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

In May 2018, Brian Estrada, a prisoner in the custody of the Colorado Department of Corrections (CDOC), attempted to escape from a courthouse while shackled. He was shot three times by Jacob Smart, a CDOC officer. Estrada filed a lawsuit under 42 U.S.C. § 1983, alleging excessive force. The district court granted summary judgment in favor of Smart, concluding that Estrada had failed to exhaust all available CDOC administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States District Court for the District of Colorado found that Estrada did not follow CDOC’s three-step grievance process regarding the shooting incident. Estrada argued that the courthouse was not a CDOC prison, and thus, the PLRA did not apply to his case. The district court disagreed, ruling that the PLRA and CDOC’s grievance procedures applied to the shooting of a CDOC inmate by a CDOC officer, regardless of the location.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s decision. The Tenth Circuit held that the PLRA’s exhaustion requirement applies broadly to all inmate suits about prison life, including incidents occurring outside the prison walls, such as the courthouse shooting. The court also determined that CDOC’s grievance procedures were applicable to the incident, as they cover actions by employees and incidents affecting inmates, even outside the facility. The court concluded that Estrada’s failure to exhaust the available administrative remedies barred his § 1983 claim. View "Estrada v. Smart" on Justia Law

The case involves a civil rights suit filed under 42 U.S.C. § 1983 by Peatinna Biggs, an intellectually disabled prisoner, against Sedgwick County, the Sedgwick County Sheriff’s Department, and Sheriff Hanna in his individual and official capacities. Biggs alleged that Sheriff Hanna sexually assaulted her while transporting her between county jails. The district court dismissed the complaint against the County and the Sheriff’s Department, reasoning that the County could only be liable if the challenged conduct had been taken pursuant to a policy adopted by the official or officials, and Hanna’s actions were not pursuant to Department policies, but in direct contravention of them. Hanna was then found liable by a jury in his individual capacity.The United States Court of Appeals for the Tenth Circuit reversed the district court's decision. The court held that Sheriff Hanna’s actions fell within the scope of his policymaking authority regarding the custody and care of prisoners and subjected the municipal defendants to liability. The court reasoned that when an official takes action over which he or she has final policymaking authority, the policymaker is the municipality, so it is fair to impose liability on that entity for that action. The court concluded that given that Hanna raped a prisoner in his custody while transporting the prisoner to another jail, that requirement was undoubtedly satisfied. The case was remanded for further proceedings. View "Whitson v. Hanna" on Justia Law

The case involves a § 1983 excessive-force action brought by Marta Sanchez, the Estate of Stephanie Lopez, and Dominic Martinez against officers from the Littleton and Englewood Police Departments in Colorado. The plaintiffs alleged that the officers fired 66 bullets into their motionless vehicle while they were attempting to surrender, resulting in the death of Stephanie Lopez, severe injuries to Dominic Martinez, and rendering Marta Sanchez a paraplegic. The defendants, however, described a high-speed car chase following an armed carjacking, during which the plaintiffs allegedly used their vehicle as a weapon and endangered the public.The district court granted summary judgment to the defendants, ruling that they were entitled to qualified immunity. The court found that the plaintiffs failed to carry their burden on the clearly established law issue. The plaintiffs appealed this decision.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The appellate court found that the plaintiffs failed to provide a record-based factual universe upon which the court could conduct a clearly established law analysis. The court held that the plaintiffs effectively waived their review of their challenge to the district court’s grant of qualified immunity to the defendants. The court concluded that without a record-based factual universe reflecting the plaintiffs' version of events, it could not opine on whether the district court committed reversible error in concluding that the plaintiffs did not satisfy the clearly established law prong of the qualified-immunity test. View "Sanchez v. Guzman" on Justia Law

The case revolves around the death of Daryl Clinton, who died in the Oklahoma County Jail four days after being booked. Clinton was arrested for driving under the influence and was evaluated at a hospital before being discharged and sent to jail. Despite reporting several health issues, including an inability to move his arms or upper body, Clinton's complaints were largely dismissed by medical personnel. He was found unresponsive in his cell and later pronounced dead at the hospital. The cause of death was listed as blunt force trauma to the cervical spine.The case was initially heard in the United States District Court for the Western District of Oklahoma. Equlla M. Brothers, the personal representative of Clinton's estate, filed a lawsuit against Tommie Johnson III, the Oklahoma County Sheriff, alleging that Johnson was deliberately indifferent to Clinton's serious medical needs, violating his Fourteenth Amendment rights. The district court denied Johnson's motion for summary judgment, and the case proceeded to trial. The jury returned a verdict in favor of Johnson.Upon appeal to the United States Court of Appeals for the Tenth Circuit, Brothers argued that the evidence at trial was insufficient to support the verdict, the jury instructions misled the jury on the systemic failure claim, and the district court erred in denying her motion to contact the jury. However, the appellate court found that Brothers had waived her challenge to the sufficiency of the evidence by failing to raise a Rule 50(a) or 50(b) motion or argue plain error. The court also found that Brothers' objections to the jury instructions were waived as she had not distinctly stated her objections and grounds for them at the district court. Lastly, the court found no abuse of discretion by the district court in denying Brothers' motion to contact the jury. The judgment of the district court was affirmed. View "Brothers v. Johnson" on Justia Law

This case arose from a raid by U.S. Immigration and Customs Enforcement (ICE) at Abel Ramirez-Peñaloza’s family home in Heber City, Utah. After Mr. Ramirez-Peñaloza was indicted for unlawful entry into the U.S., ICE officials attempted to arrest him at his home. During two searches of his home, officials detained and questioned his family members. The plaintiffs, some of Mr. Ramirez-Peñaloza’s family members who were detained during the searches, filed claims against the U.S. and the agents alleging Fourth Amendment and state law violations.The district court dismissed most of the plaintiffs’ claims, but allowed three claims to go to trial, where a jury returned a verdict in favor of the officers. The plaintiffs appealed the district court’s grant of summary judgment in favor of the officers on the excessive use of force and false arrest claims.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the dismissed claims were barred by the Federal Tort Claims Act’s (FTCA) judgment bar, which precludes suits against federal employees after the entry of final judgment on a claim against the U.S. for an analogous cause of action. Since the district court entered final judgment in favor of the U.S. on the plaintiffs’ analogous FTCA claims, the claims against the individual defendants were barred. View "Ramirez v. Reddish" on Justia Law

The case involves three transgender individuals, Rowan Fowler, Allister Hall, and Carter Ray, who sued the Governor of Oklahoma, the Commissioner of Health for the Oklahoma State Department of Health, and the State Registrar of Vital Records. The plaintiffs challenged an executive order issued by the Governor that directed the Oklahoma State Department of Health to stop amending sex designations on birth certificates. The plaintiffs, who had obtained court orders directing that their sex designations on official documents be amended, had their applications for amended birth certificates denied by the Department of Health, citing the Governor's executive order.The plaintiffs filed a lawsuit alleging that the policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment. The district court dismissed the case, ruling that the plaintiffs failed to state a claim. The plaintiffs appealed the decision.The United States Court of Appeals for the Tenth Circuit reversed the district court's dismissal of the equal protection claim, but affirmed the dismissal of the plaintiffs' substantive due process claim. The court found that the policy of denying sex-designation amendments on birth certificates was not rationally related to any legitimate state interest and therefore violated the Equal Protection Clause. However, the court affirmed the dismissal of the plaintiffs' substantive due process claim, concluding that the plaintiffs failed to allege that their involuntary disclosures of their transgender status amounted to state action. View "Fowler v. Stitt" on Justia Law

Anthony Buntyn, an employee of a private company that transported detainees for law enforcement agencies, was charged with willfully violating the detainees' rights under the Fourteenth Amendment's due process clause due to inhumane conditions of confinement. The conditions developed while Buntyn transported the detainees in a van to various detention facilities. The government alleged that Buntyn had violated the Fourteenth Amendment's due process clause through deliberate indifference to intolerable conditions of confinement and that this indifference had resulted in bodily injury to three detainees. The jury found Buntyn guilty of depriving the detainees of humane conditions, acting willfully and with deliberate indifference, and causing bodily injury to one detainee.Buntyn appealed his conviction to the United States Court of Appeals for the Tenth Circuit, arguing that the evidence was insufficient for a finding of guilt, that the district court erred in preventing his attorney from using the term malice in closing argument, and that the court coerced the jury to reach a verdict. The Tenth Circuit rejected Buntyn's arguments and affirmed his conviction. The court found that the evidence was sufficient to support the jury's findings of inhumane conditions, deliberate indifference, and willfulness. The court also found that the district court did not err in prohibiting the use of the term malice in closing argument, and that Buntyn had waived his challenge to the district court's instruction for the jury to continue deliberating. View "United States v. Buntyn" on Justia Law

The plaintiff, Gary Avant, was a truck driver for Muskogee County. County officials believed that Avant was complaining to other citizens about the county’s road plan and the assignment of a county worker. Avant was subsequently fired by the county commissioner. Avant sued the commissioner under 42 U.S.C. § 1983, claiming retaliation in violation of the First Amendment. However, during the litigation, Avant denied making the statements that led to his firing. The commissioner moved for summary judgment, arguing that the perceived speech hadn’t involved a matter of public concern. The district court denied this part of the motion, and the case was remanded for the district court to develop the record.After remand, the district court again denied summary judgment, leading the commissioner to appeal again. On appeal, the commissioner argued that Avant hadn’t pleaded a claim for perceived speech and that qualified immunity applies given the lack of precedent on how to assess a public concern for perceived speech.The United States Court of Appeals for the Tenth Circuit found that it lacked jurisdiction to consider the adequacy of the pleadings. However, it did have jurisdiction over the commissioner’s argument for reversal based on the absence of a clearly established violation. The court concluded that Avant had not shown that the perceived speech involved a clearly established public concern. Therefore, the commissioner was entitled to qualified immunity, and the court reversed the denial of qualified immunity and remanded the case for the district court to grant summary judgment to the commissioner in his personal capacity on the First Amendment claim for retaliation based on perceived speech. View "Avant v. Doke" on Justia Law

The case involves Alonzo Cortez Johnson, a state prisoner who petitioned for federal habeas relief under 28 U.S.C. § 2254. Johnson, a Black man, claimed that his constitutional rights were violated because the state court failed to follow the appropriate procedural steps under Batson v. Kentucky, which prohibits racial discrimination in jury selection. Johnson alleged that the prosecutor had exercised peremptory strikes based on race. The Tenth Circuit Court of Appeals agreed that the state court had mishandled the Batson procedural framework and remanded the case to the district court to hold a Batson reconstruction hearing, unless doing so would be impossible or unsatisfactory.On remand, the district court granted Johnson conditional habeas relief, deciding that holding a Batson reconstruction hearing would be “both impossible and unsatisfactory.” The court reasoned that it could not sufficiently reconstruct all relevant circumstances to meaningfully apply Batson’s third step, which involves determining whether the prosecutor’s stated reasons for the strikes were actually a pretext for discrimination.The Tenth Circuit Court of Appeals disagreed with the district court's decision. The court found that the district court had enough evidence to hold a Batson reconstruction hearing at step two, which involves the prosecution providing a race-neutral reason for the objected-to strike(s). The court concluded that the district court had applied the “impossible or unsatisfactory” standard too harshly and remanded the case back to the district court to hold a Batson reconstruction hearing. View "Johnson v. Rankins" on Justia Law

The case involves a lawsuit filed by the parents of Shamikle Jackson against four police officers for using unconstitutionally excessive force. Jackson had called 911, claiming that two people were dead inside an apartment and that he was holding others hostage. When the police arrived, they encountered Jackson's sister who informed them that Jackson was alone, unarmed, and might have mental health problems. However, as the officers proceeded to search the apartment, Jackson emerged from a bedroom with a machete and was shot and killed by the officers.The United States District Court for the District of Colorado denied the officers' motion for summary judgment based on qualified immunity. The court concluded that a reasonable jury could find that the officers recklessly created the need to use deadly force, thereby unreasonably violating Jackson's constitutional rights under clearly established law.The United States Court of Appeals for the Tenth Circuit reversed the lower court's decision. The appellate court found that the officers had a split second to respond to a deadly threat posed by Jackson. Under these circumstances, it was not clearly established that the officers recklessly created a situation where the use of deadly force was necessary. Therefore, the officers were entitled to qualified immunity. The court also rejected the claim that the other officers failed to intervene to prevent the violation of Jackson's rights, as there was no underlying constitutional violation. View "Flores v. Henderson" on Justia Law