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

Plaintiffs in this case alleged their former bankruptcy trustee breached professional duties due them because of conflicting obligations the trustee owed the bankruptcy estate. Plaintiffs sought recovery under state law. However, plaintiffs filed suit in federal court against the trustee alleging diversity jurisdiction and the right to have the case resolved in an Article III court. The trustee maintained the case should have been heard in an Article I bankruptcy court because the alleged-breached professional duties arose from the bankruptcy proceedings. The district court concluded the case should have been heard in the Article I court, and certified its decision for immediate appeal. The Tenth Circuit concluded that an Article III court had jurisdiction, and reversed the district court's order. View "Loveridge v. Hall" on Justia Law

Petitioner Yang You Lee was a native and citizen of Thailand. He became a permanent resident of the United States in 1987 when he was five years old. In 2014, an immigration judge (IJ) sitting in Dallas found him removable for committing a crime of violence (a misdemeanor domestic assault) and denied his application for cancellation of removal. In the Board of Immigration Appeal's order dismissing Lee's appeal, the BIA noted Oklahoma City next to Lee's file number, apparently indicating Lee's final hearing was located there. Lee filed his petition for review in the Fifth Circuit, which transferred the petition to the Tenth Circuit sua sponte and without explanation. The Tenth Circuit concluded after review that venue was proper with the Fifth Circuit, and transferred this case back to that court for further proceedings. View "Lee v. Lynch" on Justia Law

In 1989, FBI agents raided the nuclear weapons production facility known as Rocky Flats, first operated by Dow Chemical Company, then Rockwell International Corporation. The agents discovered that plant workers had been mishandling radioactive waste for years. The waste found its way into the nearby soil and groundwater.The plant's neighbors followed the government's criminal action with a civil suit, citing the federal Price-Anderson Act and state nuisance law as grounds for relief. A jury found for plaintiffs, and the district court approved roughly $177 million in compensatory damages and $200 million in punitive damages, as well as $549 million in prejudgment interest. Defendants appealed, arguing that the district court had failed to instruct the jury properly about the terms of the Price-Anderson Act. Dow and Rockwell made a "curious tactical decision," arguing that the district court's jury instructions about what constituted a nuclear incident were too permissive. The Tenth Circuit agreed that the district court's jury instructions about what did and did not qualify as a nuclear incident were too permissive. On this basis, it vacated the district court's judgment and remanded the case for further proceedings in light of the Act's correct construction. Plaintiffs appealed, renouncing the benefits the Act provided to both parties. Plaintiffs accepted the premise that they could not prove a nuclear incident as the term was interpreted by the Tenth Circuit. Instead, plaintiffs relied on their state law tort claim. Defendants countered with the argument that the Act precluded plaintiffs' state law claim. Furthermore, defendants argued that the Tenth Circuit's mandate in the first appeal of this case barred plaintiffs from relief on their state law nuisance verdict. The district court ruled in favor of defendants, and again this case came before the Tenth Circuit on appeal. "In two separate appeals spanning many years the defendants have identified no lawful impediment to the entry of a state law nuisance judgment on the existing verdict. They have shown no preemption by federal law, no error in the state law nuisance instructions, no mandate language specifically precluding this course. No other error of any kind is even now alleged." The Tenth Circuit vacated the district court's judgment and remanded the case for further proceedings. View "Cook v. Rockwell International" on Justia Law

In 2008, Donald Stewart, driving a semi-tractor trailer, hit the back of a tow truck driven by Melvin Mathis. Mathis sued Stewart and his employer, Huff & Puff Trucking, Inc., for negligence in the District of Wyoming. After a bench trial, the district court issued findings of fact and conclusions of law. The court determined Stewart was 100 percent at fault for the accident, and entered judgment in favor of Mathis. The damages award, which was significantly less than Mathis sought, was based on findings that his spinal injuries from the accident were only temporary and he did not suffer a mild traumatic brain injury (“MTBI”). Mathis moved for a new trial, arguing, among other things, that the judge’s law clerk had an undisclosed conflict of interest. The court denied the motion. On appeal, Mathis challenged: (1) the district court’s factual findings relating to his back and head injuries; (2) whether the court impermissibly allowed a defense expert to testify beyond his qualifications as a biomechanical engineer; and (3) the court’s denial of his motion for a new trial based on the alleged law clerk conflict. Finding no reversible error, the Tenth Circuit affirmed. View "Mathis v. Huff & Puff Trucking" on Justia Law

At issue in this case was the district court's grant of summary judgment to the court-appointed receiver for Winsome Investment Trust, a business entity whose founder, Robert Andres, caused it to illegally distribute funds as part of a Ponzi scheme. The court found that Andres had fraudulently transferred funds from Winsome to William Cornelius and his law firm, Cornelius & Salhab, and that the receiver could recover these funds on Winsome's behalf under the Uniform Fraudulent Transfer Act (UFTA). Cornelius, who was unaware of the fraud, raised several challenges to the district court's jurisdiction and its judgment on the merits. Finding no reversible error, the Tenth Circuit affirmed: the receiver was entitled to sue Cornelius in Utah, and no federal jurisdictional impediments prevent the district court from reaching the UFTA claim. The district court also correctly concluded the payments to Cornelius violated the UFTA and the four-year statute of limitations did not bar the receiver's claim. View "Klein v. Cornelius" on Justia Law

Plaintiff-appellant Sabreen Gad filed a complaint with the Equal Employment Opportunity Commission against Kansas State University, alleging she was discriminated against in her effort to obtain a tenure-track position. Despite the EEOC sending her a formal charge document to sign and verify, as both Title VII and EEOC regulations required, she never did so. The EEOC elected not to pursue her case; she brought a Title VII suit against KSU. The issue this appeal presented for the Tenth Circuit's review centered on whether Title VII's requirement that a claimant verify the charges against an employer was a jurisdictional prerequisite to suit: if yes, then the district court correctly concluded that it lacked Article III subject-matter jurisdiction and dismissed the complaint; if the verification requirement was a non-jurisdictional condition precedent to suit, it could be waived without defeating jurisdiction. The Tenth Circuit concluded the verification requirement was non-jurisdictional and did not divest the federal courts of subject-matter jurisdiction. Consequently, the Court reversed the district court's contrary decision and remanded the case for further proceedings. View "Gad v. Kansas State University" on Justia Law

Several voters filed a challenge to Sandoval County’s administration of the 2012 local election, and the district court concluded that the County’s election procedures were so dysfunctional that an immediate remedy was necessary to avoid voter disenfranchisement in the approaching 2014 election. To remedy the anticipated election day problems, the court entered a preliminary injunction that required the County to adhere to new regulations increasing the number of voting centers and voting machines. County election officials sought interlocutory appellate review of the preliminary injunction prior to the election, but the Tenth Circuit declined to intervene at that time. The election went off without a hitch, and the Court reviewed the County’s challenge to the injunction. In addition, the Court considered a motion to dismiss the appeal as moot presented by the voters who brought the suit. Concluding the issues raised by the grant of the preliminary injunction were mooted by the passage of the 2014 election, the Court granted the motion and dismissed the appeal for lack of jurisdiction. View "Fleming v. Gutierrez" on Justia Law

For a second time, Dustin Eastom attempted to appeal a district court’s order granting summary judgment to the City of Tulsa and Jeffrey Henderson, a Tulsa police officer. Eastom attempted to appeal the same order in 2014, but the Tenth Circuit dismissed for lack of jurisdiction. The Tenth Circuit again dismissed Eastom’s appeal for lack of jurisdiction because the district court’s order was still not final. View "Eastom v. City of Tulsa" on Justia Law

Multiple plaintiffs, including ConAgra Foods, Inc. and Swift-Eckrich, Inc., brought suit in Kansas state court against Americold Logistics, LLC and Americold Realty Trust (the “Americold entities”). The Americold entities removed the case to the United States District Court for the District of Kansas. As the basis for removal, the Americold entities asserted the parties were completely diverse. No party challenged the propriety of removal; the district court did not address the issue. The merits of the suit were submitted to the district court on cross-motions for summary judgment. The district court granted summary judgment to the Americold entities. ConAgra and Swift-Eckrich appealed. After the parties filed their merits briefs, the Tenth Circuit noted a potential jurisdiction defect in the notice of removal. The issue this case presented was how the citizenship of a trust is determined: by exclusive reference to the citizenship of its trustees? The Tenth Circuit held that citizenship of a trust, just like the citizenship of all other artificial entities except corporations, is determined by examining the citizenship “of all the entity’s members.” That being the case here, the district court lacked subject matter jurisdiction over the suit underlying this appeal. The Tenth Circuit remanded the matter to the district court to vacate its judgment on the merits and remand the matter to state court. View "Conagra Foods v. Americold Logistics" on Justia Law

The Miss Dixie was a cargo line boat operated by defendant-appellant Jantran, Inc., a company involved in maritime transportation on the Verdigris River in Oklahoma. The Miss Dixie struck and extensively damaged a lock maintained by the Army Corps of Engineers. After repairing the lock, the Corps sued Jantran for the costs of repair. The district court dismissed the Corps' suit, concluding that federal law did not allow the Corps to seek in personam damages directly from the owners of a vessel that damages a structure on navigable waters. As the court found, the applicable statute, the Rivers and Harbors Act, only allowed in rem claims against the vessel that caused the damage. After review, the Tenth Circuit agreed with the district court that the Act did not authorize in personam actions against the owners of the vessel. The Act only allowed the Corps to proceed in rem against the vessel itself. The Court therefore affirmed the district court's ruling. View "United States v. Jantran" on Justia Law