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

Raul Guzman was living in a camper trailer parked on property in Albuquerque, New Mexico, where the City had declared two buildings substandard and posted notices prohibiting anyone from residing in the structures or on the property. Despite these warnings, Guzman stayed in the trailer with the property owner’s permission. In September 2022, city code enforcement officers, accompanied by police, inspected the property. Upon finding Guzman in the trailer, officers entered, detained him, and discovered a firearm inside.A grand jury indicted Guzman for being a felon in possession of a firearm. He moved to suppress the evidence, arguing he had a reasonable expectation of privacy in the trailer because he had the owner’s permission to stay there and the posted notices did not specifically mention the trailer. The United States District Court for the District of New Mexico held an evidentiary hearing and denied the motion. The court found that, although Guzman may have had a subjective expectation of privacy, this expectation was not objectively reasonable because the posted notices made clear that residing on the property was unlawful. The court also found, in the alternative, that exceptions to the warrant requirement would have justified the officers’ actions. Guzman subsequently pleaded guilty but reserved the right to appeal the suppression ruling.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 Guzman lacked Fourth Amendment standing to challenge the search because he did not have a reasonable expectation of privacy in the trailer. The court reasoned that, given the explicit posted notices prohibiting residence on the property and Guzman’s admission that he read them, society would not recognize his expectation of privacy as reasonable. The court therefore affirmed the denial of the suppression motion. View "United States v. Guzman" on Justia Law

Several minors diagnosed with gender dysphoria, their parents, and a physician challenged an Oklahoma law (SB 613) that prohibits healthcare providers from administering gender transition procedures—including puberty blockers and cross-sex hormones—to individuals under eighteen. The law defines these procedures as medical or surgical interventions intended to affirm a minor’s gender identity when it differs from their biological sex. The statute does not ban mental health counseling or certain other medical treatments. The plaintiffs, all affected by the law’s restrictions, argued that SB 613 violated their constitutional rights.The United States District Court for the Northern District of Oklahoma denied the plaintiffs’ request for a preliminary injunction, finding they had not demonstrated a likelihood of success on the merits of their claims. The plaintiffs appealed this decision to the United States Court of Appeals for the Tenth Circuit. While the appeal was pending, the Tenth Circuit paused proceedings to await the Supreme Court’s decision in United States v. Skrmetti, which addressed a similar Tennessee law.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of a preliminary injunction. The court held that SB 613 does not violate the Equal Protection Clause because it classifies based on age and medical use, not sex or transgender status, and is subject to rational basis review. The court found Oklahoma’s interest in the health and welfare of minors provided a rational basis for the law. The court also rejected the substantive due process claim, concluding that there is no fundamental right for parents to access gender transition procedures for their children, and that the law is rationally related to a legitimate state interest. The court found no evidence of invidious discriminatory intent by the legislature. View "Poe v. Drummond" on Justia Law

In 2021, Ralph Marcus Hardy, an inmate at Adams County Detention Facility (ACDF) in Colorado, fell from his wheelchair and suffered serious injuries. Despite his repeated requests for medical attention, jail officials allegedly ignored his pleas. Hardy claims that Detention Specialist Daniel DeHerrera ignored emergency distress signals from his cell, and Deputy Dennis Rabie, who later found Hardy in pain, also failed to provide medical assistance.The United States District Court for the District of Colorado reviewed the case. Deputy Rabie and Detention Specialist DeHerrera moved to dismiss Hardy’s claims, asserting qualified immunity. The district court denied their motion, finding that Hardy plausibly alleged violations of his Fourteenth Amendment rights. The court held that the defendants were not entitled to qualified immunity, leading to this appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Hardy sufficiently alleged that both Deputy Rabie and Detention Specialist DeHerrera acted with deliberate indifference to his medical needs. The court found that Hardy’s constitutional rights were violated and that these rights were clearly established at the time of the incident. The court concluded that both defendants were aware of Hardy’s serious medical needs and failed to take reasonable measures to address them, thus denying them qualified immunity. View "Hardy v. Rabie" on Justia Law

Cody Byron Teerlink was convicted of making a false statement during the acquisition of a firearm. He had previously pleaded guilty to a third-degree felony for driving under the influence in Utah and completed his probation successfully. Despite being eligible for a reduction of his felony to a misdemeanor under Utah law, he did not apply for it. In 2021, Teerlink attempted to purchase firearms on three occasions, falsely stating on ATF Form 4473 that he had not been convicted of a felony. He was able to purchase a rifle once due to a system glitch but was denied on the other two attempts.The United States District Court for the District of Utah directed the parties to agree on jury instructions. The parties jointly submitted an instruction defining "proof beyond a reasonable doubt," which included language criticized by the Tenth Circuit and the Supreme Court. The jury convicted Teerlink on one count of making a false statement during the acquisition of a firearm and acquitted him on the other counts. He was sentenced to eight months' imprisonment.The United States Court of Appeals for the Tenth Circuit reviewed the case. Teerlink argued that the jury instruction lowered the government's burden of proof, violating his Fifth Amendment rights. However, the court held that Teerlink invited any alleged error by jointly submitting the instruction and failing to object at trial. The court emphasized that parties cannot propose jury instructions and later challenge them on appeal. The court also rejected Teerlink's argument that a footnote in the jury instructions preserved his right to plain-error review, stating that such a footnote cannot immunize a party from the invited-error doctrine. The Tenth Circuit affirmed the district court's decision. View "United States v. Teerlink" on Justia Law

Eric Coomer, Ph.D., the former Director of Product Strategy and Safety at Dominion Voting Systems, Inc., filed a defamation lawsuit against several defendants, including Make Your Life Epic, LLC, Reopen America, LLC, and Clayton Thomas Clark. Joseph Oltmann, a nonparty to the lawsuit, was subpoenaed to testify and produce documents. Oltmann initially appeared for his deposition but left without authorization and later boasted about his actions on his podcast, disparaging the magistrate judge and suggesting violence.The United States District Court for the District of Colorado held Oltmann in civil contempt for failing to comply with the subpoena and court orders. The court imposed a $1,000 per day fine until Oltmann complied and ordered him to pay attorney’s fees and costs. Oltmann appealed the Contempt Order, arguing that he properly invoked the newsperson’s privilege and that his due process rights were violated because the district court did not hold a hearing before issuing the Contempt Order.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s Contempt Order. The appellate court held that Oltmann waived his arguments by not raising them specifically in his objections to the magistrate judge’s recommendations. The court also found that the district court did not abuse its discretion in issuing the Contempt Order without a second hearing, as the material facts were undisputed. The appellate court further imposed sanctions on Oltmann, ordering him to pay Coomer’s reasonable expenses, including attorney’s fees and costs associated with the appeal, and remanded the case to the district court to determine the amount. View "Coomer v. Make Your Life Epic" on Justia Law

Defendants Jerrold Chavarria and Jerry Romero were accused of kidnapping and murdering a woman in Eddy County, New Mexico. They were charged with the federal crime of kidnapping resulting in death under 18 U.S.C. § 1201(a). The indictment claimed that the defendants used a motor vehicle, a Jeep, as an instrumentality of interstate commerce in committing the crime. However, the indictment did not provide details on how the kidnapping affected interstate commerce.The United States District Court for the District of New Mexico dismissed the superseding indictment, ruling that it lacked an adequate nexus to interstate commerce. The court found that the use of a motor vehicle alone, without more, was insufficient to establish federal jurisdiction under the Commerce Clause.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that not all motor vehicles are per se instrumentalities of interstate commerce. It emphasized that for an object to be considered an instrumentality of interstate commerce, it must serve the end of commerce. The court found that the government’s indictment was insufficient because it did not allege how the use of the motor vehicle in this case affected interstate commerce. The Tenth Circuit affirmed the district court’s dismissal of the superseding indictment, concluding that the federal kidnapping statute did not apply in this instance due to the lack of a sufficient connection to interstate commerce. View "United States v. Chavarria" on Justia Law

On December 21, 2022, Oklahoma City Police officers received a tip that Karen Gonzalez, who had an outstanding arrest warrant, was at a Days Inn. Officers surveilled the area and followed a car they believed she entered to a gas station. They confirmed her identity and arrested her. Jonas Tyler, who was near the car, was detained, handcuffed, and placed in a police car. Despite his compliance and lack of suspicion, officers detained him further while waiting for a K-9 unit, which eventually led to the discovery of a firearm and drugs in his car.The United States District Court for the Western District of Oklahoma denied Mr. Tyler's motion to suppress the evidence found in his car, ruling that his continued detention was reasonable. Mr. Tyler then entered a conditional guilty plea to possession of a firearm by a previously convicted felon, reserving his right to appeal the suppression ruling. He was sentenced to 84 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case and found that Mr. Tyler's continued detention after the arrest of Ms. Gonzalez was unreasonable and violated his Fourth Amendment rights. The court held that the government did not have a sufficient justification for detaining Mr. Tyler beyond the initial arrest of Ms. Gonzalez, as there was no reasonable suspicion of wrongdoing or dangerousness on his part. Consequently, the court vacated Mr. Tyler's conviction and sentence and remanded the case for further proceedings consistent with their opinion. View "United States v. Tyler" on Justia Law

Andy Nahkai was charged with two counts of abusive sexual contact with a child and one count of abusive sexual contact with a child aged 12-16, all occurring within Indian country. During the investigation, Nahkai made incriminating statements to law enforcement officers while being interviewed in an unlocked police vehicle parked outside his home. The officers did not administer Miranda warnings before the interview.The United States District Court for the District of Utah granted Nahkai’s motion to suppress the statements he made during the interview. The court concluded that the interrogation was custodial, and the statements were not voluntary under the Fifth Amendment. The court based its decision on the officers' failure to inform Nahkai that he was free to leave, the accusatory nature of the questioning, and the police-dominated atmosphere of the encounter.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that Nahkai was not in custody for purposes of Miranda v. Arizona. The court found that the totality of the circumstances did not support the conclusion that Nahkai’s freedom of action was curtailed to a degree associated with formal arrest. The court noted that Nahkai was not physically restrained, the vehicle doors were unlocked, and the questioning, although accusatory, was not unusually confrontational. The court reversed the district court’s order suppressing Nahkai’s statements and remanded the case for further proceedings. View "United States v. Nahkai" on Justia Law

Barry Jackson was convicted of illegally possessing two firearms as a domestic violence misdemeanant. After his conviction, but before pleading guilty, he was found with three additional firearms, one of which had a large-capacity magazine. Jackson challenged the constitutionality of 18 U.S.C. § 922(g)(9) and the reasonableness of his sentence.The United States District Court for the Western District of Oklahoma denied Jackson's motion to declare § 922(g)(9) unconstitutional. Jackson then pleaded guilty without a plea agreement. At sentencing, the court determined that Jackson's possession of firearms on two separate occasions constituted relevant conduct, leading to a higher advisory Sentencing Guidelines range. Jackson was sentenced to 72 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that § 922(g)(9) is constitutional as applied to Jackson, consistent with the principles established in United States v. Rahimi and United States v. Rogers. The court found that Jackson's prior domestic violence convictions demonstrated a propensity for violence, justifying his disarmament under § 922(g)(9). The court also upheld the district court's determination that Jackson's possession of additional firearms was relevant conduct, supporting the sentence imposed.The Tenth Circuit affirmed the district court's judgment of conviction and sentence, concluding that the sentence was both procedurally and substantively reasonable. View "United States v. Jackson" on Justia Law

Craig Gordon and Ronald Darnell Brown were each indicted for possession of a firearm while subject to a court order that explicitly prohibited the use, attempted use, or threatened use of physical force against an intimate partner or child. Gordon had threatened his ex-partner and caused minor injuries to his daughter, leading to a protective order against him. Brown had violently attacked his girlfriend, resulting in a protective order that also prohibited him from possessing firearms. Both were found in possession of firearms after these orders were issued.The United States District Court for the District of Utah denied their motions to dismiss the indictments, which argued that 18 U.S.C. § 922(g)(8)(C)(ii) was facially unconstitutional under the Second Amendment. The defendants then entered conditional pleas, preserving their rights to appeal the district court’s decisions. After sentencing, they appealed, and their appeals were abated pending the Supreme Court’s decision in United States v. Rahimi. Following the Supreme Court’s decision, the appeals were resumed.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that 18 U.S.C. § 922(g)(8)(C)(ii) is not facially unconstitutional under the Second Amendment. The court reasoned that the statute is constitutional in some of its applications, particularly when a protective order is issued based on a judicial determination that the individual poses a threat of physical violence. The court emphasized that the statute aims to mitigate demonstrated threats of physical violence and does not broadly restrict arms use by the public. The court affirmed the convictions of both defendants. View "United States v. Gordon" on Justia Law