Justia Constitutional Law Opinion Summaries

Plaintiff resigned from his employment as a surgeon with Mayo Clinic (“Mayo”) after an internal committee recommended his termination following an investigation into allegations of his misconduct. Plaintiff sued Mayo and his supervisor, alleging discrimination and reprisal. The district court granted summary judgment in favor of Mayo and the supervisor.   The Eighth Circuit affirmed the district court’s ruling. The court explained that Plaintiff argues Mayo’s recommendation to terminate his employment was based on his race, religion, and national origin. Because Said does not offer direct evidence of discrimination, Plaintiff must create a sufficient inference of discrimination under the McDonnell Douglas framework to survive summary judgment.   Here, Plaintiff claims another similarly situated former employee, who also received complaints, from Mayo received preferential treatment. The court concluded that even if Plaintiff was similarly situated to the other employee, the court concluded that Plaintiff does not present sufficient evidence for a reasonable jury to conclude he received disparate treatment from the other employee. The court further explained that the record overwhelmingly demonstrates that Mayo believed Plaintiff was guilty of making unwelcomed advances toward female coworkers and of other misconduct. Said fails to “create a real issue as to the genuineness of” Mayo’s perceptions. Finally, regarding Mayo’s reporting of Plaintiff’s resignation to the State Board, as already discussed, the record demonstrates Mayo believed it was required to report Plaintiff’s termination to the State Board because Plaintiff resigned during an open investigation into his misconduct. Thus, Plaintiff fails to present sufficient evidence showing this was a pretext for retaliatory intent. View "Sameh Said v. Mayo Clinic" on Justia Law

Defendant was convicted by a jury of possession of a firearm by a prohibited person, in violation of 18 U.S.C. Section 922(g)(9), and possession of a firearm with an obliterated serial number, in violation of 18 U.S.C. Section 922(k). The district court sentenced him to 125 months’ imprisonment. On appeal, Defendant makes several arguments: first, that the district court erred in denying his request for an entrapment instruction; second, he raises a Brady claim; and third, he argues ineffective assistance of counsel.   The Eighth Circuit affirmed. The court explained that factual record establishes law enforcement and its informant merely provided Defendant an opportunity to make a sale, which revealed Defendant’s unlawful possession of the firearm that he sold to the agent.  As there is no evidence of inducement, the court was not required to give entrapment instruction.   Further, Defendant’s assertions are too speculative to support a Brady claim. The jury heard the relevant testimony and was thus aware of the conflicting recollections of the agent and the confidential informant about the events leading to the sale. Furthermore, considering the weight of evidence against Defendant on the two counts of conviction, the failure to disclose the identity of the informant’s brother did not prejudice him. Finally, the court declined to hear Defendant’s ineffective-assistance claim. The court held that it only reviews such claims on direct appeal in “exceptional cases”, and this case is not such an instance. View "United States v. Brandon Hayes" on Justia Law

Plaintiff sued, now retired, police officer, after an encounter that led to Klein’s arrest and a truncated prosecution. The district court granted Defendant’s motion for summary judgment, and Plaintiff appealed the dismissal of his claims alleging unlawful seizure, false arrest, and malicious prosecution.The Eighth Circuit affirmed, concluding that the seizure and arrest claims were untimely and that the malicious prosecution claim fails on the merits. The court explained that Plaintiff’s false arrest claim accrued when he was bound over for trial on June 20, 2017, and his unlawful seizure claim accrued at the time of the seizure, on June 19, 2017. The action filed on November 6, 2019, was therefore untimely as to these claims as well. The district court properly granted Defendant’s motion for summary judgment on Plaintiff’s claims alleging false arrest and unlawful seizure under both federal law and Iowa law.Moreover, the court concluded that Defendant had probable cause to arrest Plaintiff or possession with intent to deliver more than five grams of methamphetamine, and failure to possess a tax stamp for seven grams of methamphetamine. Plaintiff argues that Defendant lacked probable cause because his search for the evidence violated the Fourth Amendment and the Iowa Constitution. The existence of probable cause in a civil action, however, is measured based on all evidence known to the arresting officer, whether or not it would have been admissible at trial. View "Michael Klein v. Warren Steinkamp" on Justia Law

Plaintiff and other death-row prisoners in Arkansas sued the governor and a corrections official, arguing that Arkansas’s three-drug execution protocol violates the Eighth Amendment. After a bench trial, the district court found that the prisoners failed to establish a violation, and denied a motion for new trial.   The prisoners argue that the district court clearly erred in finding that they failed to demonstrate that the Arkansas execution protocol creates a substantial risk of severe pain. The Eighth Circuit affirmed. The prisoners cite expert testimony from Dr. Craig Stevens and Dr. Gail Van Norman that midazolam has a ceiling effect that occurs at a dose between 0.2 to 0.4 mg/kg. These experts relied on two medical studies, which are known by the names of their principal authors as the Inagaki study and the Miyake study. The court wrote that with no scientific consensus and a paucity of reliable scientific evidence concerning the effect of large doses of midazolam on humans, the district court did not clearly err in finding that the prisoners failed to demonstrate that the Arkansas execution protocol is sure or very likely to cause severe pain. Accordingly, the district court properly dismissed the claim under the Eighth Amendment.   Further, the prisoners failed to establish that the State’s existing method was sure or very likely to cause needless suffering, so the State was not required to consider alternative methods. The district court did not abuse its discretion in denying the motion. View "Stacey Johnson v. Asa Hutchinson" on Justia Law

In 2020, Kansas City began restricting participation in its Minority Business Enterprises and Women’s Business Enterprises Program to those entities whose owners satisfied a personal net worth limitation. Mark One Electric Co., a woman-owned business whose owner’s personal net worth exceeds the limit, appeals the dismissal of its lawsuit challenging the Kansas City Program as unconstitutional because of the personal net worth limitation.The Eighth Circuit affirmed. The court explained that to survive strict scrutiny, the government must first articulate a legislative goal that is properly considered a compelling government interest, such as stopping the perpetuation of racial discrimination and remediating the effects of past discrimination in government contracting. Here, Mark One does not dispute that the City has a compelling interest in remedying the effects of race and gender discrimination on City contract opportunities for minority- and women-owned businesses. And Mark One has conceded the 2016 Disparity Study provides a strong basis in evidence for the MBE/WBE Program to further that interest.The City’s program must be narrowly tailored, which requires that “the means chosen to accomplish the government’s asserted purpose are specifically and narrowly framed to accomplish that purpose. Mark One claims that its exclusion from the Program despite its status as a woman-owned business shows that the Program is unlawful Indeed, Mark One has declared that it has suffered past discrimination, as the Program requires for certification. But the City does not have a constitutional obligation to make its Program as broad as may be legally permissible, so long as it directs its resources in a rational manner not motivated by a discriminatory purpose. View "Mark One Electric Company v. City of Kansas City, Missouri" on Justia Law

Defendant was convicted of kidnapping resulting in death and conspiracy to commit kidnapping. On appeal, Defendant challenges several rulings of the district court* and the sufficiency of the evidence in support of the convictions.The Eighth Circuit affirmed. Defendant’s first argument on appeal is that the district court erred by denying his motion to suppress statements from the interviews on November 8 and 21, 2018. He contends that investigators subjected him to custodial interrogations without advising him of his rights under Miranda v. Arizona. The court concluded that there was no custodial interrogation of Defendant on November 8. Defendant responded to the FBI agent’s request for a conversation and agreed to let the agent come to his house for the meeting. The agent did not display a weapon or restrain Defendant in any way. The agent was dressed in plain clothes and allowed Defendant’s wife to sit nearby for the interview. Further, the court held that there is no indication that Defendant is particularly susceptible to undue influence: he is an adult of average intelligence who has earned an associate’s degree and is familiar with the protections afforded by the legal system due to an extensive criminal history.Moreover, the court held that the district court did not abuse its discretion by concluding that the probative value of the evidence was not substantially outweighed by a danger of unfair prejudice. Further, the court concluded that there was no error in declining to instruct the jury that the government must prove that Defendant knew in advance that death would result from the kidnapping. View "United States v. Ramon Simpson" on Justia Law

Defendant entered a conditional guilty plea to a charge of conspiracy to distribute methamphetamine. She reserved her right to appeal an order of the district court denying her motion to suppress evidence that police seized after conducting a protective sweep of a hotel room in which she was staying. See Fed. R. Crim. P. 11(a)(2).The Eighth Circuit affirmed, concluding that the officers permissibly entered and searched the hotel room. On appeal, Defendant argues that the district court erred in denying the motion to suppress because the police lacked specific and articulable facts suggesting that a person posing a danger to the officers was located inside the hotel room. She maintains that the officers violated her rights under the Fourth Amendment by entering the hotel room without a warrant and that all evidence seized as a result of the entry should be suppressed.The court explained that a protective sweep of the hotel room was justified here as an inspection of spaces immediately adjoining the place of arrest from which an attack could be immediately launched. It is undisputed that officers were positioned in the doorway to effect the arrest, and that police crossed the threshold into the room under the authority of the warrant. Accordingly, the court held that the officers observed evidence of unlawful drug activity in plain view while conducting the protective sweep did not violate Defendant’s rights under the Fourth Amendment. View "United States v. Angela Garges" on Justia Law

Facing five child-pornography counts and one for enticing a minor, Defendant decided to enter into a plea agreement with the government. Of the six counts, he pleaded guilty to three of them: two for receiving child pornography, each from a separate victim. When the presentence investigation report said he was responsible for receiving pornographic images from two others, Minor Victim 3 and H.P., he filed a written objection. At sentencing, the fact dispute never came up. Defendant did not renew his objection, the government did not present evidence that he had received sexually explicit material from Minor Victim 3 or H.P., and the district court never made any findings. Without ever resolving the factual dispute that the presentence investigation report had flagged, the court sentenced him to 210 months in prison.The Eighth Circuit vacated Defendant’s sentence and remanded for resentencing. The court explained that agrees that Defendant specifically objected to receiving sexually explicit images from Minor Victim 3 and H.P., meaning that the district court could not rely on those facts unless the government proved them by a preponderance of the evidence. The government never did so, yet the district court sentenced Defendant as if it had. The government does not dispute that the error here was “clear or obvious.” Instead, the focus is on the next step in the plain-error analysis: whether the procedural error affected Defendant’s substantial rights. The court vacated the sentence explaining that a failure to correct the error will also seriously affect the fairness, integrity, and public reputation of judicial proceedings. View "United States v. Lamark Combs, Jr." on Justia Law

A jury convicted Defendant of aggravated bank robbery, and the district court sentenced him to mandatory life imprisonment under the federal “three strikes” law. Defendant appealed his conviction and sentence. On appeal, Defendant argued that (A) the district court erroneously admitted evidence of his flight from the second traffic stop; (B) the jury’s verdict lacked sufficient evidence; and (C) the three strikes law is unconstitutional.   The Eighth Circuit affirmed.  The court held that the district court did not clearly abuse its discretion in concluding any danger of unfair prejudice did not substantially outweigh the evidence’s probative value. Here, evidence of Defendant’s flight from the second traffic stop helped establish the government’s narrative that Defendant continually evaded police for ten days following the robbery. It also helped the jury understand why the police found Defendant, as well as incriminating evidence, in another state. Further, Defendant’s sole argument on appeal is that he was mistakenly identified as the robber. But overwhelming evidence indicates his identification was not a mistake. Finally, the court explained that based Defendant’s criminal history outlined earlier, he has proven he remains a danger to the public despite being given a second and third chance to show otherwise. The sentence imposed here was not grossly disproportionate to Defendant’s crime. View "United States v. Anthony Hall" on Justia Law

Three Anoka County residents sued a school district and teachers’ union about their union leave and reimbursement plan, alleging constitutional and statutory violations. The district court dismissed the case for lack of standing. The residents appealed.   The Eighth Circuit reversed the district court’s judgment. The court explained that pleading jurisdiction requires only “a short and plain statement of the grounds for the court’s jurisdiction,” while pleading the merits requires not just “a short and plain statement of the claim,” but one that “show[s] that the pleader is entitled to relief.” Here, the residents adequately alleged they are school district taxpayers and identified a “municipal action” contributing to their injury. Specifically, the school district spends tax revenues on the allegedly illegal action because the collective-bargaining agreement requires it to provide up to 100 days of paid leave, and the union does not fully reimburse that expense. Since the district court did not address the preliminary injunction factors, the common approach is to remand for the district court to conduct the full analysis in the first instance. View "Don Huizenga v. ISD No. 11" on Justia Law