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

Jimmy Lee Brooks was convicted by a jury of being a felon in possession of ammunition and witness tampering. The incident involved Brooks becoming irate at a beauty supply store, threatening his girlfriend S.J. with a knife, and subsequently shooting at a vehicle she was in, injuring her. Brooks was arrested after a search led police to his cousin's apartment, where he had expressed intent to kill S.J. and her family.The United States District Court for the Western District of Oklahoma sentenced Brooks to 235 months in prison, applying a cross-reference to the sentencing guidelines for attempted murder, which requires a finding of specific intent to kill. Brooks appealed, arguing that there was insufficient evidence to support the finding of specific intent to kill.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court noted that the district court had found by a preponderance of the evidence that Brooks shot at S.J. with the specific intent to kill her. The Tenth Circuit affirmed the district court's decision, stating that the evidence, including surveillance footage and witness testimony, supported the finding that Brooks acted with specific intent to kill. The court emphasized that firing a gun at another person can support an inference of intent to kill and found that the district court did not err in applying the cross-reference for attempted murder. The Tenth Circuit thus affirmed Brooks' sentence. View "United States v. Brooks" on Justia Law

Defendant William Clayton Brown, while under the influence of methamphetamine, broke into a locked bathroom and fatally stabbed Damion Martin, who was embracing Brown's sister, Lacie Watson. Brown claimed he believed Martin was going to kill Watson. The Government charged Brown with First-Degree Murder in Indian Country. Brown requested jury instructions on defense of another and involuntary manslaughter, but the district court refused, citing insufficient evidence for the defense of another and omitting the involuntary manslaughter instruction without explanation.The United States District Court for the Eastern District of Oklahoma convicted Brown of first-degree murder. However, the court later granted Brown's Rule 29 motion for acquittal on the first-degree murder charge, finding insufficient evidence of premeditation, and entered a judgment of guilty for second-degree murder, sentencing Brown to life imprisonment followed by five years of supervised release.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the district court plainly erred by omitting the involuntary manslaughter instruction based on the theory of imperfect defense of another. The Tenth Circuit found that Brown presented sufficient evidence to warrant the instruction, as multiple witnesses testified that Brown believed Martin was going to harm Watson. The omission of this instruction affected Brown's substantial rights and the fairness of the judicial proceedings. Consequently, the Tenth Circuit reversed Brown's conviction and remanded the case for a new trial. View "United States v. Brown" on Justia Law

Coti D’Shayne Davis pled guilty to failing to register as a sex offender and was sentenced to 87 months’ imprisonment followed by 10 years of supervised release. In a prior appeal, the Tenth Circuit remanded the case to the district court for resentencing to allow Davis to allocute and to make specific findings concerning a special condition of supervised release. On remand, the district court allowed Davis to allocute, struck the special condition, but again imposed the same sentence.Davis appealed, challenging a two-point addition to his criminal history score based on a misdemeanor conviction for consumption of liquor by a minor. The district court had overruled Davis’s objection, construing it as an argument that the conviction should be considered a juvenile status offense and thus not counted in his criminal history score. The court concluded that the conviction did not fit the definition of a juvenile status offense because Davis was over 18 when it occurred.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that Davis’s underage drinking conviction, which he received at 20 years old, is “similar to” a juvenile status offense under the guidelines. The court reasoned that the elements of the offense and the conduct underlying the conviction were similar to a juvenile status offense, and that common sense dictated that the conviction should not be included in Davis’s criminal history score. The Tenth Circuit remanded the case to the district court with instructions to vacate Davis’s sentence and resentence him without the two-point addition. View "United States v. Davis" on Justia Law

Defendant Ted Joseph Valdez was involved in a conspiracy to transport two undocumented immigrants within the United States. After a car accident, he moved to Mexico and later accepted an offer to drive the immigrants for $1,000. He was followed by a border patrol agent for twenty-seven miles, during which he exhibited erratic driving behavior. Valdez confessed to knowing the immigrants were in the country illegally.Valdez pleaded guilty to the charge of conspiring to transport aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(ii). The United States District Court for the District of New Mexico calculated his base offense level as 12, with reductions for his minor role and acceptance of responsibility, resulting in a total offense level of 8 and a criminal history category of II. This recommended a sentencing range of four to ten months. Valdez requested a time-served sentence of six months, while the government sought a high-end sentence. The district court sentenced Valdez to twenty-four months, citing the 18 U.S.C. § 3553(a) factors and his criminal history.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court reiterated that the Sentencing Guidelines are advisory, not mandatory. The district court's decision to impose a sentence outside the Guidelines range was based on Valdez's criminal history, the need for deterrence, and public safety concerns. The Tenth Circuit found that the district court provided a thorough explanation for the upward variance, considering all relevant factors and justifying the sentence. The court affirmed the district court's decision, concluding that the sentence was substantively reasonable and within the bounds of permissible choice. View "United States v. Valdez" on Justia Law

David Leroy Earls was convicted by a jury on three counts of engaging in a sex act with a person incapable of appraising the nature of the conduct, specifically the intellectually disabled daughter of his long-time girlfriend. Earls admitted to having sex with the victim, C.P., and the primary questions at trial were whether C.P. was incapable of appraising the nature of the conduct and whether Earls knew of her incapacity. The jury resolved both questions against Earls.The United States District Court for the Eastern District of Oklahoma sentenced Earls to 140 months in prison. Earls appealed, arguing insufficient evidence for the jury's findings and alleging trial errors. The Tenth Circuit Court of Appeals reviewed the case. The court found sufficient evidence to support the jury's findings, including testimony about C.P.'s intellectual disability and mental illnesses, and Earls' own admissions. The court also found no abuse of discretion in the trial court's handling of expert testimony and rejected Earls' claims of prosecutorial misconduct during closing arguments.However, the Government conceded that the district court erred in calculating Earls' sentence by incorrectly adding two criminal history points. The Tenth Circuit affirmed Earls' convictions but remanded the case to the district court to vacate Earls' sentence and resentence him consistent with their opinion. View "United States v. Earls" on Justia Law

Cledale Caldwell pled guilty to failing to register as a sex offender, a federal offense that spanned 13 months. During this period, he was convicted and sentenced for two separate offenses in Oklahoma. At sentencing for the failure-to-register offense, the district court assessed criminal history points for the Oklahoma offenses. Caldwell objected, arguing that these offenses should be considered relevant conduct, which would result in a lower sentencing range under the United States Sentencing Guidelines. The district court disagreed, leading to this appeal.The United States District Court for the District of Kansas sentenced Caldwell under the 2023 Guidelines Manual. The court included Caldwell’s Oklahoma offenses in his criminal history, resulting in a total of 11 criminal history points and a Guidelines range of 21 to 27 months. Caldwell argued that the Oklahoma offenses should be treated as relevant conduct because they occurred during the commission of the SORNA offense, which would have reduced his criminal history points and the corresponding sentencing range.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that relevant conduct under U.S.S.G. § 1B1.3(a)(1)(A) includes acts or omissions that occurred during the commission of the offense of conviction but must also relate to that offense. The court found that Caldwell’s Oklahoma offenses did not relate to his failure-to-register offense and were therefore correctly included in his criminal history. The Tenth Circuit affirmed the district court’s decision, maintaining Caldwell’s sentence of 21 months in prison. View "United States v. Caldwell" on Justia Law

In 2017, Raymond Lee Goldesberry's daughter, K.G., who was almost 12 years old, entered her parents' bedroom after a nightmare and climbed into bed next to her father, who was asleep. During the night, K.G. awoke to find her father touching her inappropriately. K.G. believed her father was asleep and mistook her for her mother. About four years later, the government prosecuted Goldesberry for aggravated sexual abuse of a minor under 12 in Indian Country.In October 2021, Goldesberry was charged in the United States District Court for the Northern District of Oklahoma. He pleaded not guilty, and the case proceeded to a jury trial in March 2022. The jury found Goldesberry guilty, and the district court denied his motion for acquittal. Goldesberry was sentenced to 30 years' imprisonment, the mandatory minimum under 18 U.S.C. § 2241(c).The United States Court of Appeals for the Tenth Circuit reviewed the case. Goldesberry appealed on the grounds of insufficient evidence and prosecutorial misconduct. The Tenth Circuit focused on the sufficiency of the evidence, particularly the knowledge element of the charged offense. The court concluded that the evidence presented was insufficient to establish beyond a reasonable doubt that Goldesberry knowingly engaged in the sexual act, as the evidence equally supported the theory that the touching occurred by mistake.The Tenth Circuit vacated Goldesberry's conviction and remanded the case for further proceedings, holding that the government failed to prove the knowledge element of the offense beyond a reasonable doubt. View "United States v. Goldesberry" on Justia Law

Defendant Stetson Bruce was convicted of two counts of aggravated sexual abuse in Indian country for sexually abusing his five-year-old son, R.W. The trial included testimony from R.W. and his half-sister, E.R., who witnessed one of the acts. After their testimonies, the United States District Court for the Eastern District of Oklahoma admitted recordings of their forensic interviews, which were consistent with their trial testimonies. These recordings were not played in the courtroom but were available to the jury during deliberations.The district court denied Defendant's pretrial motion to exclude the recordings as hearsay, ruling they would be admitted upon proper foundation testimony. During the trial, the defense suggested that R.W. had been coached by the prosecutor and that E.R.'s memory was faulty. The district court admitted the recordings under Rule 801(d)(1)(B) of the Federal Rules of Evidence, allowing prior consistent statements to rebut charges of recent fabrication or to rehabilitate credibility when attacked on another ground. The jury found Defendant guilty on both counts, and he was sentenced to concurrent life terms.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting the recordings as prior consistent statements under Rule 801(d)(1)(B)(i) and (ii). The court found that the defense's suggestions of coaching and faulty memory opened the door for the government to use the prior consistent statements to rebut these charges. The court also rejected Defendant's arguments that the district court ruled prematurely on the admission of the recordings and that it committed structural error by sending the recordings to the jury room rather than playing them in court. The Tenth Circuit affirmed the district court's decision. View "U.S. v. Bruce" on Justia Law

The case involves Calvin Woodmore, who was convicted for his role in a methamphetamine-trafficking ring in eastern Oklahoma. Woodmore was found guilty of conspiracy to commit drug trafficking, conspiracy to commit money laundering, and money laundering. He appealed his convictions and sentence, arguing that the district court made several errors during his trial and sentencing.In the lower court, the United States District Court for the Eastern District of Oklahoma handled the case. Woodmore was convicted by a jury on all counts. He then moved for a judgment of acquittal, arguing that the government had not provided sufficient evidence to support the money laundering charges. The district court denied his motion and sentenced him to 324 months in prison for the drug trafficking conspiracy and 240 months for the money laundering charges, to be served concurrently.The United States Court of Appeals for the Tenth Circuit reviewed the case. Woodmore raised several issues on appeal, including the district court's failure to properly instruct the jury on the definition of "methamphetamine (actual)" and the right of attorneys to interview witnesses. He also challenged the sufficiency of the evidence supporting his money laundering convictions and the district court's calculation of his sentence.The Tenth Circuit affirmed the district court's decisions. The appellate court found that the jury instructions were adequate and that the evidence presented at trial was sufficient to support Woodmore's convictions. The court also upheld the district court's calculation of the drug quantity attributable to Woodmore and the application of sentencing enhancements. Consequently, the Tenth Circuit affirmed Woodmore's convictions and sentence. View "United States v. Woodmore" on Justia Law

Law enforcement identified the defendant as a supplier of methamphetamine and fentanyl in a drug-trafficking conspiracy in Kansas City. After seizing three pounds of methamphetamine from a car en route to the defendant, DEA agents enlisted the driver to continue the delivery to the defendant. The defendant was arrested upon arrival to collect the drugs. During custody, the defendant made incriminating statements and consented to a search of his cell phone. He later moved to suppress these statements and the phone's contents.The United States District Court for the District of Kansas denied the suppression motions. The court ruled that the defendant's pre-Miranda statement about his cell phone number was admissible under the inevitable-discovery doctrine. It also found that the defendant voluntarily and knowingly waived his Miranda rights and that his post-Miranda statements were not coerced. The court concluded that the defendant's consent to the cell phone search was voluntary.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the inevitable-discovery doctrine applied to the pre-Miranda statement. It found that the defendant voluntarily and knowingly waived his Miranda rights, and his statements were not coerced. The court also held that the defendant's consent to the cell phone search was voluntary. The Tenth Circuit concluded that the totality of the circumstances supported the district court's findings and affirmed the denial of suppression. View "United States v. Perez" on Justia Law