United States v. DeCoster, No. 15-1890 (8th Cir. 2016)Annotate this Case
Defendants Jack and Peter DeCoster pled guilty, as "responsible corporate officers" of Quality Egg, LLC, to misdemeanor violations of 21 U.S.C. 331(a) for introducing eggs that had been adulterated with salmonella enteritidis into interstate commerce. The language in the Food Drug & Cosmetic Act, 21 U.S.C. 331, and Supreme Court precedent interpreting the statute support the conclusion that defendants are not required to have known that they violated the FDCA to be subject to the statutory penalties. The court concluded that this is not the rare case in which a threshold comparison of the crime committed and the sentence imposed leads to an inference of gross disproportionality. Moreover, defendants' three month prison sentences fell at the low end of the prescribed statutory range of 21 U.S.C. 333(a) (one year maximum), and the court has never held a sentence within the statutory range to violate the Eighth Amendment. Therefore, the court concluded that the district court's sentences in this case do not violate the Eighth Amendment. The court also concluded that the sentences were procedurally reasonable where the district court did not clearly err by determining that the actions or inactions of defendants was insufficient and blameworthy under these circumstances; the district court did not clearly err in interpreting the evidence to show that defendants had failed to follow all of the expert recommendations; and the district court properly considered relevant past conduct and imposed substantively reasonable sentences on defendants. Accordingly, the court affirmed the judgment.
Court Description: Murphy, Author, with Beam and Gruender, Circuit Judges] Criminal case - Criminal law and sentencing. In a prosecution for violating 21 U.S.C. Sec. 331(a) for introducing eggs that had been adulterated with salmonella into interstate commerce, the court rejects defendants' Due Process Clause and Eighth Amendment constitutional challenges; the penalty for defendants' violation was relatively small - three months - and did not violate due process; both the language of the statute and relevant Supreme Court precedent support the conclusion that defendants are not required to know they violated the Act to be subject to statutory penalties; the sentences are not grossly disproportionate to the offense and do not violate the Eighth Amendment; the district court did not commit any procedural error in setting the sentences, and the sentences imposed were not substantially unreasonable. Judge Gruender, concurring. Judge Beam, dissenting.