Justia Constitutional Law Opinion Summaries

A Nebraska jury convicted Mayfield, a California resident, of conspiracy to distribute and possess with intent to distribute methamphetamine (21 U.S.C. 841(a)(1), 841(b)(1)(A), and 846). The district court imposed the mandatory minimum sentence of 240 months’ imprisonment. At trial, three cooperating witnesses testified that their methamphetamine supplier, Love, purchased meth from the “Cali Boys,” brothers “Rob” Mayfield and Anthony “Duga” Harris. The Eighth Circuit affirmed, rejecting an argument that out-of-court statements Love made to the cooperators, and recorded calls that Harris made from jail to “Rob” at a California telephone number, were inadmissible hearsay. The statements were made during the course and in furtherance of the conspiracy; such statements are generally non-testimonial, and their admission does not violate the Confrontation Clause The court found the evidence sufficient to convict and upheld the imposition of an obstruction-of-justice sentencing enhancement based on defendant's act of making a throat-slashing gesture to testifying co-conspirator. View "United States v. Mayfield" on Justia Law

An unpaid lobbyist unsuccessfully sued to enjoin enforcement of Mo. Rev. Stat. Sections 105.470 and 105.473 which require lobbyists to register and report certain activities. The Eighth Circuit affirmed. The district court properly analyzed the claims under an intermediate or exacting level of scrutiny, rather than strict scrutiny, citing the “Citizens United” decision. Missouri has a sufficiently important governmental interest in government transparency to require both paid and unpaid lobbyists to register and report and the registration requirements in Sec. 105.473 are substantially related to Missouri's interest in transparency. The burden placed on the plaintiff is not disproportionate to Missouri's interest and the court did not err in finding the statute was constitutional as applied to the plaintiff. The court rejected a facial challenge to the word "designated" in the definition of a legislative lobbyist. The term is clearly defined, and the statute uses the word within its plain meaning; “people of ordinary intelligence” would have a “reasonable opportunity to understand” what “designated” means in the context of the statute. View "Calzone v. Hagan" on Justia Law

Henderson, a 19-year-old black man, was attending a party at a Woodbury, Minnesota Red Roof Inn. Without warning, another young black male, Ballinger, pulled a gun, robbed the other guests, including Mark, and held them hostage. A woman called 911 and then hid her phone. Though the caller was unable to speak with the operator, the operator kept the line open and listened; the operator discerned an apparent confrontation between someone with a gun and another person with a knife. The person with the gun (Ballinger) demanded that the person with the knife (Henderson) give it up. The dispatcher alerted police. During the response, which involved Henderson trying to escape the hotel room while Ballinger fired shots, Henderson was shot by three officers who fired 17 rounds while he was lying on the ground. Henderson died. The district court rejected, on summary judgment, claims by his estate under 42 U.S.C. 1983. The Eighth Circuit reversed. The resolution of the conflicting testimony between one officer's more or less contemporaneous statement to investigators and all of the officers' subsequent unified deposition testimony should be left to a jury; the district court erred in finding the defendants entitled to qualified immunity. View "Henderson v. City of Woodbury" on Justia Law

In 2001, Nelson pled guilty to the kidnapping and unlawful interstate transportation of Pamela for the purpose of sexual abuse which resulted in her death. The government dropped a charge traveling across state lines with the intent to engage in a sex act with a female under the age of 12 which resulted in death. Days later, Nelson attempted suicide by ingesting prescription medicine. The penalty phase jury returned a death penalty verdict. The court allowed Nelson to address the court. Nelson, showing no remorse, blistered the court and the victim’s family with a profanity-laden tirade. The court imposed the death sentence. The Eighth Circuit affirmed; the Supreme Court denied certiorari. The Eighth Circuit affirmed the rejection of Nelson’s 28 U.S.C. 2255 motion. The jury heard substantial mitigating evidence and there was no reasonable probability that its death sentence verdict would have been different if the evidence produced at the habeas evidentiary hearing had been introduced during the penalty phase, so the district court did not err in denying Nelson's ineffective assistance of counsel claims concerning failure to conduct an adequate mitigation investigation, failure to adequately investigate his mental health and failure to advise Nelson to decline to submit to a mental health exam by a government examiner. View "Nelson v. United States" on Justia Law

Missouri inmate Barr filed suit under 42 U.S.C. 1983 alleging that state-contracted health care providers violated the Eighth Amendment when they stopped administering his multiple sclerosis medication. Barr’s medical record indicated that he was being followed “for high suspicion of multiple sclerosis” but had discontinued taking Avonex “on his own due to undesirable side effects.” The Eighth Circuit affirmed summary judgment in favor of the Defendants. While inmates have a right to adequate medical care, they have no right to receive a particular or requested course of treatment. Defendants’ decision to halt Barr’s Avonex injections did not rise to a level akin to criminal recklessness and was probably not even negligent. Even if Barr did not refuse his injections, Defendants had good reason to end them. Three different health care providers wrote in Barr’s medical record that he had complained to them about side effects; it was well within Defendants’ independent medical judgment to stop administering Avonex. Barr does not allege that any harm occurred after the injections ended. After Barr’s injections were halted, Defendants continued to provide medical care—prescribing other medication, scheduling follow-ups, and requesting additional diagnostic tests. No rational trier of fact could find that Defendants were deliberately indifferent. View "Barr v. Pearson" on Justia Law

Phillips, who resided with Coleman, called 911, stating that Coleman had punched her and had a gun. North Little Rock Officer Crowder responded, finding Phillips outside the residence with facial injuries. Phillips opened the door. She and Crowder entered the residence, where Crowder confronted and arrested Coleman after a struggle that involved the use of a taser. Crowder found a large bag of white substance and a large amount of cash in Coleman's pockets, small baggies of white powder on the stairwell, and a handgun and another bag of cocaine in a loveseat near where Coleman was arrested. Additional officers responded and discovered firearms and drugs during a protective sweep of the residence and a warrant search the following day. At a hearing, Phillips contradicted Officer Crowder, denying stating that Coleman struck her and was armed, and denying opening the door and escorting Crowder inside. The Eighth Circuit affirmed the denial of a motion to suppress; Coleman’s convictions for possession with intent to distribute controlled substances and conspiracy to possess with intent to distribute, 21 U.S.C. 841(a)(1), (b)(1)(A), 846, being a felon in possession of a firearm, 18 U.S.C. 922(g)(1), and possession of a firearm in furtherance of drug trafficking, 18 U.S.C. 924(c)(1)(A), and his 161-month sentence. Phillips’s testimony established that she possessed common authority over the premises. The court explicitly credited Crowder’s testimony as more accurate. View "United States v. Coleman" on Justia Law

The Minnesota Bureau of Criminal Apprehension obtained a state court warrant to place a GPS tracker on Lopez-Zuniga's car for 60 days. The officer provided an affidavit detailing a drug investigation into Garcia-Jimenez, noting several controlled drug transactions involving Garcia-Jimenez; sometime before a controlled drug transaction at the apartment complex where Garcia-Jimenez was believed to live, the officer saw someone in Lopez-Zuniga's car "drop off an individual who resembled Garcia-Jimenez." Another agent later observed Lopez-Zuniga and Garcia-Jimenez get into the same car at the apartment complex and drive to a restaurant. After 60 days, the agent obtained a second warrant, citing the same information plus the results of tracking the car and of a pen register on Garcia-Jimenez's phone, showing that he and Lopez-Zuniga had 154 "contacts" over about two months. Charged with conspiring to distribute methamphetamine, 21 U.S.C. 841(a)(1), 841(b)(1)(A), and 846, Lopez-Zuniga successfully moved to suppress evidence obtained from the tracking devices. The Eighth Circuit affirmed the suppression of evidence obtained from the first two warrants. The first warrant application was so lacking in indicia of probable cause that belief in its existence would have been entirely unreasonable, and the search is not saved by the good-faith exception. The second warrant application was still insufficient. The court erred in suppressing the fruits of the third and fourth warrant applications, which were supported by information regarding controlled sales to a confidential informant. View "United States v. Lopez-Zuniga" on Justia Law

Escobar, Jackson, and Cruz were convicted of federal crimes related to a methamphetamine distribution operation; Rojas-Andrade and Garcia pleaded guilty. The Eighth Circuit affirmed the convictions and their sentences of 137 to 330 months. Evidence seized during a search made pursuant to an anticipatory search warrant was admissible under the good-faith exception, as the totality of the circumstances showed the officers' reliance on the warrant was objectively reasonable. There was no error in the denial of a motion to suppress wiretap evidence; the wiretap affidavit established that normal investigative techniques had not been successful in exposing the full extent of the drug conspiracy. The district court properly admitted recorded out-of-court statements of co-conspirators and properly imposed a two-level enhancement against Escobar for possession of a dangerous weapon in connection with a drug offense under U.S.S.G. 2D1.1(b)(1). Rojas-Andrade's motion to withdraw his guilty plea was properly denied; a misunderstanding of how the guidelines would apply is not a fair and just reason to withdraw a plea. There was no error in denying Jackson's motion to sever conspiracy and possession counts and no error in admitting evidence of Jackson's prior drug convictions as they were not too remote in time and were relevant under Rule 404(b). Garcia did not object to the drug quantity calculation in his PSR or at his sentencing and cannot challenge the quantity on appeal.. View "United States v. Escobar" on Justia Law

Plaintiff filed suit alleging that a county deputy was deliberately indifferent to Jeffry Alan Barton's serious medical needs and that the county jail administrator failed to adequately train or supervise the deputy. Plaintiff also alleged that the county did not adequately train its detention facility workers and that its policies failed to ensure that detainees received adequate medical care.The Eighth Circuit affirmed the district court's denial of qualified immunity to the deputy where a jury could find that Barton was experiencing a medical need so obvious that a layperson would recognize the need for prompt medical attention, the deputy did not perform the healthcare screening the jail policies required, and it was clearly established at the time that booking Barton into jail would constitute deliberate indifference. The court reversed the denial of qualified immunity to the administrator and held that the administrator did not know that the deputy was inadequately trained or supervised. Finally, the court dismissed the county's appeal for lack of jurisdiction. View "Barton v. Ledbetter" on Justia Law

The EEOC filed suit alleging that North Memorial violated 42 U.S.C. 2000e-3(a), by unlawfully retaliating against an employee. The district court granted summary judgment for North Memorial and dismissed the claim, concluding that North Memorial did not violate section 2000e-3(a) because it did not discriminate against the employee.The Eighth Circuit affirmed and held that the EEOC failed to establish a prima facie case of opposition-clause unlawful retaliation because merely requesting a religious accommodation was not the same as opposing the allegedly unlawful denial of a religious accommodation. The court reasoned that, when an employee or applicant requested a religious accommodation, and the request was denied by an employer such as North Memorial that accommodated reasonable requests that did not cause undue hardship, there was no basis for an opposition-clause retaliation claim under Sec. 2000e-3(a). The court held that the employee or applicant's exclusive Title VII remedy was an unlawful disparate treatment or disparate impact claim under section 2000e-2(a)(1). View "EEOC v. North Memorial Health Care" on Justia Law