Steven Colloton of Iowa is a judge of the U.S. Court of Appeals for the Eighth Circuit, a position he has held since President George W. Bush appointed him in 2003. Judge Colloton has a résumé that also includes distinguished service as the U.S. Attorney for the Southern District of Iowa, a Special Assistant to the Attorney General in the Justice Department’s Office of Legal Counsel, and a lecturer of law at the University of Iowa. He received his law degree from Yale, and he clerked for Chief Justice William Rehnquist. Judge Colloton is an Iowa native.
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In re Lombardi
Death row prisoners challenged Missouri’s lethal injection protocol on Eighth Amendment grounds. The district court ordered discovery of the identities of the physician, pharmacist, and laboratory involved in the prescription, compounding, and manufacturing of the three drugs used in the protocol. The state petitioned for a writ of mandamus prohibiting the discovery on the grounds that these identities were irrelevant to the Eight Amendment claim, and their disclosure would prevent the state from obtaining necessary lethal chemicals due to public backlash. Judge Colloton granted the writ, finding that the discovery sought was not relevant to the Eighth Amendment challenge.
United States v. Lunsford
Judge Colloton’s majority opinion held the Sex Offender Registration and Notification Act did not require a registered sex offender to change address when moving to a foreign country. His opinion split the circuits on the issue. In Nichols v. United States, the Supreme Court unanimously resolved the issue in Judge Colloton’s favor.
Davison v. City of Minneapolis
An Eighth Circuit panel found a Minneapolis firefighter critical of the department had established a prima facie case of discrimination sufficient to survive summary judgment. Judge Colloton dissented, citing concerns that the ruling would open the door for any outspoken public employee to assert discrimination in the face of an adverse employment decision, and calling for a higher evidentiary burden on the plaintiff in such cases.
United States v. Harris
Harris pled guilty to unlawful possession of a firearm and was sentenced to imprisonment followed by supervised release. As a condition of his supervision, the court prohibited him from having unprotected sex without probation office approval. On appeal, he challenged the district court’s ability to impose such a condition. Judge Colloton held that the district court lacked such authority because the perceived problem it attempted to address had no relation to the nature of the defendant’s offense, and it impermissibly deprived the defendant of more liberty than was reasonably necessary to afford adequate deterrence.
Southern Wine & Spirits of America, Inc. v. Division of Alcohol and Tobacco Control
The Missouri Department of Public Safety denied Southern Wine’s application for a wholesale liquor license for failure to satisfy a statutory residency requirement. The constitutionality of the residency requirement relied upon the relationship between the dormant Commerce Clause and § 2 of the Twenty-First Amendment. Judge Colloton and the Eighth Circuit upheld the statute because its purpose satisfied the Twenty-First Amendment’s objective of permitting States to establish a uniform system for regulating liquor through its “transportation, importation, and use.” The statute therefore had a rational basis and failed to deny Southern Wine equal protection under the Fourteenth Amendment.
Creative Calling Solutions, Inc. v. LF Beauty LTD
An Iowa district court dismissed the suit brought by an Iowa corporation against a Hong Kong company for breach of contract, citing a lack of personal jurisdiction. The Iowan corporation appealed the ruling, arguing that the court could have jurisdiction over a foreign company that directly interacted with company employees in Iowa by soliciting business from them, mailing products to them, and remitting payments to them in Iowa. Judge Colloton reversed the lower court, holding that the plaintiff presented sufficient evidence of minimal contacts to justify jurisdiction. The opinion further held that jurisdiction would not offend traditional personal jurisdiction concerns of fair play and substantial justice because of the state’s interest in providing a local forum for plaintiffs.
U.S. v. Castleman
In a concurrence, Judge Colloton explained his view of the Fourth Amendment’s open fields doctrine. Police executed a search warrant at the defendant’s home, but also searched other areas of the 262-acre property. Charged with conspiracy to manufacture methamphetamine, the defendant challenged evidence police found on the property. He argued he had a reasonable expectation of privacy to his entire property because he controlled access to it with a locked gate, barbed wire fences, and signs posted.