Justia Constitutional Law Opinion Summaries

Plaintiff sued her former employer, Dakota County, Nebraska under 42 U.S.C. 1983 and 1985. She also sued a sheriff, chief deputy, and sergeant, claiming the chief deputy and sheriff created or fostered a sexually hostile work environment, and the chief deputy and sergeant conspired to deprive her of her civil rights. The defendants moved for summary judgment based on qualified immunity, which the district court denied. The Eighth Circuit Court of Appeals (1) affirmed the denial of summary judgment to the chief deputy, holding that Plaintiff sufficiently showed the five elements of a hostile-work-environment sexual harassment claim and that the right the chief deputy violated was clearly established; (2) reversed the denial of summary judgment as to the sheriff and sergeant on Plaintiff's claim that they conspired to violate her constitutional rights, as Plaintiff failed to demonstrate the existence of a conspiracy; and (3) reversed the denial of summary judgment as to the sheriff on Plaintiff's sexually hostile work environment claim, as the sheriff's conduct was not sufficiently severe to create a sexually hostile work environment.

A jury convicted Appellant of four counts of deprivation of rights and two counts of making false statements. The district court sentenced Appellant to 120 months' imprisonment on the deprivation of rights counts and sixty months' imprisonment on each of the false statements counts, with all terms to be served concurrently. In imposing this sentence, the court applied an enhancement for physical restraint under U.S.S.G. 3A1.3 and an enhancement for aggravated assault resulting in serious bodily injury under U.S.S.G. 2A2.2. On appeal, Appellant challenged the application of the two enhancements. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant moved his victims to an enclosed area to be assaulted, the district court did not err in applying the physical restraint enhancement; and (2) because Appellant had the requisite intent to assault his victims, the district court did not err in applying the enhancement for a crime resulting in serious bodily injury.

A jury found Appellant guilty of being a felon in possession of a firearm. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err by (1) permitting Appellant to represent himself pro se, as Appellant's waiver to counsel was knowing and voluntary and the district court adequately warned him of the dangers of self-representation; (2) denying Appellant's motion to suppress evidence recovered from a warrantless search of his vehicle; and (3) denying Appellant's motion for judgment of acquittal, as the evidence was sufficient to prove that Appellant knowingly possessed the weapons discovered in the truck he was driving.

Defendant pleaded guilty to being a felon in possession of a firearm. At sentencing, the district court determined Defendant had four prior convictions that qualified as violent felonies, and thus he was subject to the enhanced sentencing provisions of the Armed Career Criminal Act (ACCA). Defendant appealed the enhanced ACCA sentence. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly used a modified categorical approach in looking to the charging documents, plea agreement, and change of plea documents; (2) the charging documents contained sufficient information to show the convictions qualified as violent felonies; and (3) thus, because Defendant committed at least three prior violent felonies, the district court properly sentenced him as an armed career criminal.

Antoine Porter was charged with being a felon in possession of a firearm. Porter was convicted as charged after a jury trial and was sentenced to thirty-three months imprisonment. Porter appealed his conviction, arguing the district court erred in denying his motion for judgment of acquittal based on insufficient evidence and erred in overruling Porter's objection to statements made by the Government's counsel during closing arguments. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Porter's motion for acquittal, as there was ample evidence to support the jury's conviction; and (2) the district court did not err in overruling Porter's objection to statements made by the Government's counsel during closing arguments.

A jury convicted Appellants, Ferris Lee, Maurice Forest, and Marcus Royston, of various drug-related offenses. The district court sentenced Lee to 540 months imprisonment, Forest to a statutory mandatory minimum of 120 months imprisonment, and Royston to a statutory mandatory minimum life sentence. On appeal, Appellants raised numerous challenges to their convictions, and Forest and Royston challenged their sentences. The Eighth Circuit Court of Appeals (1) affirmed the district court's judgment and sentence as to Lee; and (2) affirmed Forest's and Royston's convictions, but vacated their sentences, holding that the Fair Sentencing Act (FSA) was applicable in these cases, and therefore, the revised statutory penalties should have applied to their sentences. Remanded for resentencing pursuant to the FSA.

Defendant appealed the district court's denial of his motion to suppress drugs and weapons found in an apartment he entered after fleeing from police during a buy/bust operation. Defendant entered a conditional guilty plea to possession with intent to distribute five grams or more of cocaine base and possession of a firearm in furtherance of a drug trafficking crime. Defendant subsequently appealed the suppression ruling, arguing that the actions by law enforcement officers during the buy/bust operation violated his Fourth Amendment rights and tainted the search warrant affidavit used to seize the drugs and weapons from the apartment. The Eighth Circuit Court of Appeals affirmed, holding (1) the search warrant was properly issued; (2) the officers' entry into the dwelling was lawful; and (3) the officers lawfully searched the dwelling.

James Schottel brought this action under 42 U.S.C. 1983 alleging a state court judge, Judge Patrick Young, violated his constitutional rights by conditioning the grant of his motion to withdraw as counsel on the repayment of a $1,600 retainer to the clients. The district court dismissed the action for lack of subject matter jurisdiction pursuant to the Rooker-Feldman doctrine. The Eighth Circuit Court of Appeals affirmed, holding that because Judge Young's actions were judicial in nature and were not taken in the complete absence of all jurisdiction, Judge Young was entitled to judicial immunity for the claims brought against him in this section 1983 action.

Mischelle Richter appealed (1) the district court's order dismissing her retaliation claims under Title VII and the Missouri Human Rights Act for failure to exhaust administrative remedies, and (2) the dismissal of her wrongful discharge claim under Missouri law for failure to state a claim upon which relief may be granted. The Eighth Circuit Court of Appeals (1) affirmed the district court's dismissal of the retaliation claims, holding that Richter did not properly exhaust her retaliation claims; but (2) reversed and remanded on the state-law wrongful discharge claim, holding that Richter alleged sufficient facts to state a wrongful discharge claim under Missouri law.

Robert Gray and Teresa Tremusini committed various crimes related to schemes to defraud the United States Postal Service (USPS). Gray, who pled guilty, appealed certain sentencing evidentiary rulings and the district court's loss calculation with respect to his sentence. Tremusini was convicted following a jury trial and appealed the district court's (1) admission of particular out-of-court statements made by Gray, (2) refusal to give Tremusini's requested jury instructions, and (3) denial of her motion for a judgment of acquittal. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err in (1) determining the loss calculation with respect to Gray, as the calculation reflected the "fair market value of services provided to Gray less the amount actually paid for those services"; (2) admitting the out-of-court statements made by Gray; (3) declining to give a model instruction requested by Tremusini; and (4) denying Tremusini's motions for acquittal.