Justia Constitutional Law Opinion Summaries

Dr. Lee Davis, an African-American cardiologist, obtained medical-staff privileges at Jefferson Regional Medical Center (JRMC). Later, JRMC's Board of Directors voted to revoke Davis's medical-staff privileges for poor quality of patient care, improper medical documentation, and unprofessional behavior. Davis filed the instant suit in federal district court, alleging, inter alia, race discrimination and retaliation, in violation of 42 U.S.C. 1981 and the Arkansas Civil Rights Act (ACRA), and conspiracy to interfere with his civil rights, in violation of 42 U.S.C. 1985(3). The district court granted summary judgment to Defendants, JRMC, its CEO, and several physicians (Defendants), and dismissed all of Davis's claims. The Eighth Circuit Court of Appeals affirmed, holding (1) because Davis failed to provide any evidence giving rise to an inference that Defendants racially discriminated against him, the district court did not err in granting summary judgment on Davis's race discrimination claims; (2) Davis failed to establish a prima facie case of retaliation under section 1981 and ACRA; and (3) the district court did not err in dismissing Davis's civil rights conspiracy claim pursuant to section 1985(3), as Davis failed to show any racial animus on the part of Defendants.

Karen Anthony, a Nebraskan citizen, filed in federal district court an action against The Cattle National Bank & Trust Company (the Bank), a national bank headquartered in Nebraska, alleging fraud. Anthony asserted subject matter jurisdiction under 12 U.S.C. 24(4), 12 U.S.C. 1831n(a)(2)(A), and 28 U.S.C. 1331. The district court dismissed the complaint for lack of subject matter jurisdiction, concluding (1) there was no diversity jurisdiction, and (2) federal-question jurisdiction did not exist. The Eighth Circuit Court of Appeals affirmed, holding (1) diversity jurisdiction did not exist; (2) section 1831n did not create a private right of action; and (3) Anthony's remaining arguments were meritless or improperly raised for the first time on appeal.

Appellant was convicted for being a felon in possession of a firearm and sentenced to 235 months' incarceration. Appellant appealed his conviction and sentence. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court properly denied the motion to suppress DNA evidence obtained after Appellant's arrest; (2) Appellant's waiver of the right to counsel was knowing, voluntary, and intelligent, and therefore, the trial court did not err in allowing Appellant to represent himself at trial; (3) the district court did not abuse its discretion in denying Appellant's motion for a mistrial; and (4) the district court committed no procedural error at sentencing.

Officer John Cook fatally shot David Morgan after responding to a domestic disturbance at Morgan's residence in Missouri. Morgan's estate sued Cook pursuant to 42 U.S.C. 1983, alleging Cook used excessive force in violation of Morgan's Fourth Amendment rights. The district court granted Cook's motion for summary judgment, finding Cook was entitled to qualified immunity because his actions were objectively reasonable. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err in its conclusion that Cook's actions were objectively reasonable and therefore did not violate Morgan's Fourth Amendment rights. Thus, Cook was entitled to qualified immunity.

A jury convicted Defendant of being a felon in possession of a firearm. Defendant appealed, asserting that the district court erroneously denied his motion to suppress and excluded prior convictions of a government witness under Fed. R. Evid. 609. Defendant also argued that there was insufficient evidence to support the jury's verdict. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err when it denied Defendant's motion to suppress; (2) the district court did not erroneously exclude two prior convictions of a government witness under Rule 609; and (3) there was sufficient evidence to support Defendant's conviction for being a felon in possession of a firearm.

Defendant David Gamble appealed from his sentence of 188 months' imprisonment for conspiracy to distribute at least five grams of cocaine base, arguing that the district court erred in not applying the Fair Sentencing Act (FSA) to his case. The conduct underlying Gamble's sentence occurred before the FSA went into effect, but Gamble's sentencing was after this date. The Eighth Circuit Court of Appeals reversed under Dorsey v. United States, in which the Supreme Court held that the FSA applies where the defendant committed the crime before, but was sentenced after, the FSA went into effect. Dorsey abrogated the Eighth Circuit's case, United States v. Sidney, which held that the FSA does not apply retroactively. Remanded.

A jury convicted Defendant of aggravated sexual abuse of a child. The district court denied Defendant's motion for a new trial and sentenced him to 360 months' imprisonment, followed by a lifetime of supervised release. The court also ordered that, upon his release, Defendant abstain from the use of alcohol and from possessing sexually explicit materials. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion by denying Defendant's new trial motion, as Defendant did not meet his burden of proving that the loss of an exhibit after trial resulted in a miscarriage of justice; and (2) the district court did not plainly err by requiring Defendant to participate in an alcohol and drug abuse treatment program and by prohibiting Defendant from possessing sexually explicit materials.

Defendant was convicted of attempting to manufacture methamphetamine, being a felon in possession of a firearm, and attempting to escape from a correctional institution. The district court sentenced Defendant to 264 months' imprisonment. Defendant appealed his sentence, alleging procedural error in the district court's calculation of the offense level, its refusal to award Defendant a one-point reduction of his offense level for timely notice of an intent to plead guilty, and its lack of Fed. R. Crim. P. 32(h) notice before imposing the sentence. The Eighth Circuit Court of Appeals found no error on these issue but remanded to the district court for an explanation of the reasons for the two-month upward variance from the Guidelines range of 210-262 months' imprisonment.

Defendant Jose Villa-Madrigal was charged with possession of five kilograms of cocaine with intent to distribute. Defendant filed a motion to suppress evidence discovered during a search of the vehicle he was driving that was conducted by an Arkansas highway patrolman. After a suppression hearing, the district court denied Defendant's motion. Defendant subsequently entered an unconditional guilty plea, which was accepted. Defendant subsequently appealed his conviction, arguing that the court erred by denying his motion to suppress. The Eighth Circuit Court of Appeals affirmed, holding that Defendant's argument was foreclosed by his guilty plea, which was knowing and voluntary.

Following a jury trial, Appellant Thomas Frederick was convicted of aggravated sexual abuse of a minor, sexual contact with a minor, and tampering with a witness. The district court sentenced Frederick to 145 months in prison. The Eighth Circuit Court of Appeals affirmed, holding (1) Appellant's rights under the Confrontation Clause were not violated by the district court's decision to disallow him from asking the complainants about prior accusations of sexual abuse, and the district court did not err in concluding that the probative value of allowing Appellant to cross-examine the complainants on these matters was substantially outweighed by the danger of mini-trials and confusion of the jury; and (2) the district court did not err in prohibiting Appellant from presenting testimony of a certain witness at trial.