals affirmed, holding that because Defendant did not provide the government truthful information and evidence about the relevant crimes before sentencing, the court had no choice but to deny a safety valve reduction.

Southeast Technical Institute (STI) in South Dakota is a public post-secondary technical school funded by the State through Sioux Falls School District No. 49-5 and governed by the Sioux Falls School Board. STI terminated Registrar Matt Onnen for awarding degrees to students who had not earned them, not awarding degrees when students had earned them, and failing to verify students for graduation. Meanwhile, Onnen filed a qui tam complaint against the school district, its superintendent, and the school board members, alleging that Defendants violated the False Claims Act (FCA) by knowingly submitting false or fraudulent claims to the federal government for student grants and guaranteed loans. Onnen did not sue STI or any STI employee. The district court granted summary judgment for Defendants. The Eighth Circuit Court of Appeals affirmed, holding the district court did not err in concluding Onnen's affidavit was insufficient to prove that any defendant committed a knowing violation of the FCA. Therefore, summary judgment was appropriate.

Tracy and Steve Lind filed this suit after Defendants attached funds in the Linds' joint bank account pursuant to Minnesota's garnishment laws. The Linds alleged that Defendants deprived Tracy of her due process rights in violation of 42 U.S.C. 1983 and that Defendants violated the Fair Debt Collection Practices Act (FDCPA). The district court dismissed both claims, concluding (1) Tracy had received constitutionally sufficient notice and an opportunity for a hearing; and (2) the Linds failed to allege any independent violation of the FDCPA in the complaint. The Eighth Circuit Court of Appeals affirmed, holding (1) because Tracy had actual notice and an opportunity for a postdeprivation hearing, her due process rights were not violated when Defendants attached funds from the Linds' joint bank account pursuant to the Minnesota garnishment statutes; and (2) the district court did not err in dismissing the Linds' FDCPA claim, as the Linds alleged no specific acts that demonstrated violations of the Act.

Defendant appealed the sentence he received after pleading guilty to one count of possessing with intent to distribute five grams or more of a mixture or substance containing a detectable amount of cocaine base. Defendant committed his offense prior to passage of the Fair Sentencing Act but was indicted, pleaded guilty, and was sentenced after the Act's passage. Defendant argued at sentencing that he should be sentenced in accordance with the Act. The district court, following the Eighth Circuit Court of Appeals' precedent in United States v. Sidney, held the Act did not apply to Defendant. As such, the court imposed a sixty-month mandatory minimum term of incarceration and a four-year mandatory minimum term of supervised release. Subsequent to Defendant's sentencing, the Supreme Court abrogated the Eighth Circuit's precedent, finding the Act applicable to defendants in Defendant's position. The Eighth Circuit (1) affirmed the imposition of the sixty-month term of incarceration, holding it was neither unreasonable nor unsupported by adequate explanation; and (2) reversed for reconsideration the term of supervised release. Remanded.

Defendant waived indictment and was charged by information with structuring financial transactions for the purpose of evading currency-transaction reporting requirements and with evading taxes. The district court, varying upwards from Defendant's guidelines range, sentenced him to sixty-months' imprisonment for his illegal structuring charge and ten months' imprisonment for his tax evasion charge and ordered that the sentences run consecutively. The court also ordered restitution in the full amount of the underlying fraud. The Eighth Circuit Court of Appeals affirmed the sentence, holding (1) the district court did not violate Defendant's Fifth and Sixth Amendment rights in determining Defendant's sentence; and (2) the district court did not violate Defendant's Fifth Amendment right to remain silent when it criticized his attorney for advising him not to cooperate with the probation office in preparing his presentence investigation report.

Following a jury trial, Defendant was convicted of possessing with intent to distribute cocaine base, being a felon in possession of a firearm, and being an unlawful user of a controlled substance in possession of a firearm. The district court sentenced Defendant to 200 months imprisonment. The Eighth Circuit Court of Appeals affirmed Defendant's conviction, holding (1) nothing in the record established that the conduct engaged in by the government during grand jury proceedings required dismissal of the indictment; (2) the district court did not err in admitting certain evidence; and (3) the prosecutor made improper comments during closing argument, but the trial record taken as a whole did not show that Defendant was entitled to reversal of his convictions.

A jury found Defendant guilty of conspiracy to distribute cocaine and possession of cocaine with intent to distribute. The presentence report classified Defendant as a career offender with a sentencing guidelines range of 360 months to life, and a district court sentenced him to life in prison without parole. The Eighth Circuit Court of Appeals affirmed Defendant's conviction and sentence. Defendant later brought a motion under 28 U.S.C. 2255, arguing that, pursuant to Johnson v. United States, his conviction for manslaughter in the second degree under Minn. Stat. 609.205, which contributed to his classification as a "career offender" under U.S.S.G. 4B1.1, was not a crime of violence. The district court denied Defendant's motion. The Eighth Circuit Court of Appeals affirmed, holding that, pursuant to Sun Bear v. United States, Defendant's motion under section 2255 was not cognizable.

Minnesota State Patrol Captain Thomas Fraser detained Plaintiff at the site of the collapse of the I-35W bridge in Minneapolis, Minnesota. Plaintiff, an experienced bridge and construction safety consultant, discussed the cause of the collapse with the media at the time of the collapse. Later, Plaintiff went to the site to investigate. Fraser turned Plaintiff over the Minneapolis Police Department (MPD). An MPD officer handcuffed Plaintiff and transported him to the police department. Plaintiff was released later that night. Plaintiff sued Fraser and others asserting, among other things, false arrest and First Amendment retaliatory arrest claims. The district court granted summary judgment in favor of Fraser. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err in finding no constitutional violation in Plaintiff's arrest; and (2) the district court did not err in concluding that the presence of probable cause to arrest Defendant for trespass defeated his First Amendment retaliatory arrest claim.

Plaintiff was arrested under the authority of St. Louis Ordinance 17.16.270, which prohibits conduct, including speech, that has the consequence of impeding pedestrians or vehicular traffic. After the City dropped the charges against him, Plaintiff brought this action under 42 U.S.C. 1983 as a facial challenge to the St. Louis ordinance. The district court granted the City's motion for summary judgment, finding the ordinance to be a content-neutral time, place, and manner restriction. The Eighth Circuit Court of Appeals reversed, holding that the ordinance was unconstitutional on its face because it did not provide fair notice of what conduct was prohibited, and it excessively chilled protected speech.