United States v. Metcalf

The Eighth Circuit affirmed defendant's conviction of committing a hate crime in violation of the Matthew Shepard and James Byrd, Jr., Hate Crimes Prevention Act of 2009, 18 U.S.C. 249(a)(1). The court held that the district court did not err in denying defendant's motion to dismiss the indictment on constitutional grounds where Congress rationally determined, in light of the Thirteenth Amendment, that racially motivated violence constitutes a badge and incident of slavery; the district court did not abuse its discretion in refusing to give the proposed jury instruction on character evidence; and the evidence was clearly sufficient to support the conviction. View "United States v. Metcalf" on Justia Law