Justia Constitutional Law Opinion Summaries

Defendant and the government reached a binding plea agreement whereby Defendant would plead guilty to transportation of a minor in violation of 18 U.S.C. Section 2423(a) and receive a below-guideline sentence of 150 months. At a change-of-plea hearing in March, the district court rejected the plea agreement. At the end of the second hearing, the district court accepted Defendant’s guilty plea. The district court imposed a sentence of life without the possibility of parole.   Defendant appealed arguing that the district court participated in plea negotiations in violation of Rule 11(c)(1) of the Federal Rules of Criminal Procedure, requiring vacatur of his conviction and sentence. The Eighth Circuit affirmed the district court’s order.   The court explained that Defendant waived “all rights to appeal or collaterally attack . . . [his] conviction or sentence [and] all non-jurisdictional issues.” Because Defendant’s appeal requests vacatur of his conviction and sentence, it falls within the scope of the waiver. However, a violation of Rule 11(c)(1) is appealable unless the defendant specifically waives “an appeal challenging the voluntariness of his plea.” Here, Defendant did not waive his right to appeal, thus the court wrote that Defendant must show that the district court’s error affected his substantial rights. The court explained that although at least one factor favors Defendant, the particular facts and circumstances in the entire record here do not show that the Rule 11 violation affected Defendant’s substantial rights. View "United States v. Douglas Schneider" on Justia Law

Missouri challenged the Secretary of the Treasury’s implementation of the American Rescue Plan Act of 2021 (ARPA), Pub. L. No. 117-2, 135 Stat. 4. Missouri argues that the Secretary’s “erroneously broad interpretation” of a provision in ARPA—the “Offset Restriction”—is unconstitutional. The district court dismissed the case, finding that Missouri lacked standing and that Missouri’s claims were not ripe for adjudication.   On appeal, Missouri identifies five specific ways it has been injured: (1) the broad interpretation of the Offset Restriction punishes Missouri for exercising its constitutional right to set taxes; (2) the Secretary’s “embrace of the broad interpretation” has harmed Missouri’s interest in the offer Congress provided to the State; (3) Treasury’s regulations make ARPA’s requirement more onerous, leading to greater compliance costs; (4) under the broad interpretation, there is an increased chance Missouri will lose ARPA funds; and (5) under the pre-enforcement test, Missouri has alleged an intention to engage in conduct arguably affected with a constitutional interest, but proscribed by statute, with a credible threat of enforcement hanging over it.   The Eighth Circuit affirmed, finding that Missouri has not alleged an injury in fact. The court explained that Missouri has only alleged a “conjectural or hypothetical” injury, not one that is actual or imminent. It has also not alleged a future injury that is “certainly impending” or even likely to occur. Instead, Missouri asked the court to declare, in the abstract, what a statute does not mean. It asked the court to enjoin a hypothetical interpretation of the Offset Restriction that the Secretary has explicitly disclaimed, without alleging any concrete, imminent injury from the Secretary’s actual interpretation. View "State of Missouri v. Janet Yellen" on Justia Law

After two separate arrests Defendant was charged with nine conspiracy- and drug-related counts in a 19-count second superseding indictment. The district court denied Defendant’s motion to suppress the evidence recovered during these stops. At sentencing, the district court varied downward from the United States Sentencing Guidelines range of 360 months to life imprisonment and sentenced Defendant to 180 months imprisonment and 5 years supervised release. Defendant appealed his conviction, arguing that the district court erred in denying his motion to suppress, the evidence was not sufficient to support his conviction on three of the nine counts, and the district court gave an erroneous jury instruction. The government cross-appealed Defendant’s sentence, arguing that the district court procedurally erred when it relied on clearly erroneous facts.   The Eighth Circuit affirmed the conviction and sentence.  Amongst other claims, Defendant argued that the March 12 stop and accompanying pat-down and inventory searches, as well as the November 1 stop, was unconstitutional and that the district court erred in denying his motion to suppress the evidence recovered pursuant to these illegal stops and searches. The court explained that the detective did not exceed the allowable scope of the pat-down search when he reached into Defendant’s pocket. “Because the ‘sole justification for such a search is the protection of the officer and others, its scope must be confined to a search reasonably designed to discover concealed weapons.”   Further, the court found that the district court did not commit plain error by failing to sua sponte instruct the jury as to some unspecified “heightened showing” required to prove constructive possession. View "United States v. Eric Williams" on Justia Law

After the district court denied Defendant’s motion to suppress evidence, Redman pleaded guilty to possession of a firearm by a prohibited person in violation of 18 U.S.C. Sections 922(g)(1) and 924(a)(2). Defendant appealed, arguing that the arresting officer lacked reasonable suspicion to seize him and that evidence recovered after the seizure should have been suppressed.   The Eighth Circuit affirmed the district court’s judgment denying Defendant’s motion to suppress evidence. The court explained, during a Terry stop, an officer may “take such steps as [are] reasonably necessary to protect their personal safety and to maintain the status quo during the course of the stop,” including frisking a person for weapons if the officer has “articulable suspicion that the person is armed and dangerous.”   Here, the parties agree that Defendant was not seized until the officer physically grabbed his jacket. The court concluded that the officer had reasonable articulable suspicion to detain Defendant at that time. The officer was investigating an early-morning report of shots fired near 1:00 a.m. in a high-crime area. That he had been told that the call may have pertained to fireworks did not alone end his investigation, however. The officer knew that, among other facts, Defendant was one of only two people present in the dark parking lot that was the alleged location of the shots fired. Given these circumstances, the officer had reasonable suspicion that Defendant may have been involved in a shots fired incident, which justified his decision to seize Defendant and to perform a limited search to determine if Defendant was armed. View "United States v. Anthony Redman" on Justia Law

Appellant, a black male who was 60 years old at the time his employment was terminated, brought race, sex, and age discrimination claims under Title VII, the Age Discrimination in Employment Act (“ADEA”), and the Minnesota Human Rights Act (“MHRA”) and a retaliation claim under the Minnesota Whistleblower Act ("MWA") after the Minnesota Guardian ad Litem Board (“GALB”) terminated his employment following internal and external investigations into allegations of his misconduct. The district court granted GALB’s motion for summary judgment, finding that Appellant failed to demonstrate a prima facie case of discrimination or retaliation and, even if he had done so, he failed to demonstrate GALB’s reasons for terminating his employment were pretextual.   Appellant appealed and the Eighth Circuit affirmed. The court explained that Appellant failed to point to any direct evidence of discrimination or retaliation; thus, the McDonnell Douglas burden-shifting framework applies. The court concluded that GALB has demonstrated a legitimate, nondiscriminatory and nonretaliatory reason for terminating Appellant in March 2018: the internal and external investigations into Appellant’s alleged misconduct uncovered evidence that Appellant had engaged in gross misconduct. As such, because Appellant failed to show that GALB’s reasons for terminating his employment were pretextual, the district court did not err in granting summary judgment to GALB on his race, sex, and age discrimination claims and his retaliation claim. View "Gregory King v. MN Guardian ad Litem Board" on Justia Law

Defendant was convicted of attempting to persuade, induce, and entice an individual who had not yet attained the age of 18 years old to engage in sexual activity. The district court sentenced Defendant to a mandatory minimum sentence of 120 months imprisonment under 18 U.S.C. Sec 2422(b). Defendant challenged the district court's imposition of the mandatory minimum sentence as a violation of the Eighth Amendment.The Eighth Circuit affirmed Defendant's sentence, finding that it did not violate the Eighth Amendment's prohibition against cruel and unusual punishment. The court explained that the facts of the case show defendant intentionally engaged in dangerous conduct that was exploitive of children, which is exactly the type of conduct contemplated and targeted by the statute. Under these facts, the court determined that there was no inference of gross disproportionality. View "United States v. Raul Rivas" on Justia Law

Appellant petitioned the district court for a writ of habeas corpus in part on the basis that an off-the-record jury selection procedure violated his constitutional rights. Without holding an evidentiary hearing, the district court dismissed Appellant’s petition with prejudice. The Eighth Circuit granted a certificate of appealability as to whether the district court prematurely dismissed Appellant’s claims that the pretrial jury selection procedure violated his right to be present, right to a public trial and right to an appeal and that his trial counsel was ineffective for participating in the procedure.The Eighth Circuit ultimately affirmed the district court’s ruling. The court explained that Appellant has not shown that “fundamental unfairness” resulted from his trial counsel’s participation in the pretrial jury selection procedure. Appellant alleged that his was fundamentally unfair because he was unaware of the pretrial jury selection procedure and any discriminatory strikes made during this procedure.  However, the court wrote, that Appellant’s trial counsel agreed to and participated in the procedure, which effectively gave both parties an additional 15 peremptory strikes; a record was, in fact, made of these strikes, and maintained by and available for review at the Washington County Circuit Court Clerk’s Office; the written submission of strikes that occurred as part of the pretrial jury selection procedure was only a portion of voir dire; and the remainder of voir dire, along with the evidentiary and sentencing phases of the trial, remained open to the public. Thus, Appellant’s trial counsel’s participation in the pretrial jury selection procedure did not render his trial fundamentally unfair. View "Zachariah Marcyniuk v. Dexter Payne" on Justia Law

Monsanto Company and BASF Corporation began developing dicamba-tolerant seed and sued each other over intellectual property. When the USDA deregulated Monsanto’s dicamba-tolerant soybean seed that year, Monsanto began to sell it. BASF’s lower-volatility dicamba herbicide was approved in 2017. Bader Farms, Inc. sued Monsanto and BASF for negligent design and failure to warn, alleging its peach orchards were damaged by dicamba drift. The jury awarded compensatory damages and punitive damages based on Monsanto’s acts.   The district court denied Defendants’ motions for a new trial and judgment as a matter of law but reduced punitive damages to $60 million. The district court’s judgment also held Monsanto and BASF jointly and severally liable for the punitive damages.   Defendants appealed, arguing that Bader failed to prove causation, the measure of actual damages is the value of the land rather than lost profits, Bader’s lost profits estimate was speculative, and the punitive damages award was unwarranted under Missouri law and excessive under the United States Constitution.   The Eighth Circuit held that Bader established causation by showing Defendants' conduct was both the cause in fact and the proximate cause of Bader's injury. Further, the district court properly refused to find intervening cause as a matter of law or to give an affirmative converse on the issue. However, the evidence established different degrees of culpability between BASF and Monsanto, and the district court should have instructed the jury to separately assess punitive damages against each of them; therefore, the court remanded with directions to hold a new trial only on the issue of punitive damages. View "Bader Farms, Inc. v. BASF Corporation" on Justia Law

After Nygard removed his driveway and was about to pour a new one, an Orono inspector told Nygard that he needed a permit. The next day, Nygard finished the driveway and applied for a permit. The new driveway was narrower than the previous one. The city responded with a form, imposing several conditions. Nygard crossed out some conditions, initialed the modified form, and returned it. After several exchanges, the city notified Nygard that he must agree to the conditions or “this matter will be turned over to the prosecuting attorney.” Nygard did not acknowledge the conditions. A police officer drafted a statement of probable cause, alleging that “work had been completed without having first obtained a permit” and listing some alleged deficiencies in its construction. According to the Nygards, the police did not inspect the property and some allegations were not true.Nygard was acquitted of violating the city code. The Eighth Circuit affirmed the dismissal of his suit under 42 U.S.C. 1983, claiming the code was void for vagueness and alleging First Amendment retaliation, abuse of process, and malicious prosecution. Nygard’s prosecution was not based on falsehoods. The report did not claim that the conditions were required by the code but that Nygard had not agreed to the conditions and had replaced a driveway without a permit. Any failure to investigate did not defeat probable cause; the city already knew that he installed a driveway without a permit. View "Nygard v. City of Orono" on Justia Law

Minneapolis police investigated Randle for selling crack cocaine while he was on supervised release for a prior federal offense. After conducting a controlled buy, Officer Hamilton applied for a warrant to search a Brooklyn Park, Minnesota home that Randle listed as his supervised release address. The warrant was executed that day. Randle arrived during the search. Police seized 308 grams of crack cocaine and related evidence from the home and from bags carried by Randle.The district court denied a motion to suppress, applying the good-faith exception while concluding the affidavit did not create a “fair probability that evidence of Randle’s alleged drug trafficking activities would be found at the Residence” because it did not include Hamilton’s statement that in his professional judgment drug traffickers typically keep narcotics in their home and did not state that Hamilton followed Randle to the residence directly after the controlled buy and failed to specify when the officers started following Randle. The Eighth Circuit affirmed. The evidence is admissible because “it was objectively reasonable for the officer executing [the] search warrant to have relied in good faith on the [issuing] judge’s determination that there was probable cause to issue the warrant.” The court also upheld the denial of a “Franks” hearing; Randle failed to make the necessary “substantial preliminary showing” of “deliberate falsehood or of reckless disregard for the truth.” View "United States v. Randle" on Justia Law