Justia Constitutional Law Opinion Summaries

Andrew Butler was arrested after his ex-girlfriend reported to police that he broke into her apartment with a gun and then left in a car registered to him. Officers, knowing Butler was a convicted felon on probation with a waiver permitting warrantless searches and with outstanding misdemeanor arrest warrants, went to his workplace, Altium Packaging. There, they located his vehicle but did not see a gun inside. Upon entering the workplace, officers encountered Butler, who then fled, and during their pursuit, they saw him pick up a gun. After a brief chase, Butler was apprehended near the gun, which was recovered by police.The United States District Court for the Eastern District of Arkansas denied Butler’s motion to suppress the gun and related fingerprint evidence, ruling that he did not have a basis to challenge the officers’ entry into his workplace and, alternatively, that his search waiver justified the entry. Butler then pleaded guilty to being a felon in possession of a firearm, reserving the right to appeal the denial of his suppression motion. The district court sentenced him to 60 months in prison, a sentence above the advisory guidelines range.On appeal, the United States Court of Appeals for the Eighth Circuit held that Butler could not challenge the officers’ entry under the Fourth Amendment because he could not assert greater privacy rights than the property owner, and Steagald v. United States did not extend a right to object to entry into a third party’s property to the subject of an arrest warrant. The appellate court also found that the district court did not abuse its discretion in imposing an above-guidelines sentence, as it reasonably considered the relevant sentencing factors. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Butler" on Justia Law

Police officers stopped a vehicle after observing a traffic violation near a gas station known for gang and drug activity. Upon running the vehicle’s registration, they identified Marwan Hamdan, a known gang affiliate on parole for a prior firearm offense, as a co-owner. During the stop, officers questioned the occupants about their parole status, relationships, drug and alcohol use, and the presence of weapons. As the stop progressed, police requested identification from all passengers and performed record checks, including for an individual in a nearby vehicle who was believed to be associated with violence. After backup arrived, officers conducted pat-down searches and discovered an open container of alcohol. A subsequent search led to the discovery of a firearm in the glove box, resulting in Hamdan’s detention and federal charge for being a felon in possession.A United States Magistrate Judge in the District of South Dakota held an evidentiary hearing and recommended denial of Hamdan’s motion to suppress evidence, finding officers had reasonable suspicion for the stop and for further investigation. The United States District Court for the District of South Dakota adopted the amended report and recommendation, concluding the stop was valid and the officers lawfully developed reasonable suspicion during the encounter. The motion to suppress was denied.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The court held that the officers did not impermissibly extend the traffic stop in violation of the Fourth Amendment. Specifically, the use of radio dispatch for record checks, the request for a records search of a nearby individual, and the questioning of the driver did not unlawfully prolong the stop. The court affirmed the district court’s denial of the motion to suppress the firearm evidence. View "United States v. Hamdan" on Justia Law

The case concerns Brad Wendt, who owned two firearms stores in Iowa and also served as the Chief of Police for the small city of Adair. As police chief, Wendt had the authority to write official letters (“law letters”) that allowed his stores to acquire machine guns for the Adair Police Department or for demonstration purposes. Over several years, Wendt wrote numerous law letters to acquire ninety machine guns, some of which he resold for significant profit. Evidence showed that these acquisitions and demonstrations were not genuinely for police department use or potential future purchase but were instead for personal gain and to facilitate sales to other firearms dealers. Wendt also arranged for machine guns to be acquired and demonstrated by other dealers without legitimate department interest.After a jury trial in the United States District Court for the Southern District of Iowa, Wendt was convicted on multiple counts, including making false statements, conspiracy to make false statements and defraud the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), and illegal possession of a machine gun. The district court sentenced him to sixty months in prison, imposed a fine, and ordered the forfeiture of firearms. Wendt moved for acquittal or a new trial, but the district court denied these motions.On appeal to the United States Court of Appeals for the Eighth Circuit, Wendt challenged his convictions and sentence. The Eighth Circuit affirmed the convictions and sentence related to false statements and conspiracy, finding that the jury instructions fairly reflected the law and that there was no ambiguity requiring special instruction. However, the court found that the statute criminalizing possession of a machine gun was unconstitutionally vague as applied to Wendt in his role as police chief. The court reversed his conviction for illegal possession of a machine gun, remanded for vacatur of that conviction, but affirmed the remaining convictions and sentence. View "United States v. Wendt" on Justia Law

The plaintiff, an inmate in an Arkansas correctional facility, was placed in isolation for approximately six weeks during the summer, in a cell lacking air conditioning. He claimed that, as a dialysis patient subject to fluid restrictions, exposure to excessive heat caused him significant discomfort and posed a risk to his health. Throughout his confinement, he submitted several grievances to prison officials, asserting that his medical condition required air-conditioned housing. Although medical staff and other personnel were consulted, no documented medical restriction indicated that air conditioning was medically necessary for him, and prison officials relied on a physician’s opinion that his situation did not constitute an emergency.After discovery, the plaintiff brought a civil rights action under 42 U.S.C. § 1983 against three prison officials, alleging cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The United States District Court for the Western District of Arkansas granted summary judgment in favor of the defendants, finding them entitled to qualified immunity. The plaintiff’s motion for reconsideration was denied.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court assumed, for purposes of analysis, that the plaintiff’s medical condition presented an objectively serious risk. However, the court concluded that the record lacked evidence of deliberate indifference by the defendants: they consulted medical professionals, responded to grievances, implemented measures to mitigate heat, and treated the plaintiff’s medical complaints. Because the defendants did not violate a clearly established constitutional right, they were entitled to qualified immunity. The Eighth Circuit affirmed the district court’s judgment, holding that the prison officials were not deliberately indifferent to the plaintiff’s serious medical needs and did not subject him to cruel and unusual punishment. View "Hamilton v. Earl" on Justia Law

Two individuals, a political commentator and a state legislator, brought suit against Minnesota officials to challenge a state statute that criminalizes the dissemination of “deep fake” content intended to influence elections. The law applies to realistic depictions that could mislead a reasonable person into believing a public figure engaged in speech or conduct they did not. The commentator created an AI-generated video of Vice President Harris, which he labeled as parody with a clear disclaimer. The legislator shared the same video without any disclaimer. Both plaintiffs argued that the statute infringed their First and Fourteenth Amendment rights.After the complaint was filed in the United States District Court for the District of Minnesota, the district court found that the commentator lacked standing because the only videos he posted were labeled as parody and thus not covered by the statute. The court concluded that the legislator did have standing, since she shared content that could plausibly be seen as a deep fake under the law. However, the court denied her motion for a preliminary injunction, concluding she had unreasonably delayed in seeking relief—waiting over sixteen months after the statute’s enactment without sufficient explanation.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decisions. The appellate court held that the commentator did not demonstrate a credible threat of prosecution or show any evidence of injury, including from third parties. The court also determined that the legislator’s delay in seeking a preliminary injunction undermined her claim of irreparable harm, and the district court did not abuse its discretion in denying extraordinary relief. The Eighth Circuit left open the possibility of further proceedings on the merits, including a permanent injunction, but affirmed the denial of preliminary relief. View "Kohls v. Ellison" on Justia Law

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