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

A physician employed jointly by a Kansas hospital and its parent health system alleged that he was fired and later reported to the state medical licensing board in retaliation for reporting another doctor’s alleged sexual harassment of nurses. The physician had served in various roles at the hospital, including as Chief Medical Officer, and had made a formal complaint about a colleague’s conduct. After an internal investigation into an unrelated anonymous complaint about the physician’s own conduct, the hospital terminated his employment and subsequently referred several of his cases for outside peer review, which led to reports being filed with the state licensing board.The United States District Court for the District of Kansas granted summary judgment to the hospital and health system on the physician’s Title VII retaliation claims, finding that he could not show the reasons for his termination or the reports to the licensing board were pretextual. The court also declined to exercise supplemental jurisdiction over related state law claims. The physician appealed.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. It held that the physician presented sufficient evidence for a reasonable jury to find that the hospital’s internal investigation and subsequent actions were motivated by retaliatory animus, particularly under a “cat’s paw” theory, where biased subordinates influenced the ultimate decisionmakers. The court found genuine disputes of material fact regarding whether the stated reasons for termination and reporting were pretextual, including evidence of disparate treatment and an unfair investigation. The Tenth Circuit reversed the grant of summary judgment on both Title VII retaliation claims and remanded for further proceedings. It also directed the district court to reconsider whether to exercise supplemental jurisdiction over the state law claims. View "Byrnes v. St. Catherine Hospital" on Justia Law

An attorney based in Oklahoma developed a business model to help out-of-state clients enter the state’s medical marijuana industry, which is governed by strict residency and disclosure requirements. He created a two-entity structure: one company, with nominal Oklahoma-resident owners, obtained the necessary state licenses, while a second company, owned and operated by out-of-state clients, ran the actual marijuana operations. The attorney did not disclose the true ownership structure to state authorities, and in some cases, marijuana was grown before the required state registrations were obtained. State authorities began investigating after noticing irregularities, such as multiple licenses listing the same address and repeated use of the same Oklahoma residents as owners, many of whom had little or no involvement in the businesses.Oklahoma state prosecutors charged the attorney with multiple felonies related to his business practices, including conspiracy and submitting false documents. While those charges were pending, a federal grand jury indicted him for drug conspiracy and maintaining drug-involved premises, based on the same conduct. In the United States District Court for the Western District of Oklahoma, the attorney moved to enjoin his federal prosecution, arguing that a congressional appropriations rider barred the Department of Justice from spending funds to prosecute individuals complying with state medical marijuana laws. The district court held an evidentiary hearing and denied the motion, finding that the attorney had not substantially complied with Oklahoma law, particularly due to nondisclosure of ownership interests and failure to obtain required registrations.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed. The court held that the appropriations rider does bar the Department of Justice from spending funds to prosecute private individuals who comply with state medical marijuana laws. However, the court found that the attorney failed to substantially comply with Oklahoma’s requirements, so the rider did not protect him. The court concluded that the district court did not abuse its discretion in denying the injunction. View "United States v. Stacy" 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

The case involves Early Willard Woodmore, III, who was convicted for his role in a methamphetamine distribution enterprise in eastern Oklahoma. The Drug Enforcement Administration (DEA) began investigating the Woodmore organization in 2018 after receiving a tip about methamphetamine shipments. Early Woodmore, along with his siblings Calvin and Amber, led the organization. They received methamphetamine from Kimberly Noel in California, who shipped the drugs concealed in everyday objects. The organization distributed the drugs in smaller quantities throughout eastern Oklahoma. Early Woodmore was arrested in April 2019 and continued to communicate with his sister Amber, who took over operations. The DEA intercepted a significant methamphetamine shipment in August 2019, leading to further charges.The United States District Court for the Eastern District of Oklahoma indicted Early Woodmore on five counts, including conspiracy to distribute methamphetamine and money laundering. He proceeded to a joint trial with his brother Calvin in April 2022. The jury convicted Early Woodmore on all counts, and he was sentenced to life imprisonment for the drug charges and 240 months for the money laundering charges, to run concurrently.The United States Court of Appeals for the Tenth Circuit reviewed the case. Early Woodmore raised three main challenges: judicial bias due to the district court's handling of a custody dispute during the trial, an erroneous jury instruction regarding the right of attorneys to interview witnesses, and the lack of a definitional instruction for "methamphetamine (actual)." The Tenth Circuit rejected all three challenges. The court found no judicial bias, upheld the jury instruction on attorney interviews, and determined that the term "methamphetamine (actual)" was sufficiently clear based on the evidence presented at trial. Consequently, the Tenth Circuit affirmed the district court's judgment of conviction. View "United States v. Woodmore" on Justia Law

Two elderly individuals, Ms. Penelope Lamle and Ms. Maxine Houston, applied for Medicaid but faced delays and additional questions from the Oklahoma Department of Human Services, allegedly directed by attorney Susan Eads. They refused to answer these questions and subsequently sued, seeking an expedited decision, payment of Medicaid benefits, and damages. Both applicants died during the litigation, and their estates were substituted as parties in the appeal.The United States District Court for the Western District of Oklahoma dismissed the action with prejudice, citing the plaintiffs' failure to state a valid claim. However, the court was unaware that the applicants had died while the action was pending.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the claims for an injunction became moot when the agency denied benefits and the applicants died. The court noted that the requested relief would no longer benefit the estates, as the Oklahoma Department of Human Services had already denied the applications. The court also held that the Eleventh Amendment barred the requested retrospective relief. Consequently, the court remanded the case to the district court with instructions to vacate the judgment on the claim for a prospective injunction and dismiss it without prejudice.Regarding the claim against Ms. Eads in her individual capacity, the Tenth Circuit held that she was entitled to qualified immunity. The court found that the plaintiffs did not allege facts showing the violation of a clearly established right. As a result, the court affirmed the dismissal with prejudice of the claim for damages against Ms. Eads. View "Lamle v. Eads" on Justia Law

Ricky Koel sought emergency care at Citizens Medical Center in Colby, Kansas, after sustaining serious injuries to his right eye. He was evaluated by a triage nurse, a physician assistant, and Dr. Daniel Kuhlman, who suspected a possible globe rupture. Dr. Sam Funk, an optometrist, also examined Koel but did not confirm an open globe rupture. A CT scan indicated a possible globe rupture, but Dr. Kuhlman did not share these results with the specialists. Koel was discharged with instructions to see an ophthalmologist the next morning. Despite undergoing emergency surgery the following day, Koel ultimately lost vision in his injured eye.The United States District Court for the District of Kansas dismissed Koel's EMTALA claim, concluding that Citizens Medical Center did not violate the Act's requirements. The court granted summary judgment in favor of Citizens and declined to exercise supplemental jurisdiction over Koel's state-law claims.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that Citizens Medical Center provided an appropriate medical screening examination within its capabilities and adhered to its own standard procedures, as required by EMTALA. The court also found that Citizens did not have actual knowledge of Koel's specific emergency medical condition (an occult globe rupture) and therefore was not obligated to stabilize him for that condition before discharge. The court affirmed the district court's summary judgment in favor of Citizens Medical Center. View "Koel v. Citizens Medical Center" on Justia Law

Plaintiff John Doe filed a class action lawsuit against Integris Health, Inc., alleging that Integris collected confidential health information from its website visitors and unlawfully shared it with third parties like Google and Facebook. Doe's complaint, filed in Oklahoma state court, asserted state law claims including negligence, invasion of privacy, and breach of fiduciary duty. Integris removed the case to federal court under the federal officer removal statute, claiming it was acting under the direction of a federal officer by helping the federal government achieve its objective of ensuring patient access to electronic health records (EHR).The United States District Court for the Western District of Oklahoma remanded the case to state court, concluding that Integris had not demonstrated it was "acting under" the direction of a federal officer. The court found that Integris was merely complying with federal regulations, which is insufficient to establish federal officer jurisdiction.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 Integris was not "acting under" a federal officer because it was only complying with federal regulations and not fulfilling a basic government task. The court emphasized that compliance with federal law, even if highly detailed and supervised, does not equate to acting under a federal officer. The court also noted that Integris's use of tracking technology on its website was not required by the federal government and was not part of any federal directive. Therefore, the court concluded that removal under the federal officer removal statute was improper. View "Doe v. Integris Health" on Justia Law

A federal inmate, Dustin Rowland, developed a hernia after a pretrial detention fight. A physician deemed the hernia "reducible and stable," recommending non-surgical treatments. Rowland, desiring surgery, utilized the Bureau of Prisons' (BOP) Administrative Remedial Program, which involves a four-step grievance process. His initial requests were denied, but a later appeal led to approval for a surgical consultation. However, Rowland's final appeal was denied for procedural reasons, and he did not correct the deficiency. He eventually received surgery but filed a lawsuit claiming deliberate indifference to his medical needs, seeking damages under Bivens, injunctive relief for post-operative care, and a negligence claim under the Federal Tort Claims Act (FTCA).The United States District Court for the District of Colorado dismissed Rowland's Bivens claim, granted summary judgment against his injunctive relief claim for failure to exhaust administrative remedies, and dismissed the FTCA claim for lack of subject matter jurisdiction due to non-exhaustion. Rowland's motion for reconsideration was also denied.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's dismissal of the Bivens claim, noting that Rowland's case presented a new context not covered by previous Bivens cases and that the BOP's Administrative Remedial Program provided an adequate alternative remedy. The court also upheld the summary judgment on the injunctive relief claim, as Rowland failed to exhaust administrative remedies specifically for post-operative care. Lastly, the court affirmed the dismissal of the FTCA claim, emphasizing the jurisdictional requirement of exhausting administrative remedies before filing suit. The court found no abuse of discretion in the district court's denial of Rowland's Rule 60(b) motion for reconsideration. View "Rowland v. Matevousian" on Justia Law

Plaintiffs M.S. and L.S. sought insurance coverage for mental health treatments for their child, C.S., under a health benefits plan provided by M.S.'s employer, Microsoft Corporation. The plan, administered by Premera Blue Cross, is subject to ERISA and the Parity Act. Premera denied the claim, stating the treatment was not medically necessary. Plaintiffs pursued internal and external appeals, which upheld the denial. Plaintiffs then sued in federal district court, alleging improper denial of benefits under ERISA, failure to produce documents in violation of ERISA’s disclosure requirements, and a Parity Act violation for applying disparate treatment limitations to mental health claims.The United States District Court for the District of Utah granted summary judgment to Defendants on the denial-of-benefits claim but ruled in favor of Plaintiffs on the Parity Act and ERISA disclosure claims. The court found that Defendants violated the Parity Act by using additional criteria for mental health claims and failed to disclose certain documents required under ERISA. The court awarded statutory penalties and attorneys’ fees to Plaintiffs.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court vacated the district court’s grant of summary judgment on the Parity Act claim, finding that Plaintiffs lacked standing to bring the claim. The court reversed the district court’s ruling that Defendants violated ERISA by not disclosing the Skilled Nursing InterQual Criteria but affirmed the ruling regarding the failure to disclose the Administrative Services Agreement (ASA). The court upheld the statutory penalty for the ASA disclosure violation and affirmed the award of attorneys’ fees and costs to Plaintiffs. View "M.S. v. Premera Blue Cross" on Justia Law

M.G. and C.V., medically fragile children under New Mexico’s Medicaid program, sued the New Mexico Human Services Department (HSD) for failing to provide the private duty nursing (PDN) hours they are entitled to. They sought a preliminary injunction to compel HSD to take good faith steps to provide these hours. The district court granted the injunction, and HSD appealed.The United States District Court for the District of New Mexico found that M.G. and C.V. were consistently not receiving their required PDN hours, which placed them at risk of severe medical harm. The court concluded that M.G. and C.V. were likely to succeed on the merits of their Medicaid Act claims, which mandate the provision of PDN services. The court also found that the children would suffer irreparable harm without the injunction, that the balance of harms favored the plaintiffs, and that the injunction was in the public interest. The injunction required HSD to take specific steps, such as negotiating with managed care organizations and increasing monitoring of PDN hour shortfalls, to provide the necessary PDN hours.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The appellate court held that M.G. and C.V. had standing to seek injunctive relief and that the district court did not err in its conclusions. The court found that the injunction was not impermissibly vague and that the Supreme Court’s decision in Armstrong v. Exceptional Child Center, Inc. did not preclude the issuance of the injunction. The Tenth Circuit concluded that the district court acted within its discretion in granting the preliminary injunction, given the likelihood of success on the merits, the risk of irreparable harm, the balance of harms, and the public interest. View "M.G. v. Armijo" on Justia Law