Federal appellate courts issued several rulings this week concerning constitutional law, including jurisdictional standards, Fourth Amendment protections, and municipal liability. The Eleventh Circuit ruled that Maritime Drug Law Enforcement Act jurisdiction is a preliminary question of law for judges rather than a jury element, requiring proof by a preponderance of the evidence. In the Sixth Circuit, the court reversed the dismissal of a Monell failure-to-train claim against Knox County regarding a jail overdose death, finding that staff failure to follow medical policies supported the claim. Separately, the Eighth Circuit rejected Fourth Amendment challenges to a protective frisk in a felon-in-possession case. Additionally, the Fifth Circuit affirmed the dismissal of a habeas petition regarding First Step Act credits, while the Sixth Circuit upheld convictions for the murder of a federal officer, affirming the validity of the underlying search warrant. Synthesized from 10 manifests produced by 4 monitored court and legislature sources in the last 7 days, including court holdings, constitutional amendments, statehouse measures.
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Eleventh Circuit affirms MDLEA jurisdiction standard and sentencing enhancement in drug trafficking case
The Eleventh Circuit affirmed the convictions and sentences of three defendants for drug trafficking under the Maritime Drug Law Enforcement Act (MDLEA). The court clarified that MDLEA jurisdiction is a preliminary question of law for the judge, not a jury element, and must be proven by a preponderance of the evidence.
Fifth Circuit affirms dismissal of habeas petition seeking First Step Act time credits
The Fifth Circuit affirmed the district court's dismissal of Dennis Hogan's § 2241 habeas petition, which sought First Step Act (FSA) time credits for the period between his sentencing and arrival at his designated Bureau of Prisons (BOP) facility. The court held that because Hogan failed to substantiate any participat
Sixth Circuit Affirms Convictions for Murder of Federal Officer and Drug Trafficking
Then Sixth Circuit affirmed the convictions and life sentences of Nathan Goddard and Cahke Cortner for the murder of DEA Officer Jorge Del Rio. Then court held that the search warrant was supported by probable cause, the exclusion of the DEA's operational plan was not an abuse of discretion, and sufficient evidence sup
Sixth Circuit reverses dismissal of failure-to-train claim in Knox County jail overdose death
The Sixth Circuit held that a plaintiff plausibly stated a Monell failure-to-train claim against Knox County by alleging that jail staff failed to screen or monitor a detainee who died of an overdose despite obvious symptoms. The court determined that the total failure of multiple staff members to follow established ja
Eighth Circuit affirms conviction and sentence in United States v. Davis Negrete
The Eighth Circuit affirmed the conviction and 77-month sentence of David Negrete for being a felon in possession of a firearm. The court rejected Negrete's Fourth Amendment challenges to his detention and the scope of the protective frisk, and upheld the district court's application of a four-level sentencing enhancem