Justia Civil Rights Opinion Summaries

Defendant pleaded guilty to distributing methamphetamine and being a felon in possession of a firearm. The district court sentenced Defendant to 151 months' imprisonment. Defendant appealed his sentence, raising as his sole issue the propriety of the district court's enhancement of his sentence for obstructing justice. The district court found that while in prison, after pleading guilty, Defendant engaged in a conspiracy to murder a confidential informant in this case. The Eighth Circuit Court of Appeals reversed the sentence, holding that the sentencing enhancement did not apply because there was no showing the plot was intended to obstruct justice on the instant offense of conviction.

Defendant pleaded guilty to one count of interstate transportation of a minor with intent to engage in criminal sexual activity. The district court sentenced Defendant to 360 months' imprisonment, applying an upward variance of thirty-three months from the high end of the Guidelines range. Defendant appealed, arguing that his sentence was substantively unreasonable based on the factors in 18 U.S.C. 3553(a). The Eighth Circuit Court of Appeals affirmed, holding (1) given the record, the district court did not impose a sentence greater than necessary to comply with the purposes of section 3553(a)(2); and (2) under the circumstances, the district court gave sufficient weight to mitigating factors.

A jury convicted Defendant of distribution of heroin and distribution of heroin resulting in death. The district court sentenced Defendant to 240 months on each count, concurrently. Defendant appealed, arguing the court erred by admitting hearsay testimony and denying his motions for judgment of acquittal and a new trial. The Eighth District Court of Appeals affirmed, holding that the district court did not err (1) by rejecting Defendant's proximate cause instructions or by using "contributing cause" language to define the causation element; (2) in denying Defendant's motion for a new trial because of remarks made by the prosecutor, where the remarks were proper; (3) in denying Defendant's motion for a judgment of acquittal, as the evidence was sufficient to sustain the convictions; and (4) in admitting certain testimony, because even if the district court erred in admitting the testimony, the error was harmless.

A North Dakota jury convicted Defendant of manufacturing methamphetamine, possessing methamphetamine, and possessing drug paraphernalia, all in violation of state law. After the North Dakota Supreme Court affirmed Defendant's conviction and the denial of his motion for state postconviction relief, Defendant filed a petition for writ of habeas corpus, arguing that the state court erred in requiring him to prove that his counsel's error was prejudicial under Strickland v. Washington. At issue on appeal was whether the wearing of prison clothing was necessarily prejudicial under United States v. Cronic, and therefore, a specific showing of prejudice was not required. The district court denied the petition. The Eighth Circuit Court of Appeals affirmed, holding that based on the record before the state courts, the decision of the Supreme Court was not an unreasonable application of clearly established law.

Plaintiff brought suit under 42 U.S.C. 1983 against the County of Dakota, Nebraska, and former county official Rodney Herron. Plaintiff alleged defendants committed gender discrimination in violation of her Fourteenth Amendment rights. Herron appealed the district court's denial of summary judgment, asserting that he was entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) Plaintiff met her burden to show that Herron violated her Fourteenth Amendment right to be free from gender discrimination; (2) the right Herron violated was clearly established; and (3) because Plaintiff satisfied both prongs of the qualified-immunity analysis, the district court correctly found that Herron was not entitled to qualified immunity.

Toni Duncan sued her former employer, Dakota County, Nebraska, under 42 U.S.C. 1983 for hostile-work-environment sexual harassment and constructive discharge in violation of the Equal Protection Clause of the Fourteenth Amendment. Duncan also sued Sheriff James Wagner and her supervisor, Chief Deputy Rodney Herron, in their individual capacities. The district court (1) granted summary judgment to Wagner; and (2) denied the motions for summary judgment by the County and Herron on the basis of qualified immunity. The Eighth Circuit Court of Appeals reversed in part, holding that Herron was entitled to qualified immunity on Duncan's claim, as Herron did not violate Duncan's right to equal protection. Remanded.

Plaintiff sued her former employer, Dakota County, Nebraska under 42 U.S.C. 1983 and 1985. She also sued a sheriff, chief deputy, and sergeant, claiming the chief deputy and sheriff created or fostered a sexually hostile work environment, and the chief deputy and sergeant conspired to deprive her of her civil rights. The defendants moved for summary judgment based on qualified immunity, which the district court denied. The Eighth Circuit Court of Appeals (1) affirmed the denial of summary judgment to the chief deputy, holding that Plaintiff sufficiently showed the five elements of a hostile-work-environment sexual harassment claim and that the right the chief deputy violated was clearly established; (2) reversed the denial of summary judgment as to the sheriff and sergeant on Plaintiff's claim that they conspired to violate her constitutional rights, as Plaintiff failed to demonstrate the existence of a conspiracy; and (3) reversed the denial of summary judgment as to the sheriff on Plaintiff's sexually hostile work environment claim, as the sheriff's conduct was not sufficiently severe to create a sexually hostile work environment.

A jury convicted Appellant of four counts of deprivation of rights and two counts of making false statements. The district court sentenced Appellant to 120 months' imprisonment on the deprivation of rights counts and sixty months' imprisonment on each of the false statements counts, with all terms to be served concurrently. In imposing this sentence, the court applied an enhancement for physical restraint under U.S.S.G. 3A1.3 and an enhancement for aggravated assault resulting in serious bodily injury under U.S.S.G. 2A2.2. On appeal, Appellant challenged the application of the two enhancements. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant moved his victims to an enclosed area to be assaulted, the district court did not err in applying the physical restraint enhancement; and (2) because Appellant had the requisite intent to assault his victims, the district court did not err in applying the enhancement for a crime resulting in serious bodily injury.

A jury found Appellant guilty of being a felon in possession of a firearm. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err by (1) permitting Appellant to represent himself pro se, as Appellant's waiver to counsel was knowing and voluntary and the district court adequately warned him of the dangers of self-representation; (2) denying Appellant's motion to suppress evidence recovered from a warrantless search of his vehicle; and (3) denying Appellant's motion for judgment of acquittal, as the evidence was sufficient to prove that Appellant knowingly possessed the weapons discovered in the truck he was driving.

Defendant pleaded guilty to being a felon in possession of a firearm. At sentencing, the district court determined Defendant had four prior convictions that qualified as violent felonies, and thus he was subject to the enhanced sentencing provisions of the Armed Career Criminal Act (ACCA). Defendant appealed the enhanced ACCA sentence. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly used a modified categorical approach in looking to the charging documents, plea agreement, and change of plea documents; (2) the charging documents contained sufficient information to show the convictions qualified as violent felonies; and (3) thus, because Defendant committed at least three prior violent felonies, the district court properly sentenced him as an armed career criminal.