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

The case involves Angel Landa-Arevalo, who was indicted for conspiracy to distribute and possess with intent to distribute fifty grams or more of methamphetamine. He was tried alongside nine co-defendants. Landa-Arevalo was in pretrial confinement for 1,196 days, during which he objected to the protracted timeline and moved to sever his trial from his co-defendants to protect his Sixth Amendment right to a speedy trial. He also requested a mental competency hearing, arguing that his Fifth Amendment rights were violated by not providing him with a second, more extensive evaluation.The district court denied his motions and proceeded with the trial. A forensic psychologist was appointed to examine Landa-Arevalo and concluded that he was competent to stand trial. The court found him competent and proceeded with sentencing.On appeal to the United States Court of Appeals for the Tenth Circuit, Landa-Arevalo argued that the district court violated his Fifth Amendment rights by not ordering a second competency evaluation and his Sixth Amendment right to a speedy trial. The appellate court affirmed the district court's decision. It held that the district court did not abuse its discretion in determining Landa-Arevalo's competency and denying another evaluation. The court also found that Landa-Arevalo's Sixth Amendment right to a speedy trial was not violated, as the delays were caused by co-defendants and not the government. View "United States v. Landa-Arevalo" 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

The case involves Scott Johnson, Harlene Hoyt, and Covey Find Kennel, LLC, who challenged the constitutionality of a Kansas statute that allows warrantless inspections of their homestead, where Mr. Johnson operates a business that houses and trains bird dogs. They also claimed that their constitutional right to travel was infringed by a statutory requirement that they make the premises available for inspection within 30 minutes of the arrival of an inspector. The United States District Court for the District of Kansas dismissed their complaint for failure to state a claim.The United States Court of Appeals for the Tenth Circuit affirmed the dismissal of their right-to-travel claim but remanded for further proceedings to determine whether Mr. Johnson’s business is closely regulated and, if so, whether warrantless inspections are reasonable under the Fourth Amendment. The court found that the boarding or training kennel industry was not clearly closely regulated, and the government had not shown that warrantless searches were necessary. The court also held that the regulations did not impose burdens beyond those commonly borne by owners of businesses who travel away from the locations of their businesses, and thus did not violate the plaintiffs' right to travel. View "Johnson v. Smith" on Justia Law

Leachco, Inc., an Oklahoma corporation that manufactures and markets various products, appealed the denial of its request for a preliminary injunction to halt administrative enforcement proceedings by the Consumer Product Safety Commission (CPSC). Leachco argued that the statutory removal protections for CPSC commissioners and administrative law judges (ALJs) violated Article II of the Constitution and the separation of powers. The district court denied Leachco's motion for a preliminary injunction, stating that even if Leachco's constitutional arguments were valid, the alleged constitutional violations were insufficient to establish that Leachco would suffer "irreparable harm" if the injunction was denied.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that under current Supreme Court and Tenth Circuit precedent, Leachco's subjection to proceedings before an agency whose officials allegedly have unconstitutional protection against removal is insufficient, by itself, to establish irreparable harm. The court also found that Leachco failed to show that the removal protections for CPSC commissioners and its administrative law judge were unconstitutional. Therefore, Leachco failed to satisfy the irreparable harm requirement necessary to obtain a preliminary injunction. View "Leachco v. Consumer Product Safety Commission" on Justia Law

The case involves Jose Luis Amador-Bonilla, a citizen of Guatemala and Nicaragua, who was charged with violating 8 U.S.C. § 1326, Illegal Reentry After Removal from the United States. Amador-Bonilla had entered the United States without authorization multiple times and had been removed six times. He was arrested in Oklahoma and charged with illegal reentry, an offense for which he had already been convicted twice. He moved to dismiss the indictment, arguing that the illegal reentry provision of the Immigration and Nationality Act violates his right to equal protection under the Fifth Amendment.The United States District Court for the Western District of Oklahoma denied Amador-Bonilla's motion to dismiss the indictment. The court determined that rational basis review applied to Amador-Bonilla’s challenge and that the challenge failed because Amador-Bonilla failed to show there was no “rational relationship between the disparity of treatment and some legitimate governmental purpose.” The court also found that even if the Arlington Heights framework arguably applied, Amador-Bonilla “failed to demonstrate that [8 U.S.C. § 1326] was passed with a discriminatory purpose as a motivating factor.”The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that 8 U.S.C. § 1326 does not violate the Fifth Amendment. The court found that Amador-Bonilla failed to show that Congress enacted the provision in 1952 with a discriminatory purpose as a motivating factor. The court also noted that all parties agreed that the provision otherwise satisfies rational basis review. View "United States v. Amador-Bonilla" on Justia Law

In this case, law enforcement officers responded to a drug overdose at the home of Corban Elmore. After securing the scene and prohibiting anyone from entering the house, the officers waited almost eight hours before applying for a search warrant. Once they had a warrant, they searched Elmore’s home and discovered two firearms in his bedroom. Elmore, a convicted felon, entered a conditional guilty plea to being a felon in possession of a firearm and appealed the denial of his motion to suppress the firearms.The District Court for the District of Colorado denied Elmore's motion to suppress the firearms, finding no Fourth Amendment violation. The court determined that the officers reasonably seized Elmore’s home because they had probable cause to believe the home contained evidence of drug possession and had good reason to fear that evidence would be destroyed before they could secure a search warrant. The court also concluded that the officers acted reasonably throughout the seizure, finding it appropriate for them to prohibit anyone from entering the home and to delay obtaining a warrant so that the lead detective could focus on his investigation.The United States Court of Appeals for the Tenth Circuit reversed the lower court's decision. The appellate court held that the eight-hour seizure of Elmore’s home was unreasonable under the Fourth Amendment and that the exclusionary rule required suppression of the firearms. The court found that the officers made no effort to reconcile their law-enforcement needs with Elmore’s Fourth Amendment interests in his home and extended the seizure longer than reasonably necessary to diligently secure a warrant. The court remanded the case for further proceedings. View "United States v. Elmore" on Justia Law

The case involves a group of employees and students at the University of Colorado Anschutz Campus who challenged the university's COVID-19 vaccine mandate. The plaintiffs, identified as Jane Does 1-11 and John Does 1, 3-7, argued that the university's policies regarding religious exemptions from the vaccine mandate violated their First Amendment rights.The university initially allowed individuals to attest to their exemption based on religious beliefs using a simple form. However, in August 2021, the university implemented a new policy that required individuals seeking a religious exemption to provide additional information about their religious beliefs and to demonstrate that their religion opposes all immunizations. The university denied all of the plaintiffs' requests for religious exemptions under this policy and enforced the vaccine mandate against them.The plaintiffs filed a lawsuit seeking a preliminary injunction against the university's policies. The district court denied their motion, ruling that the plaintiffs had failed to show that they were likely to succeed on the merits of their claims. The plaintiffs appealed this decision.The United States Court of Appeals for the Tenth Circuit reversed the district court's decision. The appellate court found that the university's policies were not neutral or generally applicable and were likely motivated by religious animus. The court held that the policies violated the Free Exercise and Establishment Clauses of the First Amendment and were subject to strict scrutiny, which they did not survive. The court concluded that the plaintiffs were likely to succeed on the merits of their claims and that they were entitled to a preliminary injunction against the university's policies. View "Doe v. Board of Regents of the University of Colorado" on Justia Law

The case involves Douglas Smith, a non-Indian, who was convicted of involuntary manslaughter for an act he committed on his property located within the exterior boundaries of the Pueblo of Santa Clara. Smith shot and killed Maria Gallegos, who he saw trying to break into a trailer on his property. Prior to trial, Smith moved to dismiss the case for lack of federal jurisdiction, arguing that the federal district court lacked criminal jurisdiction over crimes committed on his property and that Congress acted outside its constitutional authority when it passed the Indian Pueblo Land Act Amendments of 2005. The district court denied his motion.Smith's case was appealed to the United States Court of Appeals for the Tenth Circuit. The appellate court had to decide whether federal criminal jurisdiction extends to land owned by a non-Indian within the exterior boundaries of a Pueblo. The court affirmed the district court's decision, concluding that Smith's property is Indian country under 18 U.S.C. § 1151, and therefore, his crime is subject to federal criminal jurisdiction under 18 U.S.C. § 1152.Smith also claimed that the 2005 Amendment is unconstitutional as applied to him. The court disagreed, holding that the 2005 Amendment did not unconstitutionally extend federal criminal jurisdiction to Smith's land. The court reasoned that the 2005 Amendment only exercised preexisting federal jurisdiction over Smith's land and was thus not an unconstitutional enactment as applied to Smith.Lastly, Smith contended that the district court erred in declining his request for a two-level sentence reduction for accepting responsibility for his crime. The appellate court found no clear error in the district court's determination, noting that Smith had challenged the factual element of intent at trial, which provided a clear basis to conclude that he did not accept responsibility. The court affirmed the district court's decision. View "United States v. Smith" on Justia Law

In 2021, the Colorado state legislature passed The Ballot Measure Fiscal Transparency Act, which required certain language to be included in state-imposed titles of citizen-initiated ballot measures. If the proposal contained a tax change affecting state or local revenues, the measure’s title had to incorporate a phrase stating the change’s impact on state and district funding priorities. In 2023, Advance Colorado proposed two tax reduction measures subject to the provisions of the Act. After Colorado’s Ballot Title Setting Board included the mandated transparency language in each initiative’s title, Advance Colorado filed suit challenging the Act as unconstitutionally compelling its political speech.The United States District Court for the District of Colorado denied Advance Colorado's request for a preliminary injunction, concluding that the titling process qualified as government speech and, therefore, Advance Colorado was not likely to succeed on the merits of its claims. The court considered the factors used for determining the boundary between government and private speech as outlined in Shurtleff v. City of Bos., 596 U.S. 243, 252 (2022). It concluded that the history of the expression, the public’s likely perception as to who is speaking, and the extent to which the government has shaped the expression all indicated Colorado’s titling system was government speech not subject to a First Amendment compelled speech claim.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision, agreeing that the Act’s requirements did not result in improperly compelled speech under the First Amendment of the United States Constitution. The court found that the Colorado initiative titling system squarely qualified as government speech and Advance Colorado had not otherwise shown its own speech was improperly compelled by the government speech. Therefore, it could not demonstrate a substantial likelihood of success on the merits of its claims. View "Advance Colorado v. Griswold" on Justia Law

The case involves an insurance dispute between Travelers Casualty Insurance Company of America and A-Quality Auto Sales, Inc., along with its owners, Felicia and Shawn Richesin. The Richesins purchased a Subaru for resale through their dealership, A-Quality Auto Sales. After having the car inspected and repaired by RNS Auto Services, they experienced mechanical issues while driving it. Ms. Richesin was severely injured when she exited the vehicle on the side of the highway and was struck by another car. RNS had a garage insurance policy with Travelers, which provided commercial general liability coverage with a per-occurrence limit of $500,000 and a general aggregate limit of $1,000,000. The Richesins sought additional compensation from RNS and Travelers for Ms. Richesin's injuries.In the lower courts, the Richesins filed a suit against Travelers and other parties in New Mexico state court. The state court dismissed all claims against Travelers, citing a lack of privity between the injured party and the insurer. Later, the Richesins and RNS entered into agreements that led to Travelers paying the Richesins $500,000, which Travelers believed to be the policy limit. The Richesins, however, argued that there were multiple occurrences and therefore the policy's aggregate limit of $1,000,000 was available. Travelers then filed a complaint in federal district court seeking a judicial declaration that the accident was a single occurrence and the policy coverage limit for the accident was $500,000.The United States Court of Appeals for the Tenth Circuit affirmed the district court's entry of declaratory judgment. The court held that the dispute was ripe for resolution under Article III of the Constitution. It also ruled that the district court did not err by declining to abstain under the Brillhart and Younger abstention doctrines. The court further held that the district court did not err by denying the Richesins' Rule 56(d) motion, thereby denying them discovery needed to meaningfully oppose Travelers' motion for summary judgment. The court concluded that the accident was a single occurrence and the policy coverage limit for the accident was $500,000. View "Travelers Casualty Insurance Co. of America v. A-Quality Auto Sales" on Justia Law