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United States v. DeCoster

No. 15-1890 (2016)

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United States v. DeCoster

United States Court of Appeals for the Eighth Circuit

No. 15-1890 (2016)

Facts

Jack and Peter DeCoster (the DeCosters) (defendants) owned and operated Quality Egg (QE) (defendant). A salmonella outbreak originated at QE’s Iowa facilities. The government (plaintiff) investigated and found QE had falsified food-safety-measure records, lied to auditors, bribed a U.S. Department of Agriculture inspector, failed to test hens for salmonella, and misled regulators and customers by changing packing dates. The DeCosters pleaded guilty to misdemeanor violations as responsible corporate officers under the Federal Food, Drug, and Cosmetic Act (FDCA). The DeCosters were each sentenced to three months’ imprisonment and appealed, arguing in part that their prison sentences violated due process and the Eighth Amendment because they did not personally commit wrongful acts or know the eggs were contaminated when shipped.

Rule of Law

Issue

Holding and Reasoning (Murphy, J.)

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