Justia Constitutional Law Opinion Summaries

Defendant entered a plea of guilty to being a felon in possession of a firearm conditioned on his right to appeal the district court's denial of his motions to suppress evidence. On appeal, the Eighth Circuit Court of Appeals affirmed, holding (1) for purposes of Defendant's motion to suppress, the traffic stop was justified; (2) even if the initial duration of the detention was unlawful, the district court did not err by denying Defendant's motion to suppress the firearms; and (3) the plain view doctrine permitted seizure of the firearms discovered in the vehicle Defendant was driving even though the search warrant did not list them as items to be seized.

The Secretary of the Department of Health and Human Services (HHS) imposed a civil money penalty on Greenbrier Nursing and Rehabilitation Center, a skilled nursing facility in Arkansas, for noncompliance with Medicare participation requirements. The Eighth Circuit Court of Appeals denied Greenbrier's petition for review, holding (1) substantial evidence supported HHS's finding that Greenbrier was not in substantial compliance with 42 C.F.R. 483.25; (2) the finding that Greenbrier's noncompliance with section 483.25 rose to the level of immediate jeopardy was not erroneous; and (3) judicial review of two of Greenbrier's objections to the monetary penalty was barred, and Greenbrier received adequate notice of its noncompliance.

Defendant was arrested for possessing a firearm. Defendant moved to suppress the firearm obtained from the vehicle he was riding in, arguing (1) the officer lacked probable cause or reasonable suspicion to stop the vehicle; and (2) even if the officer was reasonably mistaken in believing there was a traffic violation, any reasonable suspicion should have vanished when the officer saw the vehicle's valid In Transit sticker. The district court denied the motion. The Eighth Circuit Court of Appeals affirmed, holding that the initial traffic stop and the officer's limited inquiry, which led to the search and Defendant's arrest, were constitutionally valid.

Appellant entered a conditional plea agreement and pled guilty to possession with intent to distribute 500 grams or more of a mixture or substance containing a detectable amount of cocaine. As allowed by his conditional guilty plea, Appellant challenged the district court's denial of his motion to suppress. The Eighth Circuit Court of Appeals affirmed, holding (1) there was probable cause to stop Appellant; (2) there was reasonable suspicion to detain Appellant in order to search his vehicle; (3) the law enforcement officer's questions did not amount to an unreasonable search; (4) the time spent waiting for a drug detection dog was not unreasonable; and (5) the search of Appellant's vehicle after he was placed in a custodial arrest did not exceed the proper scope of investigation.

Defendant was charged with being a felon in possession of a firearm after a pat-down by law enforcement officers revealed that Defendant was in possession of a firearm, drugs, and drug paraphernalia. The district court granted Defendant's motion to suppress, concluding that although this case "was a close call," the officers did not have reasonable suspicion as required for a pat-down search under Terry v. Ohio. The Eighth Circuit reversed the order granting the motion to suppressed, holding that the totality of the circumstances created an objectively reasonable suspicion that Defendant might be armed and dangerous, and thus the pat-down search was constitutionally permissible.

Defendant Vincente Carrasco Espinoza appealed his conviction for one count of conspiracy to distribute cocaine and methamphetamine and one count of possession with intent to distribute cocaine and methamphetamine. The Eighth Circuit Court of Appeals affirmed, holding (1) the evidence at trial was sufficient to convict Defendant on both counts; (2) the district court did not err in its evidentiary rulings challenged by Defendant on appeal; (3) the government did not engage in misconduct during closing arguments; and (4) the district court did not err in giving certain jury instructions and denying Defendant's proposed jury instructions.

A jury convicted Appellant of one count of conspiring to distribute methamphetamine and two counts of distributing methamphetamine. Defendant appealed his conviction. The Eighth Circuit Court of Appeals affirmed, holding the district court did not err by (1) requiring Defendant to disclose his firearms expert; (2) refusing to instruct the jury on Defendant's coercion defense; (3) refusing to instruct the jury on Defendant's defense theory; and (4) prohibiting Defendant's counsel from presenting his defense theory in closing arguments. Defendant's remaining argument, that the district court erred by prohibiting the firearms expert from testifying, was meritless, as the district court did not make a definitive ruling on the matter.

Appellant entered a conditional guilty plea to charges that he conspired to distribute at least five kilograms of cocaine and 100 kilograms of marijuana and possessed a firearm in furtherance of a drug trafficking crime. Appellant appealed district court orders denying his motions to suppress evidence and for a Franks hearing, and his request to plead guilty to the conspiracy charge without admitting drug quantities alleged in the indictment. The Eighth Circuit Court of Appeals affirmed, holding (1) the motion to suppress was properly denied; (2) the district court did not abuse its discretion in denying a Franks hearing; and (3) the district court properly denied Defendant's plea motion under United States v. Brown.

The Minnesota Public Utilities Commission entered an order requiring Qwest Corporation, a successor Bell operating company, to submit for review and approval a price list and supporting rationale for certain telecommunication network facilities Qwest was required to provide to its Minnesota competitors under 47 U.S.C. 271. Qwest sought judicial review and declaratory relief in the district court, arguing the Commission's order was preempted by the Telecommunications Act of 1996. The district court concluded federal law and regulations did not preempt the Commission's order. The Eighth Circuit Court of Appeals reversed, holding (1) the Commission's order impermissibly intruded on federal authority to regulate rates for elements required under section 271 and interfered with the purpose and objectives of Congress and the FCC; and (2) therefore, the order was preempted by the Act and the FCC's implementing regulations and rulings.

Plaintiff had active tuberculosis at the time he was admitted to the Ramsey County Correctional Facility to serve fifty-six days for fifth degree assault. Plaintiff's condition worsened, and he was transferred to a hospital emergency room two days before he was scheduled for release. Plaintiff brought this action under 42 U.S.C. 1983, claiming that nursing staff, jail administrators, and the county had been deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. The district court granted summary judgment on immunity grounds to the administrators and the county but denied summary judgment to five nurses. The Eighth Circuit Court of Appeals (1) reversed the denial of summary judgment to two of the nurses, as the evidence was insufficient to support a finding that these nurses deliberately disregarded a serious medical need; and (2) affirmed the denial of summary judgment to the remaining three nurses, as the evidence supported a finding that these nurses were deliberately indifferent to Plaintiff's serious medical need.