Justia U.S. 10th Circuit Court of Appeals Opinion Summaries

Larry Lawson, former CEO of Spirit AeroSystems, Inc., retired and entered into a Retirement Agreement with Spirit, which allowed him to continue vesting in long-term incentive stock awards as if he were an active employee. This agreement was conditioned on his compliance with a non-competition covenant from his original Employment Agreement. Lawson later engaged with a hedge fund, Elliott Management, which was involved in a proxy contest with Arconic, a competitor of Spirit. Spirit deemed this a violation of the non-competition covenant and ceased payments and stock vesting under the Retirement Agreement.The United States District Court for the District of Kansas held a bench trial and found that Lawson had not violated the non-competition covenant, ruling in his favor. Spirit appealed, and the Tenth Circuit reversed, holding that Lawson had breached the covenant and remanded the case to determine the enforceability of the covenant under Kansas law.On remand, the district court found the non-competition covenant enforceable without applying the reasonableness test from Weber v. Tillman, concluding that the covenant was a condition precedent to the receipt of future benefits, not a traditional non-compete. The court severed the injunctive enforcement mechanism from the covenant, leaving only the condition precedent.The United States Court of Appeals for the Tenth Circuit affirmed the district court's judgment, predicting that the Kansas Supreme Court would not apply the Weber reasonableness test to a non-competition condition precedent to the receipt of future benefits. The court also denied Lawson's motion to certify the question to the Kansas Supreme Court, finding it unnecessary to resolve the issue. View "Lawson v. Spirit Aerosystems" on Justia Law

Gerald Silver filed a putative class action against the City of Albuquerque, alleging that the City violated the Telephone Consumer Protection Act (TCPA) by making pre-recorded phone calls to invite residents to virtual town hall meetings during the COVID-19 pandemic. Silver claimed he received at least seven such calls on his cell phone. The City argued that it was not subject to the TCPA as it was not a "person" under the statute and that the calls fell under the TCPA’s emergency purposes exception.The United States District Court for the District of New Mexico granted the City’s motion to dismiss, concluding that the calls fell within the emergency purposes exception of the TCPA. The court did not address whether the City was a "person" under the TCPA. Silver appealed the decision.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Tenth Circuit held that even assuming the TCPA applies to local governments, Silver’s complaint did not state a claim upon which relief could be granted. The court found that the calls were made by a local government official, were informational, and were made necessary by the COVID-19 pandemic to inform residents about virtual town hall meetings, which were a mitigation measure in response to the pandemic. Therefore, the calls fell within the TCPA’s emergency purposes exception. The court did not need to determine whether local governments qualify as persons under the TCPA. View "Silver v. City of Albuquerque" on Justia Law

C.L., a twelve-year-old student, was invited by her teacher, Jenna Riep, to an after-school art club meeting, which turned out to be a Gender and Sexualities Alliance (GSA) meeting. During the meeting, a guest speaker, Kimberly Chambers, discussed gender identity and suggested that students uncomfortable with their bodies might be transgender. Chambers also warned students that it might not be safe to tell their parents about the meeting and provided her personal contact information for further communication. C.L. announced herself as transgender at the meeting and later informed her parents, who subsequently disenrolled her from the school. H.J., another student, had similar experiences and also faced emotional distress, leading her parents to disenroll her from the school.The parents of C.L. and H.J. sued the Poudre School District and its Board of Education, alleging a violation of their Fourteenth Amendment parental substantive-due-process rights. The United States District Court for the District of Colorado dismissed the complaint without prejudice. The parents then moved to amend their complaint, focusing solely on a claim against the school district for monetary damages. The district court denied the motion to amend, concluding that the parents had failed to plausibly allege municipal liability.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the parents did not plausibly allege that the school district's official policy was the moving force behind their alleged injuries. The court found that the parents failed to establish a direct causal link between the district's policies and the constitutional injury they claimed. View "Lee v. Poudre School District R-1" on Justia Law

George Smith was convicted of first-degree murder and causing the death of another during the commission of a firearm offense. On April 8, 2021, Smith spent the day with his great-uncle, Jimmy Arthur, and later that evening, Arthur was fatally shot in the back of his head and neck while seated at his dining table. Smith claimed masked intruders were responsible, but evidence suggested otherwise. Smith was found with Arthur's body and had moved it, tampering with the crime scene. Blood consistent with Arthur's was found on Smith's sweatpants, and Smith had attempted to pawn a .25 caliber pistol earlier that day, which matched the caliber of the shell casing found at the scene.The United States District Court for the Eastern District of Oklahoma tried Smith, and a jury convicted him on both counts. Smith was sentenced to life in prison. He appealed, arguing insufficient evidence, juror misconduct, and prosecutorial misconduct.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that sufficient evidence supported the jury's verdict, including Smith's presence at the scene, his inconsistent statements, and the forensic evidence. The court also determined that the district court did not abuse its discretion in handling the juror misconduct incident, as the court conducted a thorough investigation and found no prejudice to Smith. Lastly, the court found no prosecutorial misconduct, as the statements made by the prosecutor were not improper, and any errors in testimony were corrected during the trial.The Tenth Circuit affirmed Smith's convictions, concluding that the evidence was sufficient, the juror misconduct was properly addressed, and there was no prosecutorial misconduct affecting the trial's fairness. View "United States v. Smith" on Justia Law

Patrick Harmon was stopped by Salt Lake City police officer Kris Smith for a traffic violation while riding a bicycle. Harmon provided a false name, but Officer Smith identified him and discovered an active felony warrant. When Officer Smith attempted to arrest Harmon, he fled. Officers Clinton Fox and Scott Robinson joined the chase. The officers reported seeing Harmon reach towards his waist or pocket and heard him mention cutting or stabbing. Officer Fox claimed he saw Harmon holding a knife and shot him three times from five to seven feet away. Officer Smith, who was about fifteen feet away, fired his taser. Harmon died from the gunshots, and a knife was found near his right arm.Harmon's estate and his children sued Officer Fox and Salt Lake City for excessive force. The United States District Court for the District of Utah dismissed the case, but the Tenth Circuit Court of Appeals reversed and remanded. On remand, the district court granted summary judgment to Officer Fox and Salt Lake City, concluding that any factfinder would determine Harmon was holding a knife and that the shooting was reasonable.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court found that a genuine dispute of material fact existed regarding whether Harmon brandished a knife or threatened the officers. The court noted that the video evidence did not clearly show a knife, and Officer Smith testified he did not see a knife. The court concluded that a factfinder could reasonably find that Harmon did not pose an imminent threat, making the use of deadly force unreasonable. The court held that Officer Fox was not entitled to qualified immunity and reversed the summary judgment, remanding the case for further proceedings. View "Harmon v. Salt Lake City" on Justia Law

Bruce Holder was accused of running a fentanyl distribution ring in western Colorado, distributing thousands of counterfeit pills resembling oxycodone. He was convicted of four federal drug crimes, including charges related to the death and serious injury of buyers of his product. Holder challenged the constitutionality of his trial, arguing that the district court’s COVID-19 protocols violated his right to a public trial, that the jury pool unreasonably underrepresented certain racial groups, that several counts were constructively amended at trial, and that the evidence was insufficient to support the jury’s finding that his fentanyl distribution resulted in a victim’s death.The United States District Court for the District of Colorado imposed COVID-19 protocols, including social distancing, mask-wearing, and limited public access to the courtroom. Holder objected to these protocols, particularly the lack of video access and the limited public attendance. The jury convicted Holder on all four counts.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the district court’s COVID-19 protocols did not violate Holder’s public trial rights, as the partial closure of the courtroom was justified by the substantial interest in protecting public health. The court also found no unreasonable racial disparity in the jury pool, as the absolute and comparative disparities were within acceptable limits. Additionally, the court determined that the indictment was not constructively amended, as the jury instructions did not alter the essential elements of the charges. Finally, the court held that there was sufficient evidence to support the jury’s finding that Holder’s fentanyl distribution resulted in a victim’s death.The Tenth Circuit affirmed Holder’s conviction. View "United States v. Holder" on Justia Law

Michael Hooper, a former employee of Double Eagle Alloys, Inc., left the company to join competitor Ace Alloys, LLC, taking with him 2,660 digital files containing Double Eagle’s business information. Double Eagle discovered the download and sued Hooper and Ace Alloys, alleging trade-secret violations, misappropriation of confidential business information, and civil conspiracy.The United States District Court for the Northern District of Oklahoma granted summary judgment to Hooper and Ace Alloys on all claims. The court found that Double Eagle failed to identify its alleged trade secrets with sufficient particularity and clarity to proceed to trial. The court also held that Double Eagle did not present evidence that its business information was confidential, and thus, the misappropriation claim could not stand. Finally, the court dismissed the civil-conspiracy claim because it lacked an underlying tort.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that Double Eagle did not identify its trade secrets with sufficient particularity. The court noted that Double Eagle’s PSQ specifications, pricing, and customer drawings were either publicly available or not shown to be unique and confidential. The court also found that Double Eagle failed to present sufficient evidence that its business information was confidential, as required for the misappropriation claim. Consequently, the civil-conspiracy claim was also dismissed due to the absence of an underlying tort. View "Double Eagle Alloys v. Hooper" on Justia Law

A police officer, Mathew Grashorn, shot a dog named Herkimer after responding to a business owner's call about a truck in a parking lot after hours. Upon arrival, Officer Grashorn saw the truck and two dogs, Bubba and Herkimer. Bubba initially ran towards the officer but returned to his owner when called. Herkimer then emerged and ran towards the officer, who shot the dog when it was a few feet away. Herkimer was later euthanized due to the injuries.The plaintiffs, Wendy Love and Jay Hamm, sued Officer Grashorn for violating the Fourth Amendment. The United States District Court for the District of Colorado denied the officer's motion for summary judgment based on qualified immunity, concluding that a jury could reasonably find that Herkimer did not pose an immediate danger, and thus the shooting could be a clearly established violation of the Fourth Amendment.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court upheld the district court's denial of summary judgment, agreeing that a jury could find no immediate danger and that the officer had time to consider non-lethal options. The court emphasized that common sense and case law clearly establish that shooting a pet dog without an immediate threat constitutes a Fourth Amendment violation. The court also rejected the officer's argument that a reasonable mistake about the danger would grant him qualified immunity, as the district court's factual conclusions suggested the mistake was unreasonable. The Tenth Circuit affirmed the district court's decision, denying qualified immunity to Officer Grashorn. View "Love v. Grashorn" on Justia Law

Dedric Mayfield, a felon, was convicted by a jury of possessing ammunition in violation of 18 U.S.C. § 922(g)(1) after being recorded by a police-operated camera firing a handgun during an altercation. Mayfield had five prior adult felony convictions. Before trial, he did not stipulate to the authenticity or admissibility of any government exhibits. When the camera operator became unavailable for trial, Mayfield volunteered to stipulate to the authenticity and admissibility of the footage, allowing a detective to testify about it. The district court denied the government's motion for a continuance and instructed Mayfield to stipulate to the authenticity and admissibility of exhibits unless he had a good-faith basis not to do so. Mayfield stipulated to some exhibits, and the jury found him guilty. He was sentenced to 120 months in prison.The United States District Court for the District of Colorado handled the initial trial. Mayfield did not object to the district court's instructions regarding stipulations during the trial. He later argued that these instructions violated his Sixth Amendment fair-trial and Fourteenth Amendment due-process rights by coercing his counsel into stipulating to the government's evidence, thus depriving him of a fair trial.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court assumed without deciding that the district court's instructions were erroneous but found that Mayfield failed to demonstrate a reasonable probability that the outcome of the trial would have been different but for the error. The court also rejected Mayfield's argument that 18 U.S.C. § 922(g)(1) is facially unconstitutional under the Second Amendment, citing precedent that upheld the statute's constitutionality. The Tenth Circuit affirmed the district court's decision. View "United States v. Mayfield" on Justia Law

K.A. and C.P. were married and had three daughters. Their marriage ended in divorce, and the Arapahoe County Department of Human Services (ACDHS) initiated actions against K.A. regarding her relationships with her children, leading to the termination of her parental rights and several contempt judgments. K.A. attempted to appeal the termination, but the Colorado Court of Appeals denied it as untimely, and the Colorado Supreme Court declined review. She also sought to appeal a contempt sentence, but it was again deemed untimely.K.A. filed a complaint under 42 U.S.C. § 1983 in the United States District Court for the District of Colorado against Michelle Barnes, Executive Director of the Colorado Department of Human Services (CDHS), in her official capacity; ACDHS; and Michelle Dossey, Manager of the ACDHS Division of Child and Adult Protective Services, in her official capacity. The Arapahoe County Board of Commissioners was initially named but later dismissed by K.A. The district court dismissed K.A.'s claims and denied her motion to amend her complaint. K.A. filed a timely appeal.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that it lacked jurisdiction to hear K.A.'s claims due to sovereign immunity, the Rooker-Feldman doctrine, and lack of standing. The court found that K.A.'s claims for damages were barred by sovereign immunity, and her requests to reverse the termination of her parental rights and order a new hearing were barred by the Rooker-Feldman doctrine. Additionally, her requests for declaratory relief were either barred by sovereign immunity or lacked standing. The court also upheld the district court's denial of K.A.'s motion to amend her complaint, as she failed to explain how the amendments would cure the jurisdictional defects. View "K.A. v. Barnes" on Justia Law