Justia Constitutional Law Opinion Summaries

A police officer in Des Moines, Iowa attempted to stop a vehicle driven by Dylan Pettyjohn for lacking license plates or a temporary registration. Pettyjohn fled, leading the officer on a high-speed chase through a residential area before crashing. He then ran from the vehicle, discarding a loaded revolver and a fanny pack containing 54 fentanyl pills, $389 in small bills, marijuana, and about 85 grams of methamphetamine. A search of his vehicle yielded a digital scale with white residue, more marijuana, and shell casings. Pettyjohn was arrested, and a federal grand jury indicted him on multiple counts related to drug possession with intent to distribute, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm.The United States District Court for the Southern District of Iowa denied Pettyjohn’s motion to dismiss the felon in possession charge, rejecting his argument that 18 U.S.C. § 922(g)(1) violated the Second Amendment. The court also allowed limited admission of his prior felony convictions for impeachment purposes, after an agreement between Pettyjohn and the government. At trial, Pettyjohn moved for acquittal based on insufficient evidence, but the district court found the evidence sufficient and denied the motions. The jury found Pettyjohn guilty on all counts, and the court sentenced him to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirmed the district court’s evidentiary rulings under Rules 404(b) and 609, and upheld the constitutionality of § 922(g)(1) based on circuit precedent. The Eighth Circuit held that the evidence was sufficient to support the convictions, the district court did not abuse its discretion in admitting prior conviction evidence, and § 922(g)(1) is constitutional. The judgment of the district court was affirmed. View "United States v. Pettyjohn" on Justia Law

An inmate at the McPherson Unit, a maximum-security prison in Arkansas, alleged that from 2010 to 2014, a chaplain at the facility sexually assaulted her weekly in his office. The chaplain, who was permitted by policy to be alone with female inmates, also assaulted at least two other inmates in a similar, regular manner. He resigned in 2014 and later pleaded guilty to third-degree sexual assault. The inmate brought a lawsuit under 42 U.S.C. § 1983 against several prison officials in their individual capacities, claiming they failed to protect her from the assaults and failed to supervise the chaplain adequately.The United States District Court for the Eastern District of Arkansas, Chief Judge Kristine G. Baker presiding, denied in part the defendants’ motions for summary judgment based on qualified immunity. The court found there were genuine issues of material fact regarding whether the defendants—three particular officials—were aware of the chaplain’s conduct and were deliberately indifferent to the risk he posed. The district court also found genuine disputes as to whether two of the officials had sufficient supervisory authority over the chaplain to be liable for failure to supervise and whether they took appropriate remedial action.The United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment on qualified immunity grounds. It held that, construing the facts in the light most favorable to the inmate, a reasonable jury could find the defendants were deliberately indifferent to a substantial risk of serious harm, violating clearly established Eighth Amendment rights. The appellate court also held that there were genuine disputes of material fact regarding the supervisory liability of two officials. Accordingly, the Eighth Circuit affirmed the district court’s denial of summary judgment, allowing the inmate’s claims to proceed to trial. View "Arnett v. Norris" on Justia Law

Late on January 10, 2022, Kansas City police officers stopped a pickup truck with a broken headlight and expired license plate. The driver, Alonzo Miller, was not the vehicle’s owner and could not provide proof of insurance. The officers recognized the area Miller had driven from as one known for criminal activity. During the stop, Miller exhibited nervous behavior. A computer check revealed Miller was on probation and parole for a violent felony involving a firearm. The officers, noting a significant age difference between Miller and his passenger and the late hour, suspected possible illicit activity. After Miller mentioned “something under there” when asked about illegal items and consented to a vehicle search, the officers asked him to step out. Miller behaved unusually, triggering further suspicion. As an officer attempted a frisk, Miller resisted, and a firearm discharged from his coat pocket. Miller was arrested and later indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Missouri denied Miller’s motion to suppress evidence from the stop and search. The magistrate judge found the stop lawful, that Miller’s consent to search was voluntary, and that the officers had reasonable suspicion to extend the stop and frisk Miller based on the totality of the circumstances—including Miller’s criminal history, behavior, and responses during the encounter. The district court adopted these findings. Miller then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Miller’s suppression motion, applying de novo review to legal conclusions and clear error review to factual findings. The court held that, under the totality of the circumstances, the officers had reasonable suspicion to extend the stop, request consent to search the vehicle, and frisk Miller. The judgment of the district court was affirmed. View "United States v. Miller" on Justia Law

During a protest in Omaha, Nebraska, following the death of George Floyd, law enforcement declared the gathering an unlawful assembly and ordered the crowd to disperse. Adam Keup, who was present with his partner and friends to document the protest, was standing on a sidewalk near a Walgreens with a backpack containing camera equipment. Unaware of the dispersal order, Keup was shot in the eye with a pepper ball by Deputy Nicholas Palmer, resulting in permanent vision loss. After being shot, Keup was taken behind police lines for medical attention but was not arrested.The United States District Court for the District of Nebraska granted summary judgment in favor of Deputy Palmer, finding that he was entitled to qualified immunity on both the First and Fourth Amendment claims. The district court determined that Keup had not shown he was engaged in protected First Amendment activity that was the but-for cause of the force used against him, and that the use of the pepper ball and subsequent actions did not constitute a clearly established Fourth Amendment seizure.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that Keup failed to establish a causal connection between any protected First Amendment activity and Deputy Palmer’s actions, as there was no evidence Keup was singled out for his expression. Regarding the Fourth Amendment claim, the court concluded that the use of the pepper ball was intended to disperse, not to apprehend, and that taking Keup for medical care did not amount to an unreasonable seizure. Therefore, Deputy Palmer was entitled to qualified immunity, and the district court’s decision was affirmed. View "Keup v. Palmer" on Justia Law

Drexel Starks was arrested for possession of a controlled substance and taken to the St. Louis County Justice Center, where he reported heroin withdrawal symptoms. Jail medical staff placed him on a withdrawal protocol, which included comfort medication and regular nurse assessments. Over the next day, nurses noted some improvement in his symptoms. However, there is no evidence of further assessments as required by protocol. On August 6, a correctional officer found Drexel on the floor with withdrawal symptoms; he was transferred to the infirmary and then to a hospital, where he died. The medical examiner attributed his death to withdrawal from heroin and cocaine, dehydration, and cardiac dysrhythmia.Margaret Starks, Drexel’s mother, filed suit in the United States District Court for the Eastern District of Missouri under 42 U.S.C. § 1983, alleging that jail nurses and a correctional officer were deliberately indifferent to Drexel’s serious medical needs, and that nurse supervisors and St. Louis County failed to train or supervise staff and maintained an unlawful policy of denying medical care. The district court granted summary judgment for the defendants, finding that Margaret failed to establish a violation of Drexel’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that no reasonable jury could find Drexel had an objectively serious medical need that was obvious to a layperson or supported by medical evidence, nor that the defendants acted with deliberate indifference akin to criminal recklessness. The court also held that, absent an underlying constitutional violation, claims against the nurse supervisors and the County for failure to train or supervise, or for unlawful policy, could not succeed. The judgment of the district court was affirmed. View "Starks v. St. Louis County" on Justia Law

A security services company and its sole shareholder, who is also its president and CEO, provided security services to two Iowa cities under separate contracts. After the shareholder published a letter criticizing media coverage of law enforcement responses to protests, a local newspaper published articles highlighting his critical comments about protestors and the Black Lives Matter movement. Subsequently, a city council member expressed concerns about the shareholder’s views, and the city council voted unanimously to terminate the company’s contract. The council member also pressured officials in the other city to end their contract with the company. Facing negative publicity, the company voluntarily terminated its second contract to avoid harm to a pending business transaction.The plaintiffs filed suit in the United States District Court for the Southern District of Iowa against the city, the council member, and other council members, alleging First Amendment retaliation, tortious interference with business contracts, and defamation. The district court granted the defendants’ motion to dismiss all claims under Rule 12(b)(6). It found that the shareholder lacked standing to assert a First Amendment retaliation claim for injuries to the corporation, and that the corporation failed to state a retaliation claim because only the shareholder engaged in protected speech. The court dismissed the tortious interference claim for lack of sufficient factual allegations and because the contract was terminated voluntarily. The defamation claim was dismissed for failure to identify any actionable statements by the defendants.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the dismissal of the shareholder’s First Amendment retaliation and defamation claims, but directed that these dismissals be without prejudice. The court reversed the dismissal of the corporation’s First Amendment retaliation and tortious interference claims, finding that the complaint alleged sufficient facts to survive a motion to dismiss, and remanded those claims for further proceedings. View "Conley v. City of West Des Moines" on Justia Law

In 2024, Minnesota enacted a law that revised the criteria for classifying independent contractors in the construction industry, expanding a previous nine-part test to a fourteen-part test. Several construction industry organizations and a general contractor challenged the law, arguing that certain provisions were unconstitutionally vague and that the civil penalties authorized by the statute violated the Excessive Fines Clause of the Eighth Amendment. The plaintiffs specifically objected to requirements regarding written contracts, invoicing, expense responsibility, and profit or loss realization, as well as the potential for significant civil penalties for noncompliance.The United States District Court for the District of Minnesota denied the plaintiffs’ request for a preliminary injunction to prevent enforcement of the law. The court found that the plaintiffs had not demonstrated a likelihood of success on the merits of their constitutional claims. The plaintiffs then appealed this decision to the United States Court of Appeals for the Eighth Circuit.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the plaintiffs had standing to challenge the law, as they alleged specific conduct targeted by the statute and faced a credible threat of enforcement. However, the court concluded that the challenged statutory terms were sufficiently clear for people of ordinary intelligence and did not encourage arbitrary or discriminatory enforcement. The court also determined that the plaintiffs’ excessive fines claim was premature, as no penalties had yet been imposed and Minnesota law requires a proportionality analysis before penalties are assessed. Because the plaintiffs failed to show a likelihood of success on the merits, the court found no basis for a preliminary injunction and affirmed the lower court’s judgment. View "MN Chapter of Assoc. Builders v. Blissenbach" on Justia Law

Iowa enacted a law making it a state crime for certain noncitizens who had previously been denied admission, excluded, deported, or removed from the United States to enter or be found in Iowa. The law also required state judges to order such individuals to return to the country from which they entered and prohibited state courts from pausing prosecutions based on pending or possible federal immigration status determinations. Two noncitizens residing in Iowa, both of whom had previously been subject to federal removal orders but later lawfully reentered the United States, along with a membership-based immigrant advocacy organization, challenged the law, arguing it was preempted by federal immigration law.The United States District Court for the Southern District of Iowa found that the plaintiffs had standing and granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their claim that the Iowa law was preempted by federal law under both conflict and field preemption doctrines. The district court also found that the plaintiffs would suffer irreparable harm if the law went into effect and that the balance of equities and public interest favored an injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, reviewing legal conclusions de novo and factual findings for clear error. The Eighth Circuit affirmed the preliminary injunction, holding that the plaintiffs had standing and were likely to succeed on the merits because every application of the Iowa law would conflict with federal immigration law by interfering with the discretion Congress grants to federal officials. The court also found that the other factors for a preliminary injunction were met. The Eighth Circuit remanded for the district court to determine the appropriate scope of the injunction in light of recent Supreme Court guidance. View "IA Migrant Movement for Justice v. Bird" on Justia Law

The plaintiff, who worked for a bank that operated a branch inside a public high school, was terminated from her employment after she publicly criticized the local school district’s mask mandate on social media and at school events. The bank’s operation at the school was part of a partnership in which the bank provided funds and services to the school district. The plaintiff’s children attended schools in the district, and she was active in school-related activities. After a series of confrontations and a critical Facebook post about a school board member, the school superintendent communicated with the bank’s branch manager, expressing disapproval of the plaintiff’s conduct and requesting that she be barred from school property. The bank subsequently suspended and then fired the plaintiff, citing her conduct and the school’s ban.The United States District Court for the District of Minnesota granted summary judgment to all defendants, finding that the plaintiff’s First Amendment rights were not violated and that there was insufficient evidence of a conspiracy or tortious interference. The court applied the Pickering balancing test, treating the plaintiff as a government contractor, and found no actionable retaliation. It also found no evidence of a meeting of the minds between the bank and the school district, and held that the superintendent and other officials were entitled to qualified immunity.The United States Court of Appeals for the Eighth Circuit reversed in part and affirmed in part. The court held that the plaintiff was not a government employee or contractor for First Amendment purposes and was entitled to ordinary citizen protections. It found that there was sufficient evidence for a jury to decide whether the superintendent, the bank, and the branch manager retaliated against the plaintiff for protected speech, and whether the superintendent tortiously interfered with her employment. However, the court affirmed summary judgment for the school board chair and the school district, finding insufficient evidence of their direct involvement or policy liability. The case was remanded for further proceedings. View "McNeally v. HomeTown Bank" on Justia Law

An inmate in Missouri, facing imminent execution, requested that his two daughters—both ordained ministers—be allowed to serve as his spiritual advisors in the execution chamber. One daughter would administer communion and anoint him with oil, then move to the viewing area, while the other would enter the chamber to pray over and touch him during the execution. The Missouri Department of Corrections denied this request, citing security concerns, but offered alternatives: a non-relative spiritual advisor, prison clergy, or his attorney could perform the rituals, with his daughters directing the proceedings from behind glass.After exhausting administrative remedies and just five days before his scheduled execution, the inmate filed suit in the United States District Court for the Eastern District of Missouri. He alleged that the Department’s refusal violated his rights under the First Amendment’s Free Exercise Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA). He sought a preliminary injunction and a stay of execution. The district court denied his requests and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of a stay of execution. The court focused on whether the inmate had shown a likelihood of success on the merits, specifically whether the Department’s policy imposed a “substantial burden” on his religious exercise under RLUIPA. The court found that, while the inmate preferred his daughters as spiritual advisors, he did not demonstrate that only they could perform the rituals in accordance with his beliefs. The court concluded that the Department’s alternatives did not significantly inhibit his religious exercise and that security concerns justified the restriction. The Eighth Circuit denied the motion for a stay of execution. View "Shockley v. Adams" on Justia Law