Justia Constitutional Law Opinion Summaries

Plaintiff sued the County of Dakota, Nebraska, and former sheriff's deputy Rodney Herron, alleging Title VII violations, sexual harassment, and violation of the Equal Pay Act. The County advanced a limited offer to settle the Title VII and Equal Pay Act claims, which Plaintiff accepted. Plaintiff then sought an award of attorney's fees on the partial judgment, and the district court ultimately awarded $24,500 in attorney's fees to Williams in two separate orders. The district court certified its orders as final judgments under Fed. R. Civ. P. 54(b) so as to allow for an interlocutory appeal. Defendants appealed. The Eighth Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, holding that the district court abused its discretion by entering final judgment under Rule 54(b).

Defendant entered into a plea agreement with the government wherein he pled guilty to arson and aiding and abetting arson. The government agreed it would recommend a sentence at the bottom of the advisory Sentencing Guidelines range. At sentencing the government recommended a sentence at the low end of the advisory Sentencing Guidelines range. The district court denied the request and instead departed upward under the United States Sentencing Commission. The court then sentenced Defendant to sixty months of imprisonment, the statutory maximum. The Eighth Circuit Court of Appeals affirmed, holding (1) Defendant's sentence was not substantively unreasonable; and (2) there was no breach of the plea agreement by the government.

Defendant entered a conditional plea of guilty to possession with intent to distribute cocaine base and possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Defendant's motion to suppress evidence obtained from a warrantless search of a rental vehicle, as consent for the search was validly obtained, and thus, the warrantless search did not violate the Fourth Amendment; (2) the discovery of drugs and a firearm in the vehicle was not a fruit of Defendant's detention, and thus, the Court did not need to decide whether Defendant's initial detention violated the Fourth Amendment; and (3) Defendant waived his right to appeal his sentence.

After a jury trial, Defendant was convicted on six counts related to willfully causing bodily injury to another because of that person's race, color, or national origin in violation of certain provisions of the Shepard-Byrd Hate Crimes Prevention Act. The district court sentenced Defendant to 135 months' imprisonment. The Eighth Circuit Court of Appeals affirmed Defendant's convictions and sentence, holding (1) 18 U.S.C. 249(a)(1) was constitutional; (2) the evidence was sufficient to sustain the conviction; (3) the district court did not abuse its discretion in refusing to grant Defendant's motion for a new trial; and (4) the district court did not err in failing to sua sponte grant Defendant a minor role adjustment.

Defendant pleaded guilty to distributing methamphetamine and being a felon in possession of a firearm. The district court sentenced Defendant to 151 months' imprisonment. Defendant appealed his sentence, raising as his sole issue the propriety of the district court's enhancement of his sentence for obstructing justice. The district court found that while in prison, after pleading guilty, Defendant engaged in a conspiracy to murder a confidential informant in this case. The Eighth Circuit Court of Appeals reversed the sentence, holding that the sentencing enhancement did not apply because there was no showing the plot was intended to obstruct justice on the instant offense of conviction.

Defendant pleaded guilty to one count of interstate transportation of a minor with intent to engage in criminal sexual activity. The district court sentenced Defendant to 360 months' imprisonment, applying an upward variance of thirty-three months from the high end of the Guidelines range. Defendant appealed, arguing that his sentence was substantively unreasonable based on the factors in 18 U.S.C. 3553(a). The Eighth Circuit Court of Appeals affirmed, holding (1) given the record, the district court did not impose a sentence greater than necessary to comply with the purposes of section 3553(a)(2); and (2) under the circumstances, the district court gave sufficient weight to mitigating factors.

A jury convicted Defendant of distribution of heroin and distribution of heroin resulting in death. The district court sentenced Defendant to 240 months on each count, concurrently. Defendant appealed, arguing the court erred by admitting hearsay testimony and denying his motions for judgment of acquittal and a new trial. The Eighth District Court of Appeals affirmed, holding that the district court did not err (1) by rejecting Defendant's proximate cause instructions or by using "contributing cause" language to define the causation element; (2) in denying Defendant's motion for a new trial because of remarks made by the prosecutor, where the remarks were proper; (3) in denying Defendant's motion for a judgment of acquittal, as the evidence was sufficient to sustain the convictions; and (4) in admitting certain testimony, because even if the district court erred in admitting the testimony, the error was harmless.

A North Dakota jury convicted Defendant of manufacturing methamphetamine, possessing methamphetamine, and possessing drug paraphernalia, all in violation of state law. After the North Dakota Supreme Court affirmed Defendant's conviction and the denial of his motion for state postconviction relief, Defendant filed a petition for writ of habeas corpus, arguing that the state court erred in requiring him to prove that his counsel's error was prejudicial under Strickland v. Washington. At issue on appeal was whether the wearing of prison clothing was necessarily prejudicial under United States v. Cronic, and therefore, a specific showing of prejudice was not required. The district court denied the petition. The Eighth Circuit Court of Appeals affirmed, holding that based on the record before the state courts, the decision of the Supreme Court was not an unreasonable application of clearly established law.

Plaintiff brought suit under 42 U.S.C. 1983 against the County of Dakota, Nebraska, and former county official Rodney Herron. Plaintiff alleged defendants committed gender discrimination in violation of her Fourteenth Amendment rights. Herron appealed the district court's denial of summary judgment, asserting that he was entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) Plaintiff met her burden to show that Herron violated her Fourteenth Amendment right to be free from gender discrimination; (2) the right Herron violated was clearly established; and (3) because Plaintiff satisfied both prongs of the qualified-immunity analysis, the district court correctly found that Herron was not entitled to qualified immunity.

Toni Duncan sued her former employer, Dakota County, Nebraska, under 42 U.S.C. 1983 for hostile-work-environment sexual harassment and constructive discharge in violation of the Equal Protection Clause of the Fourteenth Amendment. Duncan also sued Sheriff James Wagner and her supervisor, Chief Deputy Rodney Herron, in their individual capacities. The district court (1) granted summary judgment to Wagner; and (2) denied the motions for summary judgment by the County and Herron on the basis of qualified immunity. The Eighth Circuit Court of Appeals reversed in part, holding that Herron was entitled to qualified immunity on Duncan's claim, as Herron did not violate Duncan's right to equal protection. Remanded.