Justia Constitutional Law Opinion Summaries

Jquan Leearthur McInnis, then a juvenile, shot and killed Gustav Christianson and an infant, J.R., by firing seven shots into a car in downtown Minneapolis. Evidence gathered by investigators included statements made by McInnis to associates and forensic evidence showing the sequence of shots. After being apprehended and advised of his Miranda rights, McInnis initially denied involvement but eventually confessed to the shootings after invoking his right to remain silent. He maintained that he did not intend to kill Christianson and was unaware of the infant’s presence.The case was tried in a Minnesota state court, where McInnis moved to suppress his confession, arguing it was obtained after he had invoked his Fifth Amendment rights. The trial court denied the motion, concluding that McInnis had not unequivocally invoked his right to remain silent. The trial proceeded on stipulated evidence, including the confession, and McInnis was convicted of two counts of first-degree murder and sentenced to two consecutive life terms with the possibility of parole. On appeal, the Minnesota Supreme Court agreed that the confession should have been suppressed but determined that its admission was harmless beyond a reasonable doubt, given the other overwhelming evidence of guilt.McInnis then sought a writ of habeas corpus from the United States District Court for the District of Minnesota, arguing that the Minnesota Supreme Court unreasonably applied federal law on harmless error. The district court denied relief but granted a certificate of appealability on the harmless error issue. On appeal, the United States Court of Appeals for the Eighth Circuit held that McInnis failed to show that the Minnesota Supreme Court’s harmless error determination was contrary to or an unreasonable application of clearly established federal law. The Eighth Circuit affirmed the district court’s denial of the habeas petition. View "McInnis v. Bolin" on Justia Law

A pharmaceutical manufacturer participating in the federal 340B Drug Pricing Program challenged a Missouri law that prohibits manufacturers from restricting the delivery of discounted 340B drugs to contract pharmacies associated with covered entities. The manufacturer argued that its policy of limiting deliveries to only one contract pharmacy conflicted with Missouri’s statute, which requires delivery to all contract pharmacies designated by covered entities. The manufacturer sought declaratory and injunctive relief, claiming the Missouri statute violated the dormant Commerce Clause and was preempted by federal law.The United States District Court for the Western District of Missouri granted a motion to dismiss the manufacturer’s preemption claims, finding Missouri’s statute did not conflict with federal patent or drug exclusivity laws or the 340B Program, and that Eighth Circuit precedent foreclosed the field preemption argument. The court denied the motion to dismiss the dormant Commerce Clause claim, but ultimately denied the manufacturer’s motion for a preliminary injunction, concluding the manufacturer was unlikely to succeed on the merits of its claims, had not shown irreparable harm, and that the balance of equities and public interest weighed against preliminary relief.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of preliminary injunction under the abuse of discretion standard. The appellate court affirmed the district court’s decision, holding that the Missouri statute regulates only in-state delivery of 340B drugs and does not impermissibly control extraterritorial commerce, discriminate against interstate commerce, or impose excessive burdens in relation to local benefits. The court also found the manufacturer’s preemption claims foreclosed by Eighth Circuit precedent and concluded the statute is neither field nor conflict preempted. The district court’s denial of preliminary injunctive relief was affirmed. View "Novartis Pharmaceuticals Corp. v. Hanaway" on Justia Law

Angela Prichard endured months of harassment and stalking from her ex-husband, Christopher, including threats, vandalism, and surveillance. Despite multiple reports to police and both temporary and permanent restraining orders—each of which mandated Christopher’s arrest for violations—law enforcement officers did not take significant protective action. After a period away from her home, Angela returned despite warnings from the Chief of Police. A week later, Christopher fatally shot her. He was subsequently convicted of her murder. Angela’s family, including her sons, then sued the City of Bellevue and three police officers, alleging that the failure to protect Angela violated federal constitutional rights and Iowa law.The United States District Court for the Northern District of Iowa dismissed the complaint, determining that neither federal nor Iowa law created a duty for law enforcement to protect Angela from private violence under these circumstances. The court also denied the family’s post-judgment motion to amend their complaint, finding it was untimely and would have been futile because the proposed amendments did not present sufficient factual matter to plausibly state a claim.Reviewing the case, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that substantive due process under the United States Constitution does not impose an affirmative duty on the government to protect individuals from private violence, consistent with the Supreme Court’s decision in DeShaney v. Winnebago County Department of Social Services. The court also concluded that Iowa’s no-contact order statute does not create a private right of action against law enforcement for failing to enforce such orders. The court further rejected the family’s other state law claims, including those brought under the Iowa Slayer Statute and for intentional infliction of emotional distress, finding the facts alleged did not support those causes of action. The court found no abuse of discretion in denying leave to amend the complaint. View "Close v. City of Bellevue Iowa" on Justia Law

Several individuals who were non-custodial parents and owed more than $2,500 in child support had their driver’s licenses suspended by the Missouri Department of Social Services, Family Support Division (FSD), under a statutory scheme that, until 2023, did not require consideration of an individual’s ability to pay before suspending a license. The plaintiffs’ suspensions occurred in 2017 and 2018. Two plaintiffs’ suspensions were later stayed, and a third’s license was fully restored. They argued that the suspension policy violated their constitutional rights under the Fourteenth Amendment and the fundamental right to travel, seeking declaratory and injunctive relief and reinstatement of their licenses.The United States District Court for the Eastern District of Missouri first denied a preliminary injunction as moot and then partially dismissed the complaint. It rejected dismissal based on the Rooker-Feldman doctrine and Younger abstention, finding that plaintiffs’ claims were independent and no ongoing state proceeding existed. The court allowed only the procedural due process claim to proceed, dismissing other constitutional claims and claims against the governor. Later, the district court dismissed the case sua sponte for lack of subject matter jurisdiction, concluding that the plaintiffs lacked standing because their suspensions were stayed or lifted.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. It held that the plaintiffs lacked standing for declaratory relief because they did not allege ongoing or immediate injury, and their alleged harms were too speculative or unsupported. Any relief regarding Missouri’s prior statutory scheme was moot due to legislative amendments that now require consideration of ability to pay. The court affirmed the district court’s dismissal of the complaint for lack of subject matter jurisdiction and dismissed the appeal regarding the preliminary injunction as moot. View "Bedford v. MO Dept of Social Services, Family Support Div." on Justia Law

During protests opposing the Dakota Access Pipeline in November 2016, Sophia Wilansky was severely injured when police fired an aerial warning munition that struck her arm. Earlier that night, officers had ordered Wilansky and another protester to disperse from a barricade on a closed bridge, warning that they would use less-lethal munitions if the order was ignored. When Wilansky and the other protester did not comply, officers fired various less-lethal munitions. After Wilansky began retreating, she was struck by the aerial munition, causing permanent injury to her left hand and forearm.Following the incident, Wilansky filed two lawsuits in the United States District Court for the District of North Dakota. She alleged, under 42 U.S.C. § 1983, that county and state officers used excessive force in violation of the Fourth and Fourteenth Amendments and that Morton County maintained unconstitutional policies or customs. During the litigation, the district court struck certain new allegations and defendants from one complaint and ordered Wilansky to file an amended complaint. Wilansky then filed a second lawsuit with additional allegations against the stricken defendants. The district court ultimately dismissed both cases with prejudice.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgments. The court held that Wilansky did not sufficiently plead that the officers’ actions amounted to a clearly established Fourth Amendment seizure, nor did her allegations meet the “shocks the conscience” standard required for a Fourteenth Amendment claim. The court further held that she failed to establish a pattern of unconstitutional conduct by Morton County as of the date of her injury. Finally, the Eighth Circuit concluded that the district court did not abuse its discretion in dismissing the claims with prejudice. View "Wilansky v. Morton County, North Dakota" on Justia Law

A 15-year-old girl, E.R., stayed overnight at her friend G.T.’s home, where G.T.'s uncle, Rayford Evans, also lived. The morning after the sleepover, E.R. saw a cell phone through a bathroom transom window while she was bathing, which was quickly withdrawn. She believed Evans had tried to record her and reported this to G.T., who, with E.R., informed G.T.'s father, Ancel Teal. Teal coordinated with E.R.'s parents, one of whom was a sheriff’s deputy. Law enforcement was notified, and Officer Smith from the Doniphan Police Department responded. He confronted Evans at the home, requested Evans’s phones, and ultimately seized one phone after Evans initially objected but then acquiesced. Evans then consented in writing to a search of the phone, which led to the discovery of videos of E.R. nude in the bathroom.In the United States District Court for the Eastern District of Missouri, Evans was charged with attempted sexual exploitation of a minor. He moved to suppress the evidence from the warrantless seizure and search of his cell phone, arguing his consent was involuntary and that neither exigent circumstances nor the inevitable discovery doctrine applied. The district court denied the motion, found Evans guilty after a bench trial, and sentenced him to 252 months’ imprisonment. Evans renewed his suppression motion and sought a new trial, both of which were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that exigent circumstances justified the warrantless seizure of Evans’s phone because there was a reasonable belief Evans could imminently destroy evidence, and probable cause existed. The subsequent written consent to search the phone was voluntary. The court also held that sufficient evidence supported the conviction for attempted sexual exploitation of a minor. The judgment was affirmed. View "United States v. Evans" on Justia Law

Black Hawk County, Iowa, charges jail inmates daily fees and a booking fee. Rather than pursuing the standard civil reimbursement process, which includes judicial review, the County requires inmates to sign confessions of judgment upon release, acknowledging the debt and agreeing to payment terms. Inmates’ money is seized and applied toward the debt, and the confession allows the County to file for judgment without further judicial review. Leticia Roberts and Calvin Sayers, former inmates who signed these confessions under coercive circumstances, allege that the County’s process deprived them of an opportunity to challenge the jail fees and violated their Fourteenth Amendment due process rights. Roberts made payments out of fear of further enforcement, while Sayers made one payment and had money seized by jail officials.The United States District Court for the Northern District of Iowa dismissed Roberts and Sayers’s claims for lack of standing and failure to state a claim. The district court reasoned that their injury was not traceable to the confession of judgment policy because they would owe jail fees regardless, and any payments were voluntary. The court also denied their motion for a preliminary injunction and leave to amend the complaint.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit held that Roberts and Sayers had standing to seek damages and injunctive or declaratory relief, as they plausibly alleged injuries traceable to the County’s policy and a real threat of recurring harm. The appellate court found reasonable inferences that the confessions of judgment were coercive and not voluntary, and that the County’s actions deprived Roberts and Sayers of property without constitutionally adequate process. The Eighth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Roberts v. Thompson" on Justia Law

Two individuals were arrested by the Bentonville Police Department in Arkansas and appeared before a state district court judge two days and one day after their respective arrests. During these initial hearings, the judge set bail amounts for each individual without providing them with legal representation. Only after setting bail did the judge determine that they were indigent and appoint counsel for future proceedings. Both individuals remained incarcerated for several weeks before ultimately pleading guilty and being sentenced to time served.Following their experiences, these individuals, acting on behalf of a class of similarly situated pretrial detainees, filed suit in the United States District Court for the Western District of Arkansas. They alleged that the judge’s practice of setting bail without first appointing counsel violated their rights under the Sixth and Fourteenth Amendments. They sought declaratory and injunctive relief requiring that indigent defendants be provided with counsel at the start of their initial bail hearings. The district court denied motions to dismiss, certified the class, and ultimately granted summary judgment in favor of the plaintiffs. The district court held that the plaintiffs’ right to counsel attached at the initial hearing and that the bail-setting constituted a critical stage, thus granting declaratory and injunctive relief against the judge.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The Eighth Circuit held that the plaintiffs lacked Article III standing because they failed to show an ongoing or imminent injury that could be redressed by the prospective relief sought. The court found that the possibility of facing the same situation again was too speculative and that the requested relief would not redress any past harm already suffered. As a result, the Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of standing. View "Farella v. Anglin" on Justia Law

In 2000, Briley Piper and two others committed the murder of Chester Allan Poage in South Dakota, resulting in Piper being charged with multiple offenses, including first-degree felony murder. Prior to trial, Piper pled guilty to five crimes and was sentenced to death by the state circuit court. Over the years, Piper’s case returned to the South Dakota Supreme Court several times, both on direct appeal and in habeas proceedings. The South Dakota Supreme Court initially affirmed his conviction and sentence, later vacated the death sentence due to an invalid jury waiver, and remanded for jury resentencing. The jury again imposed a death sentence, which was affirmed. Piper then filed successive state habeas applications, challenging the validity of his guilty pleas and the effectiveness of his counsel, all of which were ultimately denied.After exhausting state remedies, Piper filed a federal habeas corpus petition in the United States District Court for the District of South Dakota, advancing thirteen claims; the district court denied relief on all, granting a certificate of appealability for several. The United States Court of Appeals for the Eighth Circuit expanded the certificate to include six claims. The court reviewed issues including the constitutionality of AEDPA deference after Loper Bright Enterprises v. Raimondo, South Dakota’s application of res judicata to preclude Piper’s challenge to his guilty pleas, the denial of an evidentiary hearing regarding alleged ineffective assistance of counsel, the adequacy of impeachment of a key witness, alleged failures to rebut a prosecution assertion about a defense witness, and cumulative prejudice.The Eighth Circuit held that AEDPA’s deference requirement remains constitutional and applicable after Loper Bright. It found Piper’s challenge to his guilty pleas procedurally defaulted under South Dakota’s consistently applied res judicata rules. The court concluded the district court did not err in denying an evidentiary hearing, found no prejudice in counsel’s performance regarding impeachment or rebuttal evidence, and reaffirmed that cumulative error does not warrant habeas relief in this circuit. The court affirmed the district court’s denial of habeas relief. View "Piper v. A.G." on Justia Law

Oscar Hudspeth, a member of the Oglala Sioux Tribe, was convicted by a jury of two sex abuse offenses involving his young stepdaughter, D.J., which occurred when she was between five and seven years old and living in his home. The prosecution’s evidence included D.J.’s testimony about the abuse and statements Hudspeth made during a post-polygraph interview with an FBI agent, where he admitted to inappropriate touching. Prior to trial, both parties agreed to exclude any reference to the polygraph test from evidence, and the district court admitted a redacted version of the interview transcript omitting mention of the polygraph.In the United States District Court for the District of South Dakota, Hudspeth moved to either exclude the entire interview or, alternatively, to ensure all polygraph references were redacted. When it became clear that a redacted version would be admitted, Hudspeth changed his position, seeking to admit the entire interview, including polygraph references, to provide context for his admissions. The district court admitted the redacted interview and excluded polygraph references, noting that Hudspeth had earlier agreed to the exclusion. Hudspeth was ultimately found guilty and sentenced to the mandatory minimum term.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether excluding polygraph references violated Hudspeth’s constitutional right to present a complete defense. The court held that the exclusion did not violate his constitutional rights or constitute an abuse of discretion. It found that polygraph evidence is generally unreliable and disfavored, and that the exclusion was neither arbitrary nor disproportionate. The court concluded that even if there was error, it was harmless beyond a reasonable doubt due to the strength of the prosecution’s case. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Hudspeth" on Justia Law