Justia Civil Rights Opinion Summaries

Plaintiff was terminated from his employment with the City of Victoria, Minnesota. Plaintiff bought an action against his former employer, alleging violations of the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), the Due Process Clause of the Fourteenth Amendment, and state law. The district court granted summary judgment in favor of the City. The Eighth District affirmed, holding (1) summary judgment on Plaintiff's ADA claim was proper; (2) Plaintiff's termination did not violate the ADEA, as Plaintiff was not qualified for the position because of his disability; and (3) Plaintiff was not deprived of property without due process of law by being discharged without a formal hearing.

Torrance Bunch and Fernando Sanchez-Garcia were each convicted by a jury of conspiracy to possess with intent to distribute 500 grams or more of methamphetamine. The jury also found Bunch guilty of three counts of distribution of five grams or more of methamphetamine. On appeal, Bunch alleged that he was denied his Sixth Amendment right to counsel, and Sanchez-Garcia contended that the district court erred in denying his motion for a mistrial and committed other trial-related errors. The Eighth Circuit Court of Appeals affirmed, holding (1) by repeatedly rejecting all options except self-representation, after having been warned of the consequences, Bunch necessarily chose self-representation, and thus, the district court's ruling did not violate Bunch's rights under the Sixth Amendment; (2) the prosecutor's comments during closing argument were not improper, and thus Sanchez-Garcia was not entitled to a mistrial; (3) the district court did not commit plain error by proceeding with a joint trial; and (4) the district court did not abuse its discretion by admitting a recording of a telephone call into evidence.

Torrance Bunch and Fernando Sanchez-Garcia were each convicted by a jury of conspiracy to possess with intent to distribute 500 grams or more of methamphetamine. The jury also found Bunch guilty of three counts of distribution of five grams or more of methamphetamine. On appeal, Bunch alleged that he was denied his Sixth Amendment right to counsel, and Sanchez-Garcia contended that the district court erred in denying his motion for a mistrial and committed other trial-related errors. The Eighth Circuit Court of Appeals affirmed, holding (1) by repeatedly rejecting all options except self-representation, after having been warned of the consequences, Bunch necessarily chose self-representation, and thus, the district court's ruling did not violate Bunch's rights under the Sixth Amendment; (2) the prosecutor's comments during closing argument were not improper, and thus Sanchez-Garcia was not entitled to a mistrial; (3) the district court did not commit plain error by proceeding with a joint trial; and (4) the district court did not abuse its discretion by admitting a recording of a telephone call into evidence.

Defendant was found guilty of aiding and abetting the use and carrying of a firearm during a crime of violence and possession of a firearm by a convicted felon. Prior to trial, Defendant had also pled guilty to bank robbery. On appeal, Defendant alleged the prosecutorial misconduct during closing argument required reversal of his firearm convictions and a new trial on the merits. The Eighth Circuit Court of Appeals affirmed, holding (1) assuming a comment made by the prosecutor about Defendant's failure to testify was improper, it could not have reasonably affected the jury's verdict; and (2) there was no plain error in comments made by the prosecutor allegedly attacking the integrity of defense counsel.

Defendant was convicted for conspiring to obstruct an official proceeding and aiding and abetting evidence tampering. The Eighth District Court of Appeals affirmed, holding (1) the district court did not err either by joining Defendant's case with her husband's or by denying Defendant's motion to sever; (2) Defendant was not denied her Sixth Amendment right to an impartial jury; (3) an ex parte communication that occurred between the trial judge and the jury did not necessitate an evidentiary hearing to determine its propriety; and (4) the trial court did not err in denying Defendant's motion for a judgment of acquittal on the grounds of evidentiary insufficiency.

A jury convicted Defendant of conspiracy to distribute marijuana and conspiracy to commit money laundering. Defendant appealed, arguing that the jury instructions constructively amended Count II of the superceding indictment and that the district court plainly erred by trying her with her pro se codefendant. The Eighth Circuit Court of Appeals affirmed, holding (1) the jury instruction did not constructively amend the superseding indictment; and (2) the district court did not plainly err in failing to sever Defendant's trial, as Defendant did not suffer unfair prejudice by being tried with her pro se codefendant, and because Defendant could have anticipated the effects of her codefendant's pro se representation prior to trial and asked for a severance on that ground.

Defendant entered a plea of guilty to being a felon in possession of a firearm conditioned on his right to appeal the district court's denial of his motions to suppress evidence. On appeal, the Eighth Circuit Court of Appeals affirmed, holding (1) for purposes of Defendant's motion to suppress, the traffic stop was justified; (2) even if the initial duration of the detention was unlawful, the district court did not err by denying Defendant's motion to suppress the firearms; and (3) the plain view doctrine permitted seizure of the firearms discovered in the vehicle Defendant was driving even though the search warrant did not list them as items to be seized.

Defendant was arrested for possessing a firearm. Defendant moved to suppress the firearm obtained from the vehicle he was riding in, arguing (1) the officer lacked probable cause or reasonable suspicion to stop the vehicle; and (2) even if the officer was reasonably mistaken in believing there was a traffic violation, any reasonable suspicion should have vanished when the officer saw the vehicle's valid In Transit sticker. The district court denied the motion. The Eighth Circuit Court of Appeals affirmed, holding that the initial traffic stop and the officer's limited inquiry, which led to the search and Defendant's arrest, were constitutionally valid.

Appellant entered a conditional plea agreement and pled guilty to possession with intent to distribute 500 grams or more of a mixture or substance containing a detectable amount of cocaine. As allowed by his conditional guilty plea, Appellant challenged the district court's denial of his motion to suppress. The Eighth Circuit Court of Appeals affirmed, holding (1) there was probable cause to stop Appellant; (2) there was reasonable suspicion to detain Appellant in order to search his vehicle; (3) the law enforcement officer's questions did not amount to an unreasonable search; (4) the time spent waiting for a drug detection dog was not unreasonable; and (5) the search of Appellant's vehicle after he was placed in a custodial arrest did not exceed the proper scope of investigation.

Defendant was charged with being a felon in possession of a firearm after a pat-down by law enforcement officers revealed that Defendant was in possession of a firearm, drugs, and drug paraphernalia. The district court granted Defendant's motion to suppress, concluding that although this case "was a close call," the officers did not have reasonable suspicion as required for a pat-down search under Terry v. Ohio. The Eighth Circuit reversed the order granting the motion to suppressed, holding that the totality of the circumstances created an objectively reasonable suspicion that Defendant might be armed and dangerous, and thus the pat-down search was constitutionally permissible.