Justia Constitutional Law Opinion Summaries

The case centers on a defendant who was indicted on two counts: unlawful possession of a firearm by a drug user and making a false statement during the purchase of a firearm. The indictment alleged that, on specific dates in 2022, the defendant, as an unlawful user of marijuana and cocaine, possessed multiple firearms and falsely represented on a federal form that he was not an unlawful user or addict of a controlled substance. The evidence included the defendant’s admissions of regular drug use, his possession of firearms during the same period, and his acknowledgment that he was not prescribed any controlled substances. Additional evidence established that, at the time of a firearm purchase, he smelled of marijuana, and a subsequent search uncovered both a loaded pistol and marijuana in his vehicle. Drug tests confirmed recent use of marijuana and cocaine.The United States District Court for the Northern District of Iowa denied the defendant’s motion to dismiss, rejected his claims that the statutes were unconstitutionally vague, and found him guilty on both counts in a bench trial based on stipulated facts. The court concluded that the statutory terms were not vague as applied to the defendant, given his admissions and the explicit warning on the federal form. The court also held that the statute prohibiting firearm possession by drug users was consistent with historical tradition and deferred ruling on the as-applied Second Amendment challenge until trial evidence was complete. The defendant was sentenced to concurrent terms of imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit vacated the conviction for unlawful possession of a firearm by a drug user under 18 U.S.C. § 922(g)(3) and remanded for the district court to reassess the defendant’s as-applied Second Amendment challenge in light of intervening circuit precedent. The appellate court affirmed the district court’s decision on all other issues, including the conviction for making a false statement under 18 U.S.C. § 924(a)(1)(A). View "United States v. Ledvina" on Justia Law

A citizen of the Ivory Coast immigrated to the United States as a child refugee and later became a lawful permanent resident. As an adult, he was convicted in North Dakota of robbery, a Class B felony, for brandishing a gun and menacing others during a theft. The Department of Homeland Security initiated removal proceedings, charging him with removability based on two convictions for crimes involving moral turpitude and for the robbery conviction, which it classified as an aggravated felony for attempted theft.The Immigration Judge initially found the individual removable for the moral-turpitude convictions but determined he was eligible for cancellation of removal, concluding that the North Dakota robbery statute was overbroad compared to the federal definition of theft. The Department appealed, and the Board of Immigration Appeals (BIA) disagreed, finding the statute not facially overbroad and instructing the Immigration Judge to apply the “realistic probability” test to determine if the statute was applied to conduct beyond the generic federal definition. On remand, the Immigration Judge found the petitioner failed to show a realistic probability that the statute covered nongeneric conduct and ordered removal. The BIA dismissed the appeal, upholding the order.The United States Court of Appeals for the Eighth Circuit reviewed only the legal and constitutional claims, as required by statute. It held that North Dakota’s robbery statute is not unambiguously broader than the federal generic definition of attempted theft and that the petitioner had not demonstrated North Dakota actually prosecutes robbery based on conduct beyond that definition. Thus, the court found the robbery conviction to be an aggravated felony, rendering the petitioner ineligible for cancellation of removal, and denied the petition for review. View "Banyee v. Bondi" on Justia Law

Law enforcement uncovered a large-scale fentanyl distribution conspiracy involving multiple individuals transporting fentanyl pills from Phoenix, Arizona, to the Twin Cities. The conspirators concealed pills inside stuffed animals and shipped them as birthday gifts, taking measures to evade detection. Da’Shawn Domena participated by coordinating, receiving, and delivering packages he knew contained fentanyl. Police intercepted some packages, but others were shipped undetected. A search of Domena’s apartment revealed fentanyl pills and other evidence linking him to the conspiracy. Domena admitted his involvement, specifically acknowledging the receipt and distribution of multiple packages containing fentanyl.The United States District Court for the District of Minnesota accepted Domena’s guilty plea to conspiracy to distribute 400 grams or more of fentanyl, an offense carrying a statutory minimum sentence of 120 months under 21 U.S.C. §§ 841(b)(1)(A), 846. Despite being eligible for safety-valve relief under 18 U.S.C. § 3553(f), which could have avoided the mandatory minimum, Domena chose not to cooperate with the government. The Presentence Investigation Report found him responsible for 30.8 kilograms of fentanyl and calculated a lower guidelines range, but the statutory minimum controlled. At sentencing, Domena argued that the mandatory minimum violated the Eighth Amendment’s prohibition on cruel and unusual punishment, citing his minor role, lack of criminal history, absence of violence, and personal struggles. The district court rejected this argument, referencing existing Eighth Circuit precedent.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Domena’s Eighth Amendment challenge de novo. The court held that the mandatory minimum sentence was not grossly disproportionate to the crime and did not violate the Eighth Amendment. The court emphasized that circuit precedent consistently upholds mandatory minimum sentences for drug offenses and found Domena’s arguments unpersuasive. The Eighth Circuit affirmed the sentence imposed by the district court. View "United States v. Domena" on Justia Law

Deputy Brian Williams responded to a domestic-violence call at Tina Hight’s residence, where two dogs ran out toward him as Hight opened her door. Williams shouted warnings and fired a shot that caused the dogs to retreat. As Hight attempted to bring her dogs inside, a small Pomeranian mix ran toward Williams, prompting him to fire again in the dog’s direction. The shot missed the dog but ricocheted and struck Hight, leaving a bullet fragment in her leg.Hight filed suit in the United States District Court for the Western District of Arkansas, alleging excessive force under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments. The district court granted summary judgment to Deputy Williams on the basis of qualified immunity, concluding that Williams did not violate Hight’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo, making all reasonable inferences in favor of Hight. The appellate court considered whether Deputy Williams’s actions constituted a Fourth Amendment seizure of Hight. Applying the requirement that a seizure by force must involve an officer’s objectively manifested intent to restrain the person affected, the court found no evidence that Williams intended to restrain Hight; his actions and statements were aimed at stopping the dog. The court held that accidental force, or force directed at another target, does not satisfy the Fourth Amendment’s seizure standard as articulated in Torres v. Madrid and related precedents.The Eighth Circuit affirmed the district court’s judgment, holding that Deputy Williams did not seize Hight within the meaning of the Fourth Amendment and thus did not violate her constitutional rights. The court declined to address arguments raised for the first time on appeal. View "Hight v. Williams" on Justia Law

An 11-year-old child, L.D., was placed in foster care with Trina Mae Johnson. Over a period of fifteen months, Johnson inflicted severe abuse on L.D., including physical torture, starvation, denial of medical care, and psychological torment. The abuse resulted in significant weight loss, untreated injuries, and lasting trauma. Johnson concealed the abuse, enlisted others in her household to participate, and intimidated L.D. into silence. The abuse came to light when Johnson brought L.D. to a youth shelter, prompting an investigation by child services and the FBI.Johnson and several co-defendants were indicted on charges of child torture, child neglect, child endangerment, and assaulting a minor with a dangerous weapon in both federal and Minnesota state law violations. Some co-defendants pleaded guilty, while Johnson’s sister went to trial. Johnson was unable to accept a plea agreement because it was contingent on both sisters pleading guilty. She ultimately pleaded guilty without an agreement. The United States District Court for the District of Minnesota sentenced Johnson to 216 months in prison, after considering the relevant sentencing factors and victim impact statements. The sentence was below the government’s recommendation but above the prior plea offer.On appeal to the United States Court of Appeals for the Eighth Circuit, Johnson argued that the district court judge’s direct, sympathetic comments to L.D. at sentencing demonstrated judicial bias and violated her due process right to an impartial tribunal. The Eighth Circuit applied plain error review, noting Johnson did not object to the judge’s comments at sentencing or seek recusal. The court held that the judge’s empathetic remarks to the victim did not display deep-seated favoritism or antagonism that would make fair judgment impossible. Finding no plain error or due process violation, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Johnson" on Justia Law

Thomas Sanderson, a registered sex offender in Missouri, challenged a statutory provision requiring all registered sex offenders to post a sign at their residence on Halloween stating, “No candy or treats at this residence.” Sanderson had a history of elaborate Halloween displays, but after his 2006 conviction and imprisonment, he was informed by police that he was “grandfathered in” and could continue participating in Halloween festivities. This changed in 2022 when Hazelwood police arrested and convicted him for violating the statute, specifically the sign mandate. Sanderson then brought a facial challenge under the First Amendment, arguing that the mandate compelled speech.The United States District Court for the Eastern District of Missouri first granted a preliminary injunction, finding Sanderson was likely to succeed on the merits. After a bench trial, the court found that the sign mandate was unconstitutional compelled speech under the First Amendment and issued a permanent injunction barring enforcement of the mandate statewide. The State appealed, contesting both the constitutional ruling and certain evidentiary decisions made during the trial.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error, applying heightened scrutiny to facts relevant to the First Amendment claim. The appellate court held that the sign mandate compelled speech and thus required strict scrutiny. While the State’s interest in protecting children on Halloween was compelling, the court found the sign mandate was not narrowly tailored to achieve that interest. The evidence failed to show the signs provided any additional protection beyond existing restrictions, and no justification was presented for their necessity. The Eighth Circuit affirmed the district court’s holding that the sign mandate facially violates the First Amendment, vacated the injunction due to recent Supreme Court precedent, and remanded for reconsideration of the scope of injunctive relief. View "Sanderson v. Hanaway" on Justia Law

The plaintiffs owned and operated a hotel that had a record of serious structural and safety problems, including a window and a stone falling from the building, and repeated failures to correct code violations. After a fire occurred without activation of the sprinkler system, a follow-up inspection revealed that several fire code violations remained unaddressed, along with new violations. Based on these findings, the city’s building administrator ordered the hotel to be closed immediately, citing imminent safety risks. The owners sought to appeal and demanded hearings, but the city cited the COVID-19 pandemic as a reason for delay and directed them to other appellate avenues. The closure order was lifted once the most urgent hazards were remedied, and the owners eventually fixed all violations.The United States District Court for the District of Minnesota granted summary judgment to the city and the building administrator, finding no violations of procedural due process or the Fifth Amendment, and that qualified immunity protected the administrator in his individual capacity. The plaintiffs appealed, challenging the procedural due process provided for the closure, the application of qualified immunity, and asserting that the closure constituted a regulatory taking.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The court held that, even assuming a protected property interest existed, the risk of erroneous deprivation was low due to specific regulations and the availability of prompt post-deprivation remedies. The court also found that swift action in the face of public safety threats justified summary administrative action without additional pre-deprivation process. Regarding qualified immunity, the court determined that no clearly established law prohibited the administrator’s conduct. Finally, the court held that the temporary closure was a lawful exercise of police power and did not amount to a compensable regulatory taking. View "reVamped LLC v. City of Pipestone" on Justia Law

A federal grand jury charged the defendant with possessing methamphetamine with intent to distribute and being a felon in possession of a firearm. Task force officers at a bus station in Omaha, Nebraska identified the defendant’s suitcase as suspicious and removed it from the bus’s luggage compartment. After the defendant claimed and approached his bag, an officer questioned him about his travel plans and requested permission to search the suitcase, which the defendant consented to. The defendant then fled, prompting officers to detain him and search his belongings, ultimately discovering firearms and controlled substances.The defendant moved to suppress the evidence obtained from his suitcase, backpack, and person, arguing that the officers’ actions constituted unlawful searches and seizures under the Fourth Amendment. A magistrate judge recommended denying the suppression motion, concluding that the suitcase was not seized, the initial encounter was consensual, the consent to search was valid, and reasonable suspicion supported the later detention. The United States District Court for the District of Nebraska adopted the recommendation and denied the motion to suppress. At trial, a jury acquitted the defendant of possession with intent to distribute but found him guilty of simple possession and the firearms offense. The district court imposed consecutive sentences totaling 144 months’ imprisonment and a $2,500 fine, the latter without findings about the defendant’s ability to pay.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of the suppression motion, holding there was no Fourth Amendment seizure of the suitcase, the initial encounter was consensual, the defendant’s consent to search was voluntary, and reasonable suspicion justified the post-flight detention. The court also affirmed the custodial sentence as substantively reasonable but vacated the fine, remanding for proper findings on the defendant’s ability to pay. View "United States v. Clay" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

A member of the Sisseton Wahpeton Oyate tribe was observed by a tribal police officer driving erratically within the city limits of Sisseton, nearly causing multiple collisions and fleeing from law enforcement. He was apprehended in a tribal housing unit. Subsequently, the tribal prosecutor charged him in tribal court with driving under the influence (DUI) and resisting arrest, while South Dakota state court charged him with resisting arrest, reckless driving, and assaulting a law enforcement officer. He later pled guilty in state court to assault and was sentenced to two years in prison. The tribal court then dismissed the DUI charge without prejudice.He filed a federal lawsuit in the United States District Court for the District of South Dakota against various tribal officials, alleging that the DUI charge exceeded the tribe’s criminal jurisdiction and violated his rights under the Fourth Amendment and the Indian Civil Rights Act. The District Court dismissed the case for lack of subject matter jurisdiction, holding that the complaint failed to raise a federal question under 28 U.S.C. § 1331.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal. The court concluded that, even assuming it had jurisdiction to consider the scope of the tribe’s criminal authority, the case had become moot because the tribal DUI charge was dismissed and could not be refiled due to the expiration of the statute of limitations. The court found that neither the voluntary cessation exception nor the “capable of repetition, yet evading review” exception to mootness applied. Accordingly, the Eighth Circuit affirmed the district court’s judgment and vacated its decision, declining to address the underlying questions of tribal jurisdiction, sovereign immunity, or exhaustion of tribal remedies. View "LaBatte v. Gangle" on Justia Law