DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
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191436P.pdf 08/14/2020 Grand Juror Doe v. Wesley Bell
U.S. Court of Appeals Case No: 19-1436
U.S. District Court for the Eastern District of Missouri - St. Louis
[PUBLISHED] [Gruender, Author, with Wollman and Shepherd, Circuit Judges]
Civil case - Missouri Grand Juries. Doe was a juror on the grand jury
which considered whether to bring criminal charges against former
Ferguson, Missouri police officer Darren Wilson in the August, 2014 death
of Michael Brown. In this action she sought a declaration that Missouri's
grand jury secrecy laws are an unconstitutional abridgement of free speech
as applied to her and an injunction preventing their enforcement. For the
court's prior opinion in the matter, see Doe v. McCulloch, 835 F.3d 785
(8th Cir. 2016). On remand, the district court dismissed the action, and
this court affirms. The court need not settle the questions of whether
Doe's proposed speech about the grand jury proceedings is covered by the
First Amendment or whether Doe waived her speech rights by swearing an
oath to keep grand jury matters secret because Missouri's grand jury
secrecy laws survive even the strictest scrutiny and are narrowly tailored
to achieve a compelling state interest in preserving the functioning of
its grand jury system