Justia Constitutional Law Opinion Summaries

Dimaryn Ware was indicted on multiple firearms-related charges. He moved to dismiss the indictment, arguing that the statutes violated the Second Amendment both on their face and as applied to him. The district court denied his motion, and Ware pled guilty while preserving his right to appeal the denial. He now appeals the denial and several sentencing decisions.The district court, the United States District Court for the Southern District of Iowa, denied Ware's motion to dismiss the indictment. Ware pled guilty to two counts, and the remaining counts were dismissed on the government's motion. At sentencing, the court applied the Base Offense Level from the United States Sentencing Guideline (USSG) § 2K2.1(a)(3), concluding that the offense involved a firearm capable of accepting a large capacity magazine. The court calculated a Guidelines range of 84 to 105 months but varied upward to 144 months' imprisonment, ordering the sentence to run concurrently with a state sentence for a related shooting but consecutively to other state sentences for unrelated offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Ware's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and § 932(b)(1) were foreclosed by precedent, specifically citing United States v. Jackson and United States v. Sharkey. The court also held that the district court did not err in considering conduct underlying an acquitted charge when determining Ware's sentence, as permitted by precedent. Additionally, the court found no clear error in the district court's application of USSG § 2K2.1(a)(3) based on the evidence of the firearm's capability to accept a large capacity magazine. Finally, the court upheld the district court's decision to impose Ware's federal sentence consecutively to his unrelated state sentences and to not reduce his federal sentence based on time served for those unrelated state sentences.The judgment of the district court was affirmed. View "United States v. Ware" on Justia Law

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

The case involves a group of in-state and out-of-state precious metal traders and their representatives (the "Bullion Traders") challenging Minnesota Statutes Chapter 80G, which regulates bullion transactions. The Bullion Traders argued that the statute violated the dormant Commerce Clause due to its extraterritorial reach, as defined by the term "Minnesota transaction."The United States District Court for the District of Minnesota initially found that Chapter 80G violated the dormant Commerce Clause. The case was then remanded by the United States Court of Appeals for the Eighth Circuit for a severability analysis. The district court concluded that striking portions of the "Minnesota transaction" definition cured the extraterritoriality concern and complied with Minnesota severability law.The Bullion Traders appealed, arguing that the severed statute still applied extraterritorially and that the district court erred in applying Minnesota severability law. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court found that the severed definition of "Minnesota transaction" no longer regulated wholly out-of-state commerce and that the statute, as severed, was complete and capable of being executed in accordance with legislative intent.The Eighth Circuit held that the district court correctly severed the extraterritorial provisions from Chapter 80G, and the remaining statute did not violate the dormant Commerce Clause. The court also agreed that the severed statute complied with Minnesota severability law, as the valid provisions were not essentially and inseparably connected with the void provisions, and the remaining statute was complete and executable. The judgment of the district court was affirmed. View "Styczinski v. Arnold" on Justia Law

Principal Springer was involved in drug dealing within 1,000 feet of a school and had multiple firearms in his apartment. Following a lengthy investigation, a search of his apartment revealed drugs, drug paraphernalia, and firearms. He was charged with conspiring to deal drugs within a school zone and unlawfully possessing firearms due to his drug use and a prior misdemeanor domestic-violence conviction. Springer moved to dismiss the firearm count, arguing that the restrictions violated the Second Amendment. The district court disagreed, and Springer pleaded guilty while reserving the right to appeal his Second Amendment challenges. He was sentenced to 110 months in prison.The United States District Court for the Northern District of Iowa denied Springer’s motion to dismiss the firearm count. Springer then pleaded guilty but reserved his right to appeal the Second Amendment issues. He received concurrent sentences of 110 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the statute prohibiting drug users from possessing firearms, 18 U.S.C. § 922(g)(3), is not facially unconstitutional, referencing its previous decision in United States v. Veasley. The court also rejected Springer’s as-applied challenge to the statute prohibiting domestic abusers from possessing firearms, 18 U.S.C. § 922(g)(9), noting that a conviction under any one of the § 922(g) categories is sufficient. Additionally, the court found no abuse of discretion in the district court’s decision not to grant a downward variance in sentencing. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Springer" on Justia Law

Arkansas Act 629 criminalized many previously legal hemp products. A coalition of affected businesses sued state officers, alleging that Act 629 is unconstitutional. The district court granted the plaintiffs' motion for a preliminary injunction and denied the state's motion to dismiss the Governor and Attorney General.The United States District Court for the Eastern District of Arkansas found that the plaintiffs were likely to succeed on the merits of their Supremacy Clause and due process claims. The court concluded that the 2018 Farm Bill likely preempted Act 629 and that the Act was likely void for vagueness. The court also found that the Governor and Attorney General were not entitled to sovereign immunity because they were sufficiently connected to the enforcement of Act 629.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the 2018 Farm Bill did not expressly preempt Act 629 because the Act's savings clause allowed for the continuous transportation of hemp through Arkansas. The court also found that Act 629 did not conflict with the 2018 Farm Bill's purpose of legalizing hemp production, as the federal law allows states to regulate hemp production more stringently. Additionally, the court concluded that Act 629 was not unconstitutionally vague, as the terms "continuous transportation," "synthetic substance," and "psychoactive substances" were sufficiently clear.The court further held that the Governor and Attorney General were entitled to sovereign immunity because they did not have a sufficient connection to the enforcement of Act 629. The court vacated the preliminary injunction, reversed the order denying the motion to dismiss the Governor and Attorney General, and remanded the case for further proceedings. View "Bio Gen LLC v. Sanders" on Justia Law

Reginald Robinson, Jr. entered a conditional guilty plea to one count of being a prohibited person in possession of a firearm, preserving his right to appeal the denial of a motion to dismiss the indictment and a motion to suppress. The district court sentenced him to 60 months’ imprisonment followed by 3 years of supervised release. Robinson appealed, arguing that the district court erroneously denied his motion to suppress based on an invalid Miranda waiver and lack of reasonable suspicion, and his motion to dismiss the indictment challenging the constitutionality of 18 U.S.C. § 922(g)(1) and (g)(3).The district court denied Robinson’s motion to suppress, concluding that Officer Siferd did not circumvent Miranda and that Robinson’s waiver of his rights was knowing and voluntary. The court also found that Officer Siferd had reasonable suspicion to detain Robinson based on the Walmart employee’s report and the odor of marijuana. The district court denied Robinson’s motion to dismiss the indictment, relying on Eighth Circuit precedent that upheld the constitutionality of § 922(g)(1) and (g)(3).The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The court found no evidence that Officer Siferd engaged in an orchestrated effort to circumvent Miranda and concluded that Robinson’s waiver of his rights was knowing and voluntary. The court also held that Officer Siferd had reasonable suspicion to detain Robinson based on the shoplifting report and the odor of marijuana. Additionally, the court upheld the constitutionality of § 922(g)(1) and (g)(3), noting that Robinson’s challenges were foreclosed by circuit precedent. The court affirmed the judgment of the district court. View "United States v. Robinson" on Justia Law

In 1996, Roderick Rankin was sentenced to death for the murders of Zena Reynolds, Ernestine Halford, and Nathaniel Halford. Rankin filed a federal habeas petition, arguing that he was intellectually disabled at the time of the murders, his trial counsel was ineffective for not investigating and presenting evidence that his brother Rodney committed the murders, his trial counsel had conflicts of interest, the penalty-phase jury instructions violated Supreme Court precedents, and his trial counsel was ineffective for not objecting to these instructions. The district court denied habeas relief without an evidentiary hearing.The United States District Court for the Eastern District of Arkansas denied Rankin's habeas petition, finding that he had not exhausted all state court claims and stayed the proceedings to allow him to pursue relief in state court. Rankin's subsequent state court attempts were unsuccessful, and he returned to federal court with an amended habeas petition. The district court denied relief, noting that Rankin had not provided clear and convincing evidence to contradict the state court's determination that he was not intellectually disabled and that his other claims failed on the merits.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Arkansas Supreme Court's rejection of Rankin's intellectual disability claim was not based on an unreasonable determination of the facts. The court also found that Rankin's claims of ineffective assistance of counsel and jury instruction errors were procedurally defaulted and without merit. The court concluded that Rankin was not entitled to an evidentiary hearing on his claims. View "Rankin v. Payne" on Justia Law

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.Initially, Maser filed suit in state court against Officer Van Brocklin, the City of Coralville, and other officers, asserting both state and federal claims. The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated. View "Maser v. City of Coralville, IA" on Justia Law

The Association for Accessible Medicines (AAM), representing generic drug manufacturers, challenged a Minnesota law regulating drug prices, Minn. Stat. § 62J.842, arguing it violated the dormant Commerce Clause. The law prohibits manufacturers from imposing excessive price increases on generic or off-patent drugs sold in Minnesota. The district court granted AAM's motion for a preliminary injunction, finding the law likely violated the dormant Commerce Clause.The United States District Court for the District of Minnesota concluded that AAM was likely to succeed on the merits of its claim, faced a threat of irreparable harm, and that the balance of harms and public interest factors were neutral. Minnesota appealed, contesting the likelihood of success on the merits and the balance of harms/public interest.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling for abuse of discretion and its legal conclusions de novo. The court found that the Minnesota law had the impermissible extraterritorial effect of controlling prices outside the state, similar to laws previously struck down by the Supreme Court. The court rejected Minnesota's argument that the law did not control out-of-state prices, noting that it effectively regulated out-of-state transactions if the drugs ended up in Minnesota.The Eighth Circuit affirmed the district court’s decision, agreeing that AAM was likely to succeed on the merits of its dormant Commerce Clause claim. The court also found no abuse of discretion in the district court’s assessment of the balance of harms and public interest, noting that protecting constitutional rights is always in the public interest. The preliminary injunction against the Minnesota law was upheld. View "Ass'n for Accessible Medicines v. Ellison" on Justia Law

Nathan Rinne sued Camden County and two of its commissioners, Greg Hasty and Donald Williams, Jr., alleging violations of his First and Fourteenth Amendment rights after Hasty and Williams voted to ban him from all County property for one year. The defendants sought summary judgment on the defenses of qualified and legislative immunity and on the merits of the issue of punitive damages. The district court denied these motions in full.The United States District Court for the Western District of Missouri denied the defendants' motions for summary judgment. The defendants then appealed the denial of legislative immunity, qualified immunity, and the issue of punitive damages.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the denial of legislative immunity, holding that the commissioners' decision to ban Rinne from county property was administrative, not legislative, in nature. The court found that the act of banning Rinne did not concern the enactment or promulgation of public policy but was an effort to monitor and discipline his presence and conduct at future commission meetings. Consequently, the commissioners were not entitled to legislative immunity. The court dismissed the remainder of the appeal, including the issues of qualified immunity and punitive damages, for lack of jurisdiction, as these involved genuine disputes of fact that could not be resolved at the appellate level. View "Rinne v. Hasty" on Justia Law