Justia Civil Rights Opinion Summaries

A jury convicted Defendant of eight counts of production of child pornography, two counts of attempted production of child pornography, and two counts of possession of child pornography. The district court sentenced Defendant to 3,480 months imprisonment and a lifetime of supervised release. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err in (1) denying Defendant's motion to suppress, as the evidence was not obtained in violation of the Fourth Amendment and the Miranda rule; (2) denying Defendant's motion for a bill of particulars; (3) admitting opinion testimony from a lay witness; (4) instructing the jury on the burden of proof; and (5) determining Defendant's sentence.

Kathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees.

Appellant appealed the district court's grant of summary judgment in favor of her employer, G4S Youth Services, LLC, and her supervisor, Todd Speight (Appellees), on Appellant's claims that they terminated her employment based on her race, age, and use of family medical leave. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant did not create a genuine issue of material fact as to whether G4S's legitimate, non-discriminatory reason for terminating her employment was merely a pretext for intentional race of age discrimination, the district court did not err in granting summary judgment in favor of Appellees on Appellant's race and age discrimination claims; and (2) because Appellant failed to raise a genuine issue of fact as to whether G4S retaliated against her for exercising her FMLA rights, the district court did not err in granting summary judgment on Appellant's Family and Medical Leave Act claims.

Before the Eighth Circuit Court of Appeals was Defendant's second federal habeas petition. Defendant was convicted of vehicular homicide and vehicular battery by a South Dakota jury and was sentenced to twenty-five years imprisonment. Defendant claimed that his trial counsel was ineffective for not calling two exculpatory witnesses and that previously undiscoverable evidence showed that he was not the driver of the car involved in the accident. The district court granted Defendant a writ of habeas corpus. The Eighth Circuit reversed, holding that Defendant had not met the Antiterrorism and Effective Death Penalty Act of 1996's requirements to bring his successive petition. Remanded.

Appellant brought a civil rights action under 42 U.S.C. 1983 against two deputy sheriffs in Benton County, Arkansas, alleging that they unlawfully entered his home, detained him, employed excessive force against him, and denied him emergency medical care. Appellant also asserted a failure-to-train claim against the County and its sheriff. The district court granted summary judgment for the defendants, ruling that Carpenter had not presented sufficient evidence to prove a constitutional violation, and that the defendants were thus entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly dismissed Appellant's claim alleging an unreasonable search under the Fourth Amendment; (2) there was probable cause to arrest Appellant; (3) the deputies were entitled to qualified immunity against Appellant's excessive force claim; (4) there was insufficient evidence that Appellant's need for medical treatment was so obvious that the deputies exhibited deliberate indifference by taking Appellant to jail; and (5) the district court correctly dismissed Appellant's failure to train claim against the defendants.

Defendant was convicted of being a felon in possession of a firearm. The district court sentenced Defendant to 327 months' imprisonment. Defendant appealed, contending that evidence of the firearm should have been suppressed, that the evidence was insufficient to sustain his conviction, and that his sentence was excessive. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Defendant's motion to suppress evidence; (2) there was clearly sufficient evidence in the record to support the verdict; and (3) there was no merit to Defendant's arguments that the district court erred in imposing sentence.

Defendant pleaded guilty, pursuant to a plea agreement, to conspiracy to manufacture over 500 grams of methamphetamine mixture and fifty grams of methamphetamine. The district court initially sentenced Defendant to 240 months' imprisonment. Thereafter, the government filed a Fed. R. Crim. P. 35(b) motion, recommending a ten-percent reduction in Defendant's sentence. The district court held a telephonic hearing on the motion in which the government and Defendant's counsel participated, but Defendant did not participate. The court granted the ten-percent reduction in Defendant's sentence. Defendant appealed, arguing that he was denied the right to participate in the hearing in violation of his plea agreement. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court's failure to permit Defendant's participation in the Rule 35(b) hearing was plain error, but (2) the error did not affect Defendant's substantial rights.

Defendant pled guilty to being a felon in possession of a firearm and ammunition. The court sentenced him to the statutory minimum of 180 months' imprisonment. Defendant subsequently moved to set aside his conviction and sentence under 28 U.S.C. 2255, contending that his counsel was ineffective for (1) failing to file a motion to suppress evidence, (2) failing to file an appeal that Defendant alleged he requested, and (3) failing to obtain a mental evaluation. The district court denied the motion. The Eighth Circuit Court of Appeals affirmed, holding (1) any motion to suppress evidence would not have succeeded, and thus counsel was not ineffective for failing to file a motion to suppress; (2) the district court did not err in finding no credible evidence that Defendant requested an appeal; and (3) the district court correctly ruled that Defendant's attorney had not been ineffective because a motion to obtain a mental evaluation would not have affected the outcome of the trial.

Appellant brought this action under 42 U.S.C. 1983 against the Kansas City Board of Police Commissioners and its members, the chief of police, and certain police officers, alleging constitutional violations under the Fourth and Fourteenth Amendments of the Constitution. The district court dismissed the action for failure to exhaust administrative remedies, reasoning Title VII of the Civil Rights Act of 1964 provided the exclusive remedy for Appellant's claims and Appellant could not circumvent the Act's procedural requirements by solely pleading constitutional violations under section 1983. The Eighth Circuit Court of Appeals reversed, holding that to the extent that Appellant's complaint asserted the violation of rights secured by the Constitution and committed by persons acting under color of state law, the district court erred in dismissing her section 1983 action for failure to comply with Title VII's procedural requirements.

After a jury trial, Defendant was convicted on two counts of distribution of cocaine base, one count of possession of cocaine base with intent to distribute, and one count of possession of marijuana with intent to distribute. The district court sentenced Defendant to 300 months' imprisonment. The Eighth Circuit Court of Appeals affirmed Defendant's convictions, holding (1) the district court did not err by instructing the jury with respect to inferring an intent to distribute; (2) the admission into evidence of a wage record from the Iowa Workforce Development Agency did not violate the Confrontation Clause of the Sixth Amendment; and (3) the evidence was sufficient to support the guilty verdicts.