Justia Constitutional Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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The United States Court of Appeals for the Eighth Circuit reviewed a case involving a group of plaintiffs who owned properties near proposed wind turbine sites in Page County, Iowa. The plaintiffs sued the county, its board of supervisors, and county officials after the board issued a commercial wind energy permit to Shenandoah Hills Wind Project, LLC (SHW). The plaintiffs claimed that the issuance of the permit violated the Due Process Clause of the Fourteenth Amendment, the Iowa Constitution, Iowa Code, and county ordinances. They also claimed that county officials violated the Iowa Open Meetings Act by holding nonpublic meetings on SHW's application. The defendants removed the case to federal court based on the federal due process claim.The district court dismissed the federal due process claim for lack of prudential standing and as implausibly pleaded under Federal Rule of Civil Procedure 12(b)(6). It also dismissed the state claims as time-barred under Iowa law and implausibly pleaded under Rule 12(b)(6). After the district court's decision, the county revoked the permit. Despite the revocation, the plaintiffs appealed the district court's order.The Court of Appeals held that the county's revocation of SHW's permit mooted the plaintiffs' claims, except for their claims under the Iowa Open Meetings Act. The court affirmed the district court's exercise of supplemental jurisdiction over these remaining claims and its dismissal of them. The court vacated the remainder of the district court's order and remanded the case to the district court with instructions to dismiss the non-Open Meetings claims as moot. View "Hunter v. Page County, Iowa" on Justia Law

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The case involves Anthony Willis, who was charged with being a felon in possession of a firearm. Willis requested to represent himself in court, a request that was granted by the magistrate judge after a hearing confirmed Willis was competent to do so and had knowingly and voluntarily waived his right to counsel. Willis was warned that his right to self-representation could be revoked if he conducted himself in an obstructive or disruptive manner. Throughout the pretrial proceedings, Willis repeatedly asserted "sovereign citizen" arguments and defenses.The district court revoked Willis's right to represent himself on the morning of the trial after he ignored a warning and again asserted his sovereign citizen theories and defenses. Willis was then represented by standby counsel, and a jury convicted him. Willis appealed his conviction and sentence, arguing that the district court erred by revoking his right to represent himself on the morning of the trial.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision to revoke Willis’s right of self-representation de novo. The court concluded that the record at the time the district court revoked Willis’s right to represent himself does not reflect that he had engaged or would engage in the “serious and obstructionist misconduct” that Faretta and controlling precedents require. Therefore, the court reversed the judgment of conviction and remanded for further proceedings. View "United States v. Willis" on Justia Law

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Tyrone Cameron was convicted of being a felon in possession of ammunition following a three-day trial. The district court sentenced him to 120 months' imprisonment and a three-year term of supervised release. Cameron appealed, arguing that there was insufficient evidence to support his conviction, that his conviction violated the Second Amendment, that the district court should not have admitted his prior felony convictions involving firearms into evidence, and that the government engaged in prosecutorial misconduct during closing arguments.The district court had reviewed the evidence, including surveillance footage and testimonies, and found sufficient circumstantial evidence to support Cameron's conviction. The court also admitted Cameron's prior felony convictions into evidence, which were relevant to show that Cameron knew he was a felon and knowingly possessed ammunition.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that a reasonable jury could have found there existed ample circumstantial evidence to support Cameron’s conviction. The court also rejected Cameron's Second Amendment challenge, noting that the Supreme Court's decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen did not cast doubt on longstanding prohibitions on the possession of firearms by felons. The court found no error in the district court's admission of Cameron's prior felony convictions, as they were relevant to the case and not unfairly prejudicial. Lastly, the court found no prosecutorial misconduct, as the government's remarks during closing arguments were permissible interpretations of the evidence. View "United States v. Tyrone Cameron" on Justia Law

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Devonte Veasley was charged with possessing a firearm while using a controlled substance, following an incident where he shot at his drug dealer. Veasley pleaded guilty to the charge. However, after the Supreme Court ruled in New York State Rifle & Pistol Ass’n v. Bruen that a New York law requiring "proper cause" to carry a firearm violated the Second Amendment, Veasley sought to withdraw his plea or have the indictment dismissed. He argued that the federal statute under which he was charged, 18 U.S.C. § 922(g)(3), which criminalizes the possession of a firearm by someone using or addicted to a controlled substance, was facially unconstitutional. The district court did not allow him to withdraw his plea or dismiss the indictment.On appeal, the United States Court of Appeals for the Eighth Circuit rejected Veasley's facial challenge to the statute. The court reasoned that the prohibition of firearm possession by drug users or addicts does not always violate the Second Amendment. The court drew analogies to historical regulations that restricted the rights of certain groups, such as the mentally ill and those who used firearms to terrorize others, to bear arms. The court concluded that, at least for some drug users, the statute imposes a comparable burden on the right to bear arms and serves a comparable justification. Therefore, the court affirmed the judgment of the district court. View "United States v. Veasley" on Justia Law

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In March 2021, Jeffrey A. Winder and Heather Durbin rented a room at a motel. During check-in, the motel manager, Gary McCullough, warned Winder that any illegal activity would result in eviction. The next day, McCullough entered the room for cleaning and discovered a backpack containing what appeared to be methamphetamine. He immediately called 911 and informed the responding officers about his discovery. Upon the officers' arrival, McCullough granted them permission to enter the room, which led to them finding more drugs and a handgun. Winder and Durbin were later arrested when they returned to the motel; another gun and more drugs were found in their vehicle.Before trial, Winder moved to suppress all the evidence obtained from the warrantless search of the motel room, arguing that his Fourth Amendment rights were violated. A magistrate judge recommended that the motion to suppress be denied. The district court adopted this recommendation, ruling that Winder had been evicted at the time of the search and that the officers had probable cause to search the backpack based on McCullough's account. Winder pleaded guilty conditionally to one count of possession of methamphetamine with intent to distribute and one count of possession of a firearm in furtherance of a drug trafficking crime, reserving his right to appeal the denial of his motion to suppress.On appeal to the United States Court of Appeals for the Eighth Circuit, the court affirmed the district court's denial of the motion to suppress. The court found that Winder was lawfully ejected from the motel room prior to the officers' entry, thus eliminating his expectation of privacy. The court also ruled that the officers' search of the backpack did not violate the Fourth Amendment as it did not exceed the scope of McCullough's private search. Consequently, the use of a drug dog and the subsequent seizure of evidence did not violate Winder's Fourth Amendment rights. Therefore, the judgment of the district court was affirmed. View "United States v. Winder" on Justia Law

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The case revolved around Darron Mayo, who was appealing the denial of his motion to suppress evidence obtained from a hidden camera placed by police officers across his apartment door. The evidence from this camera was used to obtain a search warrant for Mayo's apartment, where police found drugs, paraphernalia, cash, a loaded pistol, and an iPhone containing incriminating photographs and videos.Mayo argued that the footage from the hidden camera violated his Fourth Amendment rights and that the search warrant was deficient after removing evidence obtained from the camera. He also contended that the good-faith exception to the exclusionary rule did not apply. The United States Court of Appeals for the Eighth Circuit, however, affirmed the decision of the District Court, ruling that the probable cause affidavit remained sufficient even when the evidence from the hidden camera was omitted.The court cited four sets of related facts supporting this conclusion. First, various drugs, a scale, and stolen handguns were found in a car associated with Mayo. Second, Mayo's fingerprints were found on a handgun magazine, and a video linked him to the vehicle. Third, during a traffic stop, Mayo gave a false name, marijuana was found in the car, and he made incriminating phone calls recorded by a police dash camera. Fourth, utilities in Mayo's name connected him to the apartment in question. These facts indicated a fair probability that contraband or evidence of a crime would be found in his apartment. Therefore, the court held that the hidden camera footage was not necessary to establish probable cause. View "United States v. Mayo" on Justia Law

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Three shareholders of Fannie Mae and Freddie Mac sued the Federal Housing Finance Agency (FHFA) and the Department of the Treasury, alleging harm from the unconstitutional removal restriction of the Housing and Economic Recovery Act of 2008. Their claims were based on the premise that if President Trump had been able to remove the FHFA Director without restrictions, he would have ended a provision that, in the event of liquidation, allowed the Treasury to recover its full preference before any other shareholder. The district court dismissed the shareholders' claims, finding that they did not sufficiently demonstrate any harm.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court noted that to challenge agency action, a party must not only show that the removal restriction is unconstitutional but also that the provision caused or would cause them harm. The court found that the shareholders' assertions did not satisfy this standard. They relied heavily on a post-presidency letter from President Trump expressing his desire to have removed the FHFA Director during his presidency. The court determined that this letter did not meet the criteria of a "public statement expressing displeasure" as outlined by the Supreme Court in Collins v. Yellen. Furthermore, the court found the shareholders' circumstantial evidence of harm speculative and insufficient to state a claim for relief. Therefore, the court affirmed the dismissal of the claims. View "Bhatti v. Fed. Housing Finance Agency" on Justia Law

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In this case, the United States Court of Appeals for the Eighth Circuit was asked to determine whether Arkansas Code § 23-92-604(c), also known as Act 1103, was preempted by federal law. Act 1103 prohibits pharmaceutical manufacturers from limiting the ability of healthcare providers, who are eligible for drug pricing discounts under the Section 340B Program, to contract with outside pharmacies for drug distribution.The Pharmaceutical Research and Manufacturers of America (PhRMA) sued the Commissioner of the Arkansas Insurance Department, arguing that Act 1103 was unconstitutional because it was preempted by the Section 340B Program and the Federal Food, Drug, and Cosmetic Act, under theories of field, obstacle, and impossibility preemption.The court, however, disagreed with PhRMA's arguments. The court found that Act 1103 did not create an obstacle for pharmaceutical manufacturers to comply with 340B, rather it assisted in fulfilling the purpose of 340B. The court also found that Act 1103 did not make it impossible for drug manufacturers and wholesale distributors to comply with the Risk Evaluation and Mitigation Strategies (REMS) Program under the Federal Food, Drug, and Cosmetic Act.Therefore, the court held that Act 1103 was not preempted by either the Section 340B Program or the Federal Food, Drug, and Cosmetic Act. As such, the court affirmed the district court’s decision in favor of the Intervenors and against PhRMA. View "Pharmaceutical Research and Mfrs of America v. McClain" on Justia Law

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Two former police officers, Thomas Noon and Christopher Skidmore, were dismissed from their jobs in Platte Woods, Missouri, after submitting a letter of grievances about the police chief, James Kerns, to the city's mayor and Board of Aldermen. The officers filed a lawsuit against the mayor and police chief, claiming their First Amendment rights were violated under 42 U.S.C. § 1983. The defendants moved for summary judgment based on qualified immunity, but the district court denied their motion. The defendants then brought an interlocutory appeal.Noon and Skidmore had raised several concerns about Kerns's performance as Chief of Police, including issues with department vehicles, radar equipment, personnel, and Kerns's use of department time for personal business. After their concerns were not addressed, the officers sent a document outlining their grievances to the mayor and the Board of Aldermen. After the officers admitted to authoring the document, they were both removed from the department's schedule and eventually fired.In reviewing the case, the United States Court of Appeals for the Eighth Circuit found that the officers had established a First Amendment violation. The court determined that the officers' speech, criticizing the police chief's leadership and alleging corruption and financial mismanagement, was made as citizens on matters of public concern. The court also concluded that the defendants failed to show that the officers' speech had an adverse impact on the department's operations. Finally, the court determined that the officers' First Amendment right to be free from retaliation for protected speech was clearly established. Therefore, the defendants were not entitled to qualified immunity. The court affirmed the district court's decision. View "Noon v. Smedley" on Justia Law

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The case involves Sanimax USA, LLC, who sued the City of South Saint Paul, Minnesota, under 42 U.S.C. § 1983, alleging that the city's zoning and odor ordinances violated the First Amendment and Equal Protection Clause. Sanimax contended that the city enacted these ordinances in retaliation for Sanimax challenging prior ordinances and that the ordinances unfairly singled out Sanimax. The district court granted the city's motion for summary judgment on all counts.Sanimax operates a rendering plant in South Saint Paul that processes animal carcasses and organic byproducts, emitting pungent, foul odors that have drawn numerous complaints from nearby residents and businesses. Sanimax was designated as a "Significant Odor Generator" by the city, and later challenged the constitutionality of the city's odor ordinance, alleging that it was unconstitutionally vague.The United States Court of Appeals For the Eighth Circuit affirmed the district court's decision. The Court found that Sanimax failed to show that the city's actions were a direct retaliation for Sanimax's prior lawsuits challenging the city's ordinances. Additionally, the Court rejected Sanimax's argument that it was unfairly singled out, finding that Sanimax was not similarly situated to other businesses due to the significantly higher number of odor complaints it generated. Lastly, the Court rejected Sanimax's argument that the city's odor ordinance was unconstitutionally vague, finding that the ordinance provided sufficient notice of the prohibited conduct and did not lend itself to arbitrary enforcement. View "Sanimax USA, LLC v. City of South St. Paul" on Justia Law