Notable Opinions: Week of April 27, 2026

Trespassing Statute

Plaintiff appealed the dismissal of its complaint challenging Iowa’s “trespass‑surveillance” statute. Plaintiff and other animal welfare groups sought to block enforcement of the law, which prohibited placing recording devices on trespassed property and imposed enhanced penalties. Plaintiff argued the statute violated its members’ First Amendment rights by preventing recording on property open to the public after an owner demanded they leave, but not stop recording. The court held the statute served a substantial state interest in protecting privacy and was narrowly tailored because a demand to leave necessarily included stopping recording. The district court’s judgment was affirmed.

PETA v. Iowa Citizens for Community Improvement (8th Circuit)

Motion to Suppress Evidence

Defendant appealed his conviction and sentence for being a felon in possession of ammunition, arguing that the district court improperly denied his motion to suppress evidence and statements, lacked sufficient evidence of an interstate commerce nexus, and incorrectly applied an obstruction‑of‑justice enhancement. The court held that police lawfully stopped defendant’s vehicle due to an obstructed view and the owner’s suspended license, and lawfully extended the stop based on defendant’s behavior and apparent intoxication. As a result, the evidence was admissible, sufficient evidence supported the interstate commerce element, and the sentencing enhancement was proper. The judgment was affirmed.

U.S. v. Hallmon (8th Circuit)

Line of Duty

Relator appealed the denial of public‑safety‑officer death benefits after her brother, a sheriff’s lieutenant, died of a heart attack and drowning while on medical leave. She argued that occupational stress caused his death, qualifying as “killed in the line of duty.” The Court of Appeals held that Minn. Stat. § 299A.41, subd. 3 governed the claim and required the heart attack to occur during or shortly after qualifying on‑duty activity, which was not met. The denial of benefits was affirmed.

In re Vnuk (Court of Appeals)