Justia Constitutional Law Opinion Summaries

Defendant was convicted of conspiracy to distribute heroin and possession of heroin with the intent to distribute. He appealed the district court’s denial of his motion to suppress and its ruling to limit the cross-examination of a law enforcement witness at trial. The Eighth Circuit affirmed the denial of Defendant’s motion to suppress and the judgment of the district court. The court held that the district court did not err in its credibility finding.Defendant argued that the arresting Trooper lacked a reasonable, articulable suspicion that the occupants of the vehicle Defendant was involved in any criminal activity and, thus, the traffic stop was unlawful. He asserted that the district court clearly erred in its credibility finding and that the trooper’s testimony was “plainly contradicted” by the squad car videos. The court held that Defendant is correct that the video footage does not confirm the Trooper’s testimony concerning each of the three traffic violations, however, nothing in the video footage undermined that testimony.Next, Defendant argued the district court improperly limited his cross-examination of the Trooper at trial. At trial court sustained the government’s objection to the defense’s line of questioning regarding the Trooper and his DRE training, specifically about allegations that officers participating in the training program supplied drugs to young people in Minneapolis. The court held that the district court acted within its discretion to curtail the inquiry. View "United States v. Pierre Stewart" on Justia Law

The president of the Christian Action League of Minnesota (“CAL”), an antipornography advocacy group, frequently contacts those who advertise in a local newspaper. CAL believes that, since the paper runs advertisements for sexually oriented businesses, those who advertise in the paper are endorsing those businesses.CAL’s president continually contacted an attorney who advertised in the paper. The attorney filed a petition for a harassment restraining order ("HRO") under Minnesota Statute Sec. 609.748(2). The statute allows victims to obtain restraining orders against their harassers. CAL brought a pre-enforcement challenge against the Hennepin County Attorney, arguing that the Sec. 609.748(2) violated the First and Fourteenth Amendments. The district court granted Defendant’s motion to dismiss.The Eighth Circuit held that CAL’s complaint does not allege an intention to engage in conduct proscribed by a statute, thus CAL lacks standing. The court reasoned that the Minnesota Supreme Court would not interpret Sec. 609.748(2)'s definition of “harassment” to cover CAL’s speech. As such, nothing CAL wants to do is criminalized by the Statute. Further, because there is no allegation that the County Attorney has enforced the Statute against CAL’s protected speech or has any plans to do so, the Plaintiff lacks standing. View "Christian Action League of MN v. Mike Freeman" on Justia Law

Defendant appeals the district court’s imposition of a 66-month sentence for illegal possession of a firearm. On appeal, Defendant argues that there was insufficient evidence that he knew he was a prohibited person under any category; the prosecutor violated his right to a fair trial by misstating the presumption of innocence, and his sentence was improperly enhanced because the Iowa assault conviction is not a “crime of violence.”The Eighth Circuit found that there is sufficient evidence of an intimate partnership, including evidence of the no-contact order itself, with the state judge’s finding that Defendant and the victim met the federal definition of intimate partners. Next, the court found that the no-contact order here was issued as part of the judgment agreed to by Defendant, who was represented by counsel, in his guilty plea. Third, the court held that Iowa presumes that a no-contact order “has force and effect until it is modified or terminated by subsequent court action.” In Iowa, the absence of a record can prove the nonoccurrence of an act or event, here the nonoccurrence of any modification or termination of the no-contact order. Thus, the court held the evidence was sufficient to find that Defendant possessed a firearm with knowledge that he was subject to a no-contact order involving an intimate partner. Further, Defendant has not shown that the improper remarks prejudiced his right in obtaining a fair trial. Finally, increase to Defendant’s base offense level under Sec. 2K2.1(a), if error at all, was harmless. View "United States v. Junior Roldan Marin" on Justia Law

A jury found Defendant guilty of sexual abuse of an incapacitated victim. On appeal, Defendant challenges one pretrial evidentiary ruling by the district court and one of its directives at trial.Defendant argued that the district court erred in allowing the government to elicit testimony from the victim and her mother regarding the victim’s suicide attempt. Defendant’s primary argument was that the testimony lacked sufficient probative value to overcome its potential prejudicial effect on the jury as it determined whether the victim was sexually assaulted. The court found that the district court adequately addressed Defendant’s concern, noting that “the testimony is unlikely to be so provocative as to divert the jury’s attention from the central sexual abuse allegation.” The court found that due to the temporal and causal proximity of the victim’s suicide attempt in relation to Defendant’s conduct, the evidence was probative and not unfairly prejudicial.Next, Defendant claimed that his Fifth and Sixth Amendment rights were violated when the district court impermissibly restricted his cross-examination of both the victim and her mother. However, ultimately, the jury acquitted Defendant of aggravated sexual abuse, but it found him guilty of abuse of an incapacitated victim. That the jury convicted him of only one count but not the other indicates that it was able to make an appropriate determination based on the evidence. Thus, the court affirmed the district court ruling. View "United States v. Paul Cavanaugh" on Justia Law

A confidential informant told police that Defendant was importing heroin from Chicago and selling it at an apartment. A detective applied for a search warrant for Defendant’s apartment to seize evidence of drug distribution. Defendant moved to suppress the evidence arguing that the warrant application incorrectly stated he was listed on the utility bills—one of the seven facts the detective used in his affidavit for a search warrant.Defendant argues that the good-faith exception does not apply because the affidavit in support of the warrant was so lacking in “indicia of probable cause to search for evidence of drug trafficking” at Defendant’s apartment that the existence of probable cause was entirely unreasonable. The court disagreed, reasoning that the detective had had an objectively reasonable belief in the existence of probable cause, and the affidavit contained sufficient indicia of probable cause, thus the good-faith exception applies. There is no evidence the detective acted in bad faith, and the issuing judge found that the affidavit provided a substantial basis to find probable cause to search for evidence. Further, information known to the detective reinforces the objective reasonableness of his belief in probable cause.Defendant counters that there was not a sufficient nexus between his drug trafficking and this apartment. However, the good-faith exception applies even if there is no direct nexus between a defendant’s continuous course of drug trafficking and his residence. As a result, the court affirmed the district court’s ruling. View "United States v. Roy Norey" on Justia Law

Defendant moved to suppress evidence obtained after police stopped Defendant upon suspicion of criminal activity. He later pled guilty and appealed the district court’s denial of his first motion to suppress, arguing that officers violated his Fourth Amendment rights by conducting a Terry stop without reasonable suspicion and by arresting him without probable cause.The court found that the officer and a particularized and objective basis for suspecting Defendant of wrongdoing, which provided the officer with reasonable suspicion to conduct a Terry stop. The court reasoned that the officer stopped Defendant at the direction of a detective who was investigating Defendant for drug-related crimes and as a person of interest in a homicide investigation. Defendant argues his past convictions and his involvement in a suspected drug deal two months earlier were “stale” and thus could not provide reasonable suspicion of ongoing criminal activity. However, the court found that the argument is unpersuasive because it fails to take into consideration the totality of the circumstances. Thus, the district court correctly held that the officer had reasonable suspicion to stop Defendant.Defendant further argues that the Terry stop became an arrest when the officers drew their weapons and handcuffed Defendant. Defendant claims this purported arrest was unlawful because the officers lacked probable cause. The court found that the officers’ protective actions here did not turn the stop into an arrest. View "United States v. Andre Johnson" on Justia Law

Prison corrections officers suspected that Defendant’s family had given him contraband. A strip search did not reveal contraband, but surveillance footage showed Defendant taking bundles out of his shoes and giving them to another inmate. Defendant was charged with three counts of possessing a prohibited object in prison.Defendant claims that excluding his sole witness, a Bureau of Prisons (“BOP”) employee, violated his Fifth and Sixth Amendment right to put on a complete defense. Defendant argues that the witness would testify as to his decision not to discipline Defendant. The court held that under Rule 403, the testimony is inadmissible. Whatever probative value the testimony might have is substantially outweighed by the danger that the testimony would be unfairly prejudicial.Defendant argues that the government did not lay the necessary foundation because there was no testimony that the shoes presented at trial were in the same condition as the day of the offense. The court found Defendant didn’t present evidence to rebut the presumption that evidence is presumed unchanged unless there is “a showing of bad faith, ill will, or proof that the evidence has been tampered with.”The court found that the jury instruction was proper because an inmate need not know specifically what prohibited item he has, so long as he knows that he possesses a prohibited object. Finally, Defendant’s evidentiary insufficiency argument fails because a reasonable jury could weigh this evidence and infer that he knew the items were prohibited. Thus, the court affirmed Defendant's convictions. View "United States v. Isiah Dozier" on Justia Law

Plaintiff arrived at Becker County Jail in Minnesota with a number of physical ailments, two weeks later he was taken to the hospital and subsequently diagnosed with acute myeloid leukemia. Plaintiff filed an action against Becker County Jail (“BCJ”) and its personnel, claiming deliberate indifference to his medical needs, failure to provide adequate training to corrections officers, and negligence. The district court held that Defendants were entitled to qualified immunity. Plaintiff filed an amended complaint under 42 U.S.C. Sec. 1983, alleging Defendants violated his rights under the Eighth and Fourteenth Amendments and claims under Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978).On appeal, the court reasoned that qualified immunity “shields government officials from liability when their conduct does not violate clearly established constitutional rights of which a reasonable person would have known.” The court found no violation of the Eighth or the Fourteenth Amendments because the undisputed facts do not provide sufficient proof that the defendants acted with deliberate indifference to Plaintiff’s medical needs nor do they show intentional denial or delay in access to medical care. The court reasoned that Plaintiff gave mixed signals as to the severity of his pain. Because medical professionals failed to grasp the seriousness of his condition, prison staff without medical training could not have been expected to do so. Further, because the individual Defendants are entitled to official immunity, Becker County is entitled to the same immunity. View "Kyle Rusness v. Becker County, Minnesota" on Justia Law

Plaintiff alleges that while he was detained at a detention center, officers subjected him to severe racial harassment, including the use of racial epithets, multiple times per day. He filed several internal grievances, but each was rejected. Plaintiff alleges the grievances were rejected because of his race. Plaintiff challenges the district court’s grant of summary judgment to Defendants. He also argues that the court should have construed his pleadings to include claims for retaliation and violations of the Minnesota Human Rights Act.Plaintiff argues that his summary judgment evidence and other evidence available in the record was sufficient to establish a genuine dispute of material fact. Plaintiff identifies three “buckets” of relevant evidence: (1) his counter-affidavits; (2) the internal grievance forms filed with the adult detention center; and (3) other non-summary judgment evidence available in the record.The court found that the evidence does not raise a genuine dispute that either officer was personally involved in racial harassment or discrimination at the detention center. Plaintiff's statement fails to identify any direct or circumstantial evidence that would demonstrate the denial was racially motivated. Further, Plaintiff failed to obtain sworn testimony or documentary evidence asserting specific facts to help prove his claim. The court held that Plaintiff’s summary judgment evidence is insufficient to establish a genuine dispute of material fact that Defendants were personally involved in racial discrimination or harassment. Thus, Plaintiff cannot demonstrate that either officer’s conduct violated his Fourteenth Amendment rights, and both are entitled to qualified immunity View "Wilbert Glover v. Matt Bostrom" on Justia Law

Officers conducted a traffic stop of a car in which the defendant was the passenger. The officers stated they were concerned the defendant was carrying something, so they handcuffed him. Defendant denied carrying anything but told officers they could check, at which point they found a stun gun and a lighter.A federal grand jury indicted the defendant on three counts, and he moved to suppress the evidence officers discovered during the search. He then pled guilty to the charges. Defendant presented mitigation evidence and asked the district court to impose the minimum sentence; however, they sentenced him to 211 months of imprisonment.Defendant argued that the officers lacked reasonable suspicion, the officers placed him under de factor arrest without probable cause, and the district court gave too much weight to aggravating factors when sentencing him. First, the circuit court concluded that the totality of the circumstances justified the officer’s search. Next, the circuit court found that the officers’ reasonable belief that the defendant was carrying weapons allowed them to handcuff him without resulting in a de facto arrest. Finally, the district court did not abuse its discretion by the sentencing defendant at the bottom of the guidelines range.. View "United States v. Tanner Halverson-Weese" on Justia Law