Justia Civil Rights Opinion Summaries

Antoine Porter was charged with being a felon in possession of a firearm. Porter was convicted as charged after a jury trial and was sentenced to thirty-three months imprisonment. Porter appealed his conviction, arguing the district court erred in denying his motion for judgment of acquittal based on insufficient evidence and erred in overruling Porter's objection to statements made by the Government's counsel during closing arguments. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Porter's motion for acquittal, as there was ample evidence to support the jury's conviction; and (2) the district court did not err in overruling Porter's objection to statements made by the Government's counsel during closing arguments.

A jury convicted Appellants, Ferris Lee, Maurice Forest, and Marcus Royston, of various drug-related offenses. The district court sentenced Lee to 540 months imprisonment, Forest to a statutory mandatory minimum of 120 months imprisonment, and Royston to a statutory mandatory minimum life sentence. On appeal, Appellants raised numerous challenges to their convictions, and Forest and Royston challenged their sentences. The Eighth Circuit Court of Appeals (1) affirmed the district court's judgment and sentence as to Lee; and (2) affirmed Forest's and Royston's convictions, but vacated their sentences, holding that the Fair Sentencing Act (FSA) was applicable in these cases, and therefore, the revised statutory penalties should have applied to their sentences. Remanded for resentencing pursuant to the FSA.

Defendant appealed the district court's denial of his motion to suppress drugs and weapons found in an apartment he entered after fleeing from police during a buy/bust operation. Defendant entered a conditional guilty plea to possession with intent to distribute five grams or more of cocaine base and possession of a firearm in furtherance of a drug trafficking crime. Defendant subsequently appealed the suppression ruling, arguing that the actions by law enforcement officers during the buy/bust operation violated his Fourth Amendment rights and tainted the search warrant affidavit used to seize the drugs and weapons from the apartment. The Eighth Circuit Court of Appeals affirmed, holding (1) the search warrant was properly issued; (2) the officers' entry into the dwelling was lawful; and (3) the officers lawfully searched the dwelling.

James Schottel brought this action under 42 U.S.C. 1983 alleging a state court judge, Judge Patrick Young, violated his constitutional rights by conditioning the grant of his motion to withdraw as counsel on the repayment of a $1,600 retainer to the clients. The district court dismissed the action for lack of subject matter jurisdiction pursuant to the Rooker-Feldman doctrine. The Eighth Circuit Court of Appeals affirmed, holding that because Judge Young's actions were judicial in nature and were not taken in the complete absence of all jurisdiction, Judge Young was entitled to judicial immunity for the claims brought against him in this section 1983 action.

Mischelle Richter appealed (1) the district court's order dismissing her retaliation claims under Title VII and the Missouri Human Rights Act for failure to exhaust administrative remedies, and (2) the dismissal of her wrongful discharge claim under Missouri law for failure to state a claim upon which relief may be granted. The Eighth Circuit Court of Appeals (1) affirmed the district court's dismissal of the retaliation claims, holding that Richter did not properly exhaust her retaliation claims; but (2) reversed and remanded on the state-law wrongful discharge claim, holding that Richter alleged sufficient facts to state a wrongful discharge claim under Missouri law.

Robert Gray and Teresa Tremusini committed various crimes related to schemes to defraud the United States Postal Service (USPS). Gray, who pled guilty, appealed certain sentencing evidentiary rulings and the district court's loss calculation with respect to his sentence. Tremusini was convicted following a jury trial and appealed the district court's (1) admission of particular out-of-court statements made by Gray, (2) refusal to give Tremusini's requested jury instructions, and (3) denial of her motion for a judgment of acquittal. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err in (1) determining the loss calculation with respect to Gray, as the calculation reflected the "fair market value of services provided to Gray less the amount actually paid for those services"; (2) admitting the out-of-court statements made by Gray; (3) declining to give a model instruction requested by Tremusini; and (4) denying Tremusini's motions for acquittal.

Defendant appealed his conviction for theft of government funds, contending that the district court abused its discretion by admitting evidence at trial of his prior applications for Social Security disability benefits. Defendant also argued for the first time on appeal that venue was not proper in the Southern District of Iowa. The Eighth Circuit Court of Appeals affirmed Defendant's conviction, holding (1) the district court did not abuse its discretion in admitting evidence of Defendant's prior applications, as the evidence was relevant and the level of unfair prejudice did not substantially outweigh the probative value of the evidence; and (2) there was no plain error in prosecuting this case in the Southern District of Iowa.

A jury convicted Defendant of possession with intent to distribute as well as distribution of 500 grams or more of methamphetamine. The Eighth Circuit Court of Appeals affirmed, holding that Johnson was not entitled to a new trial, as (1) the basis of Defendant's objection to a juror's bias was clearly known during voir dire, and Defendant's counsel's failure to object constituted a waiver of Defendant's right to challenge the seating of the juror on direct appeal; (2) the government presented evidence sufficient to prove Defendant distributed 500 grams or more of methamphetamine; (3) the government did not violate Defendant's Sixth Amendment Confrontation Clause rights by failing to call as witnesses the forensic lab technician who checked the drugs found at Defendant's residence into and out of the state crime lab, and the lab supervisor who certified the lab report as a true copy of the original.

Robert Gray and Teresa Tremusini committed various crimes related to schemes to defraud the United States Postal Service (USPS). Gray, who pled guilty, appealed certain sentencing evidentiary rulings and the district court's loss calculation with respect to his sentence. Tremusini was convicted following a jury trial and appealed the district court's (1) admission of particular out-of-court statements made by Gray, (2) refusal to give Tremusini's requested jury instructions, and (3) denial of her motion for a judgment of acquittal. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err in (1) determining the loss calculation with respect to Gray, as the calculation reflected the "fair market value of services provided to Gray less the amount actually paid for those services"; (2) admitting the out-of-court statements made by Gray; (3) declining to give a model instruction requested by Tremusini; and (4) denying Tremusini's motions for acquittal.

A jury convicted Defendant of possession of child pornography, and the district court sentenced Defendant to 120 months' imprisonment. The Eighth Circuit Court of Appeals affirmed Defendant's conviction, holding that the district court did not err in (1) admitting evidence of prior acts to prove knowledge or intent; (2) permitting the government to question Defendant about an incident in which he masturbated outside his home, and in introducing a document Defendant wrote that discussed child sex; and (3) allowing the government to introduce Defendant's computers, hard drives, and computer disks into evidence, as the government established a proper chain of custody.