Justia Civil Rights Opinion Summaries

Defendant Vincente Carrasco Espinoza appealed his conviction for one count of conspiracy to distribute cocaine and methamphetamine and one count of possession with intent to distribute cocaine and methamphetamine. The Eighth Circuit Court of Appeals affirmed, holding (1) the evidence at trial was sufficient to convict Defendant on both counts; (2) the district court did not err in its evidentiary rulings challenged by Defendant on appeal; (3) the government did not engage in misconduct during closing arguments; and (4) the district court did not err in giving certain jury instructions and denying Defendant's proposed jury instructions.

A jury convicted Appellant of one count of conspiring to distribute methamphetamine and two counts of distributing methamphetamine. Defendant appealed his conviction. The Eighth Circuit Court of Appeals affirmed, holding the district court did not err by (1) requiring Defendant to disclose his firearms expert; (2) refusing to instruct the jury on Defendant's coercion defense; (3) refusing to instruct the jury on Defendant's defense theory; and (4) prohibiting Defendant's counsel from presenting his defense theory in closing arguments. Defendant's remaining argument, that the district court erred by prohibiting the firearms expert from testifying, was meritless, as the district court did not make a definitive ruling on the matter.

Appellant entered a conditional guilty plea to charges that he conspired to distribute at least five kilograms of cocaine and 100 kilograms of marijuana and possessed a firearm in furtherance of a drug trafficking crime. Appellant appealed district court orders denying his motions to suppress evidence and for a Franks hearing, and his request to plead guilty to the conspiracy charge without admitting drug quantities alleged in the indictment. The Eighth Circuit Court of Appeals affirmed, holding (1) the motion to suppress was properly denied; (2) the district court did not abuse its discretion in denying a Franks hearing; and (3) the district court properly denied Defendant's plea motion under United States v. Brown.

Plaintiff had active tuberculosis at the time he was admitted to the Ramsey County Correctional Facility to serve fifty-six days for fifth degree assault. Plaintiff's condition worsened, and he was transferred to a hospital emergency room two days before he was scheduled for release. Plaintiff brought this action under 42 U.S.C. 1983, claiming that nursing staff, jail administrators, and the county had been deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. The district court granted summary judgment on immunity grounds to the administrators and the county but denied summary judgment to five nurses. The Eighth Circuit Court of Appeals (1) reversed the denial of summary judgment to two of the nurses, as the evidence was insufficient to support a finding that these nurses deliberately disregarded a serious medical need; and (2) affirmed the denial of summary judgment to the remaining three nurses, as the evidence supported a finding that these nurses were deliberately indifferent to Plaintiff's serious medical need.

Dr. Lee Davis, an African-American cardiologist, obtained medical-staff privileges at Jefferson Regional Medical Center (JRMC). Later, JRMC's Board of Directors voted to revoke Davis's medical-staff privileges for poor quality of patient care, improper medical documentation, and unprofessional behavior. Davis filed the instant suit in federal district court, alleging, inter alia, race discrimination and retaliation, in violation of 42 U.S.C. 1981 and the Arkansas Civil Rights Act (ACRA), and conspiracy to interfere with his civil rights, in violation of 42 U.S.C. 1985(3). The district court granted summary judgment to Defendants, JRMC, its CEO, and several physicians (Defendants), and dismissed all of Davis's claims. The Eighth Circuit Court of Appeals affirmed, holding (1) because Davis failed to provide any evidence giving rise to an inference that Defendants racially discriminated against him, the district court did not err in granting summary judgment on Davis's race discrimination claims; (2) Davis failed to establish a prima facie case of retaliation under section 1981 and ACRA; and (3) the district court did not err in dismissing Davis's civil rights conspiracy claim pursuant to section 1985(3), as Davis failed to show any racial animus on the part of Defendants.

Appellant was convicted for being a felon in possession of a firearm and sentenced to 235 months' incarceration. Appellant appealed his conviction and sentence. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court properly denied the motion to suppress DNA evidence obtained after Appellant's arrest; (2) Appellant's waiver of the right to counsel was knowing, voluntary, and intelligent, and therefore, the trial court did not err in allowing Appellant to represent himself at trial; (3) the district court did not abuse its discretion in denying Appellant's motion for a mistrial; and (4) the district court committed no procedural error at sentencing.

Officer John Cook fatally shot David Morgan after responding to a domestic disturbance at Morgan's residence in Missouri. Morgan's estate sued Cook pursuant to 42 U.S.C. 1983, alleging Cook used excessive force in violation of Morgan's Fourth Amendment rights. The district court granted Cook's motion for summary judgment, finding Cook was entitled to qualified immunity because his actions were objectively reasonable. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err in its conclusion that Cook's actions were objectively reasonable and therefore did not violate Morgan's Fourth Amendment rights. Thus, Cook was entitled to qualified immunity.

A jury convicted Defendant of being a felon in possession of a firearm. Defendant appealed, asserting that the district court erroneously denied his motion to suppress and excluded prior convictions of a government witness under Fed. R. Evid. 609. Defendant also argued that there was insufficient evidence to support the jury's verdict. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err when it denied Defendant's motion to suppress; (2) the district court did not erroneously exclude two prior convictions of a government witness under Rule 609; and (3) there was sufficient evidence to support Defendant's conviction for being a felon in possession of a firearm.

Defendant David Gamble appealed from his sentence of 188 months' imprisonment for conspiracy to distribute at least five grams of cocaine base, arguing that the district court erred in not applying the Fair Sentencing Act (FSA) to his case. The conduct underlying Gamble's sentence occurred before the FSA went into effect, but Gamble's sentencing was after this date. The Eighth Circuit Court of Appeals reversed under Dorsey v. United States, in which the Supreme Court held that the FSA applies where the defendant committed the crime before, but was sentenced after, the FSA went into effect. Dorsey abrogated the Eighth Circuit's case, United States v. Sidney, which held that the FSA does not apply retroactively. Remanded.

A jury convicted Defendant of aggravated sexual abuse of a child. The district court denied Defendant's motion for a new trial and sentenced him to 360 months' imprisonment, followed by a lifetime of supervised release. The court also ordered that, upon his release, Defendant abstain from the use of alcohol and from possessing sexually explicit materials. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion by denying Defendant's new trial motion, as Defendant did not meet his burden of proving that the loss of an exhibit after trial resulted in a miscarriage of justice; and (2) the district court did not plainly err by requiring Defendant to participate in an alcohol and drug abuse treatment program and by prohibiting Defendant from possessing sexually explicit materials.