United States v. Randy Metcalf, 881 F.3d 641

On Jan. 11, 2015, Randy Joe Metcalf assaulted Lamarr Sandridge, an African‑American man, in a Dubuque, Iowa bar; surveillance showed Metcalf repeatedly kicked and stomped Sandridge’s head and returned to renew the attack.
During the incident and before it, Metcalf made repeated racial epithets, displayed a swastika tattoo, and boasted about prior cross‑burning; witnesses heard him say “die n----r” and similar statements.
Metcalf was indicted under 18 U.S.C. § 249(a)(1) (the Matthew Shepard and James Byrd, Jr. Hate Crimes Prevention Act) for willfully causing bodily injury because of Sandridge’s race.
Metcalf moved to dismiss, arguing § 249(a)(1) is unconstitutional because Congress lacked authority under the Thirteenth Amendment; the district court denied the motion.
At trial Metcalf introduced testimony asserting his lack of racism and requested a specific jury instruction on character evidence; the court admitted the evidence but refused the requested instruction, giving a general credibility instruction instead.
The jury convicted Metcalf; the district court sentenced him to the statutory maximum (120 months). Metcalf appealed, challenging the statute’s constitutionality, the court’s refusal to give his proposed jury instruction, and the sufficiency of the evidence.

Issue	Metcalf's Argument	Government's Argument	Held
Whether § 249(a)(1) is a valid exercise of Congress’s Thirteenth Amendment power	§ 249 exceeds Congress’s Thirteenth Amendment authority; Shelby County and Boerne principles limit Congress’s power	Thirteenth Amendment and Jones allow Congress to legislate against "badges and incidents of slavery," including racially motivated violence	Section 249(a)(1) is constitutional under the Thirteenth Amendment; Jones controls and Shelby/Boerne do not undermine it
Whether the court erred in refusing Metcalf’s proposed jury instruction on character (lack of racism)	Requested instruction required because character evidence went to an element/defense; it explained his legal theory	Court already admitted character evidence and gave general credibility instructions adequate to cover the substance	No abuse of discretion; evidence was admitted and instructions as a whole adequately allowed jury to consider the defense
Whether the evidence was sufficient to support the conviction	(argued on appeal) evidence insufficient to prove racially motivated injury beyond a reasonable doubt	Surveillance, eyewitness testimony, and Metcalf’s racial statements established motive and willfulness	Evidence was sufficient when viewed in the light most favorable to the verdict; conviction affirmed

Jones v. Alfred H. Mayer Co., 392 U.S. 409 (Thirteenth Amendment empowers Congress to eliminate badges and incidents of slavery)
City of Boerne v. Flores, 521 U.S. 507 (limits on Congressional enforcement under the Fourteenth Amendment)
Shelby County v. Holder, 133 S. Ct. 2612 (limits on Congressional coverage formula under the Fifteenth Amendment)
United States v. Maybee, 687 F.3d 1026 (8th Cir.) (upholding § 249(a)(1) under the Thirteenth Amendment)
United States v. Hatch, 722 F.3d 1193 (10th Cir.) (Thirteenth‑Amendment analysis supporting § 249)
United States v. Cannon, 750 F.3d 492 (5th Cir.) (same)
United States v. Krapp, 815 F.2d 1183 (8th Cir.) (district court not required to give particular character instruction)
United States v. Gianakos, 415 F.3d 912 (8th Cir.) (standard of review for instruction rulings)
United States v. Coppock, 765 F.3d 921 (8th Cir.) (standard of review for denial of motion to dismiss)
United States v. Wiest, 596 F.3d 906 (8th Cir.) (standard for reviewing sufficiency of the evidence)