Justia Constitutional Law Opinion Summaries

After a jury convicted Defendant, former Sheriff of Franklin County, Arkansas, of depriving two jail detainees of their constitutional rights by subjecting them to unreasonable force that resulted in bodily injury, the district court sentenced Defendant to 48 months imprisonment, followed by 2 years of supervised release. Defendant challenged both his conviction and his sentence.   The Eighth Circuit affirmed. The court held that the district court’s finding that Defendant attempted to influence Ball’s testimony was not clearly erroneous and sufficiently supports the district court’s application of the obstruction-of-justice enhancement. The district court sentenced Defendant to a within-Guidelines sentence of 48 months’ imprisonment. Defendant argued in a cursory fashion that his sentence is “greater than necessary,” given the alleged de minimis nature of his victims’ injuries and the purported bias of the witnesses at trial. However, the district court discussed Section 3553(a) factors in-depth and considered the proffered mitigating and aggravating circumstances in crafting the sentence. View "United States v. Anthony Boen" on Justia Law

WinRed, a “conduit” political action committee (PAC), centralizes donations to Republican-affiliated candidates and committees. WinRed helps them set up a WinRed.com webpage where donors contribute. WinRed collects and distributes the earmarked contributions. WinRed.com’s technical and maintenance services are at least partly performed by a separate entity, WinRed Technical Services, LLC (WRTS). The relationship between WinRed and WRTS is not clear, but the Eighth Circuit accepts WinRed’s affidavit that it operates exclusively in the domain of federal elections. The district court dismissed WinRed, Inc.’s request for a declaratory judgment and preliminary injunction preventing the Attorneys General from (1) investigating WinRed’s activities with respect to contributions; and (2) bringing a deceptive-practice action against it for those activities.”   The Eighth Circuit affirmed. The court explained that WinRed gives two reasons to look beyond the statutory text. Neither succeeds. The court held that WinRed errs from the start by attacking a disclaimer mandate where none exists. Minnesota’s consumer-protection law prohibits deceptive practices, and federal law does not preempt Minnesota’s enforcing it against WinRed. Because an enforceable state law underlies General Ellison’s investigation, the investigation may proceed. View "WinRed, Inc. v. Keith Ellison" on Justia Law

Defendant was indicted on separate counts of producing, receiving, and possessing child pornography. He moved to suppress all evidence obtained after the warrantless seizure of his cell phone, including the images found on the phone, the evidence seized at his house, and the images found on the hard drive. Defendant also moved to suppress the statements he made to law enforcement. The district court denied Defendant’s motion in its entirety. Shrum entered conditional guilty pleas to one count of producing child pornography and one count of receiving child pornography and was sentenced to 210 months of imprisonment. Defendant timely appealed the denial of his motion to suppress. Defendant argued that his cell phone was seized in violation of the Fourth Amendment and, therefore, the district court erred in denying his motion to suppress.   The Eighth Circuit affirmed. The court held that the Sergeant had probable cause to believe Defendant’s phone contained contraband or evidence of a crime. The Sergeant had seen photos of text messages between A.B. and Defendant that indicated they had engaged in sexual activity, perhaps as recently as on the camping trip the night before. Further, there was a fair probability that those text messages, or related evidence of unlawful conduct, would be found on Defendant’s phone. Exigent circumstances were also present. When the Sergeant did find the victim, it appeared that she had just showered, suggesting to the Sergeant that she may have washed away physical evidence of sexual contact. Given the totality of the circumstances, the court agreed with the district court that the good-faith exception applies. View "United States v. Keith Shrum" on Justia Law

While in jail, Plaintiff clawed at his own eye with enough force to tear it out. Plaintiff sued nearly everyone involved, including St. Charles County, under 42 U.S.C. Section 1983. The district court concluded that none of the individuals involved had violated his Fourth, Eighth, or Fourteenth Amendment rights. Nor, in the absence of a constitutional violation or a county-wide custom of unconstitutional conduct, was St. Charles County liable for his injuries. The question is whether qualified immunity is available to those who may have prevented the injury.   The Eighth Circuit affirmed the district court’s judgment. The court explained that the record is devoid of evidence that the Officer and Sergeant consciously disregarded a serious medical need. And even if the Nurse’s failure to administer Plaintiff’s medications approached criminal recklessness, the court wrote, it cannot say that the law was so “clearly established” that she was on “fair notice” she was violating it. Further, Plaintiff cannot point to any court that has held that an officer was deliberately indifferent because he placed a pepper-sprayed inmate in a new cell with a sink. View "Jamie Leonard v. Steven Harris" on Justia Law

Officers in an armored police vehicle shot tear gas at three people near the scene of a protest in downtown St. Louis. The district court concluded that all three had a First Amendment retaliation claim.   The Eighth Circuit affirmed in part, reversed in part, and remanded. The court agreed that one Plaintiff has a valid First Amendment retaliation claim, but qualified immunity shields the officers from the claims brought by the others. Two of the Plaintiffs claimed that the First Amendment covers what they did, which was to observe and record police conduct during the St. Louis protest. The court wrote that even if it were to assume they are correct, observing and recording police-citizen interactions was not a clearly established First Amendment right in 2015. Further, in regard to Plaintiffs’ peaceful-assembly theory. The court reasoned even if the officers “unreasonably believed” that the group was refusing to comply with their earlier directions to disperse, their official orders—not retaliatory animus—caused them to use the tear gas.   However, in regard to the third Plaintiff, the court explained at this stage, there is enough evidence to establish the “personal involvement” of everyone in the armored vehicle. To be sure, Plaintiff could not see who launched the tear gas canister. But with multiple “officers present,” the jury could find that each one of them participated in the decision or that one did it “while the others failed to intervene.” Under these circumstances, the claims against the individual officers can proceed. View "Sarah Molina v. Daniel Book" on Justia Law

Plaintiff filed a 42 U.S.C. Section 1983 lawsuit stemming from her son’s death while under the supervision of employees at an Arkansas jail. She alleged that Defendants were deliberately indifferent to her son’s serious medical needs. The district court denied Defendants’ motion for summary judgment based on qualified immunity.   The Eighth Circuit reversed. The court explained that it disagreed with the district court’s opinion that a layperson would recognize seizure-like activity as a serious medical need that one of the Defendant’s deliberately ignored. The court reasoned that a reasonable jury could not conclude from this description of events that Defendant was aware of a serious medical need. Second, a reasonable officer would not necessarily infer that seizure-like activity in these circumstances required him to take additional action. The decedent was behaving normally at booking, though very thirsty and reportedly under the influence of methamphetamine. It isn't unreasonable to believe that whatever medical episode he experienced during transport (if he actually experienced one) had fully resolved itself by the time Defendant encountered him.   Further, the court explained that in these circumstances, Defendants can't be faulted for presuming that the medical staff best knows the quantity and quality of information needed for assessments. And even though the decedent was obviously sick, recognizing that someone is sick is not the same as knowing that he is receiving inadequate care from a trained medical professional. View "Donna Reece v. S. Williams" on Justia Law

Defendant pleaded guilty to possession with intent to distribute methamphetamine. On appeal, Defendant challenged an order of the district court denying her motion to suppress evidence obtained during a traffic stop.   The Eighth Circuit affirmed and concluded there was no error. The court explained that probable cause “is not a high bar: It requires only the kind of fair probability on which reasonable and prudent people, not legal technicians, act.” In this case, the detective was not required to exclude all reasonable possibilities that Defendant was ignorant of the scale; he needed only a fair probability that she knew what was in the console. The combination of Defendant’s control over the vehicle, her proximity to the console, her history of an arrest for drugs, and her association with a backseat passenger who possessed drugs was sufficient to establish probable cause for an arrest. View "United States v. Jessica Mathes" on Justia Law

Appellant brought a variety of state and federal claims against the City of Waynesville (the City), the Waynesville Police Department (WPD), WPD Chief, WPD Officers, and Pulaski County Prosecutor (collectively, Appellees). The district court dismissed most of Appellant’s claims pursuant to Federal Rule of Civil Procedure 12(b)(6), and later granted the Appellees’ motion for summary judgment on Appellant’s remaining claims. Appellant appealed the grant of summary judgment. Appellant conceded that his unreasonable seizure and conspiracy-to-cause-false-arrest claims do not involve the officer. Additionally, Appellant clarified that his appeal of the unreasonable search claim is limited to “the district court’s determination about the computer and home searches.”   The Eighth Circuit affirmed. The court held that, at minimum, it was objectively reasonable for the police Chief and Officer to believe that Appellant had committed or was committing a violation of Mo. Rev. Stat. Section 455.085.2, Mo. Rev. Stat. Section 565.090.1 or Mo. Rev. Stat. Section 565.225.2-3. Accordingly, arguable probable cause exists, meaning that it was not clearly established that arresting Appellant on these facts would violate his right to be free from unlawful seizure. Thus, the court affirmed the district court’s grant of summary judgment on Appellant’s unreasonable-seizure claim because Appellees are entitled to qualified immunity.   Further, the court concluded that reasonable suspicion supported the search of Appellant’s house. Moreover, because there is only one minor inaccuracy in the otherwise thorough search warrant affidavit for Appellant’s computer, and the issuing judge found that there was enough evidence to support a finding of probable cause, that judgment is entitled to deference on appeal. View "Dennis Ryno v. City of Waynesville" on Justia Law

A jury convicted Defendant of possessing at least five kilograms of cocaine. Defendant retained new counsel and moved for judgment of acquittal or a new trial, raising numerous issues. The district court denied the motion. Defendant appealed. His principal argument, raised for the first time in the post-verdict motion, is that law enforcement violated the Fourth Amendment by using expired tracking warrants to locate him when he was arrested returning to the Twin Cities from a trip to Chicago with thirteen pounds of cocaine in his vehicle.   The Eighth Circuit affirmed. The court explained that it is undisputed that the Fourth Amendment argument at issue was an issue reasonably available for a pretrial motion to suppress that Defendant did not raise. However, the court agreed to review for plain error.  The court reasoned that nothing seriously affected the fairness or integrity of this prosecution. Whether the tracking warrants expired when Defendant was arrested, interviewed, and released on October 7 is an issue the court does not decide. However, it is hardly free from doubt, so any error in not reaching the issue was not plain. Moreover, Defendant fled when the police attempted to stop him on November 1, leading them on a hazardous high-speed chase that provided probable cause to arrest Defendant for resisting arrest, failing to stop after a collision, and reckless driving. Accordingly, the court affirmed the district court’s denial of Defendant’s motion for judgment of acquittal or a new trial based on the alleged expiration of the tracking warrants. View "United States v. John Pickens, Jr." on Justia Law

Defendant appealed his 2021 conviction for various sex-trafficking offenses. He argues that the Government was prohibited from prosecuting him based on a “No Further Prosecution” clause in a prior 2018 plea agreement that resolved heroin-related charges against him.The Eighth Circuit dismissed the indictment and vacated Defendant’s conviction. The court concluded that the prior plea agreement’s promise of no further prosecution encompasses the sex-trafficking convictions appealed here. The court explained that it considers three actors in considering a defendant’s demand for specific performance of a plea agreement after the defendant has pleaded guilty: (1) the possible prejudice to the defendant, (2) the conduct of the government, and (3) the public interest. Here, the prejudice is clear. Defendant pleaded guilty in 2018 to one drug offense in exchange for the Government dismissing the remaining drug offenses and promising not to bring further charges arising from or directly relating to the investigation. The Government reneged on that promise by pursuing the sex-trafficking prosecution, which relied on facts that were part of and arose out of the 2018 investigation. As a result, Defendant faced charges he would not otherwise have faced had the Government stuck to its bargain. The public also has an interest in safety from criminal behavior and in the prosecution of crimes. But that does not outweigh constitutional due-process interests, and the Government’s breach of the plea agreement violated Defendant’s due-process rights. View "United States v. Marlin Thomas" on Justia Law