Justia Constitutional Law Opinion Summaries

Defendant appealed his conviction for theft of government funds, contending that the district court abused its discretion by admitting evidence at trial of his prior applications for Social Security disability benefits. Defendant also argued for the first time on appeal that venue was not proper in the Southern District of Iowa. The Eighth Circuit Court of Appeals affirmed Defendant's conviction, holding (1) the district court did not abuse its discretion in admitting evidence of Defendant's prior applications, as the evidence was relevant and the level of unfair prejudice did not substantially outweigh the probative value of the evidence; and (2) there was no plain error in prosecuting this case in the Southern District of Iowa.

A jury convicted Defendant of possession with intent to distribute as well as distribution of 500 grams or more of methamphetamine. The Eighth Circuit Court of Appeals affirmed, holding that Johnson was not entitled to a new trial, as (1) the basis of Defendant's objection to a juror's bias was clearly known during voir dire, and Defendant's counsel's failure to object constituted a waiver of Defendant's right to challenge the seating of the juror on direct appeal; (2) the government presented evidence sufficient to prove Defendant distributed 500 grams or more of methamphetamine; (3) the government did not violate Defendant's Sixth Amendment Confrontation Clause rights by failing to call as witnesses the forensic lab technician who checked the drugs found at Defendant's residence into and out of the state crime lab, and the lab supervisor who certified the lab report as a true copy of the original.

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.

A jury convicted Defendant of possession of child pornography, and the district court sentenced Defendant to 120 months' imprisonment. The Eighth Circuit Court of Appeals affirmed Defendant's conviction, holding that the district court did not err in (1) admitting evidence of prior acts to prove knowledge or intent; (2) permitting the government to question Defendant about an incident in which he masturbated outside his home, and in introducing a document Defendant wrote that discussed child sex; and (3) allowing the government to introduce Defendant's computers, hard drives, and computer disks into evidence, as the government established a proper chain of custody.

A jury convicted Defendant of eight counts of production of child pornography, two counts of attempted production of child pornography, and two counts of possession of child pornography. The district court sentenced Defendant to 3,480 months imprisonment and a lifetime of supervised release. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err in (1) denying Defendant's motion to suppress, as the evidence was not obtained in violation of the Fourth Amendment and the Miranda rule; (2) denying Defendant's motion for a bill of particulars; (3) admitting opinion testimony from a lay witness; (4) instructing the jury on the burden of proof; and (5) determining Defendant's sentence.

Kathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees.

Appellant appealed the district court's grant of summary judgment in favor of her employer, G4S Youth Services, LLC, and her supervisor, Todd Speight (Appellees), on Appellant's claims that they terminated her employment based on her race, age, and use of family medical leave. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant did not create a genuine issue of material fact as to whether G4S's legitimate, non-discriminatory reason for terminating her employment was merely a pretext for intentional race of age discrimination, the district court did not err in granting summary judgment in favor of Appellees on Appellant's race and age discrimination claims; and (2) because Appellant failed to raise a genuine issue of fact as to whether G4S retaliated against her for exercising her FMLA rights, the district court did not err in granting summary judgment on Appellant's Family and Medical Leave Act claims.

Before the Eighth Circuit Court of Appeals was Defendant's second federal habeas petition. Defendant was convicted of vehicular homicide and vehicular battery by a South Dakota jury and was sentenced to twenty-five years imprisonment. Defendant claimed that his trial counsel was ineffective for not calling two exculpatory witnesses and that previously undiscoverable evidence showed that he was not the driver of the car involved in the accident. The district court granted Defendant a writ of habeas corpus. The Eighth Circuit reversed, holding that Defendant had not met the Antiterrorism and Effective Death Penalty Act of 1996's requirements to bring his successive petition. Remanded.

Appellant brought a civil rights action under 42 U.S.C. 1983 against two deputy sheriffs in Benton County, Arkansas, alleging that they unlawfully entered his home, detained him, employed excessive force against him, and denied him emergency medical care. Appellant also asserted a failure-to-train claim against the County and its sheriff. The district court granted summary judgment for the defendants, ruling that Carpenter had not presented sufficient evidence to prove a constitutional violation, and that the defendants were thus entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly dismissed Appellant's claim alleging an unreasonable search under the Fourth Amendment; (2) there was probable cause to arrest Appellant; (3) the deputies were entitled to qualified immunity against Appellant's excessive force claim; (4) there was insufficient evidence that Appellant's need for medical treatment was so obvious that the deputies exhibited deliberate indifference by taking Appellant to jail; and (5) the district court correctly dismissed Appellant's failure to train claim against the defendants.

Defendant was convicted of being a felon in possession of a firearm. The district court sentenced Defendant to 327 months' imprisonment. Defendant appealed, contending that evidence of the firearm should have been suppressed, that the evidence was insufficient to sustain his conviction, and that his sentence was excessive. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Defendant's motion to suppress evidence; (2) there was clearly sufficient evidence in the record to support the verdict; and (3) there was no merit to Defendant's arguments that the district court erred in imposing sentence.