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

Deborah Bradshaw and Chrystal Antao sued American Airlines and Mesa Airlines, alleging injuries and damages from the airlines' negligent handling of an in-flight emergency. During a June 2020 flight, the aircraft experienced a malfunction that led to a loss of cabin pressure, requiring an emergency descent. The plaintiffs claimed the pilot failed to properly inform passengers of the threat and descended too rapidly, while American Airlines failed to provide medical personnel upon landing.The case was initially filed in the District Court of Tulsa County, Oklahoma, and later removed to the United States District Court for the Northern District of Oklahoma on diversity grounds. The district court granted summary judgment in favor of the airlines, concluding that federal law preempted Oklahoma's common-carrier standard of care in aviation safety. The court allowed the plaintiffs to pursue a state negligence claim using the federal "reckless-or-careless manner" standard but found no evidence that the airlines violated this standard.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, holding that the Federal Aviation Act and related regulations preempt state law in the field of aviation safety. The court agreed that the federal "careless or reckless manner" standard of care applies, preempting Oklahoma's common-carrier standard. The court found no genuine issue of material fact regarding a violation of federal regulations by the airlines and upheld the summary judgment in favor of the defendants. View "Bradshaw v. American Airlines" on Justia Law

Angelo Brock, an independent distributor for Flowers Baking Co. of Denver, LLC, filed a class-action lawsuit alleging wage and hour violations under the Fair Labor Standards Act and Colorado labor law. Brock claimed that Flowers misclassified its delivery drivers as independent contractors to avoid paying proper wages. Flowers moved to compel arbitration based on an Arbitration Agreement within the Distributor Agreement between Brock and Flowers. The district court denied the motion, leading to this appeal.The United States District Court for the District of Colorado found that Brock fell within the "transportation workers exemption" under § 1 of the Federal Arbitration Act (FAA), which exempts certain transportation workers from arbitration. The court concluded that Brock's class of workers, who deliver Flowers goods intrastate, are engaged in interstate commerce because they play a direct and necessary role in the flow of goods across state lines. The court also determined that the Arbitration Agreement did not allow for arbitration under Colorado law, as it was inconsistent with the FAA.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The Tenth Circuit agreed that Brock's class of workers is engaged in interstate commerce, as their intrastate deliveries are part of a continuous interstate journey of goods. The court found that Flowers retains significant control over Brock's operations, indicating that the goods' delivery to retail stores is the final leg of an interstate route. The court declined to review Flowers's argument that the Distributor Agreement is not a contract of employment, as it was not raised in the lower court. Additionally, the court determined it lacked jurisdiction to review the district court's denial of arbitration under Colorado law. View "Brock v. Flowers Foods" on Justia Law

In a case brought before the United States Court of Appeals for the Tenth Circuit, Bruce McWhorter, a mechanic, had his certification revoked by the Federal Aviation Administration (FAA) after it was discovered that he had not replaced certain components of an aircraft's engine despite claiming to have performed a major overhaul. McWhorter appealed the decision to an administrative law judge who affirmed the FAA's decision. McWhorter then sought to appeal this decision to the National Transportation Safety Board (NTSB), but failed to serve the FAA with his notice of appeal in a timely manner. The NTSB dismissed McWhorter's appeal on these grounds. McWhorter subsequently petitioned for a review of the NTSB’s dismissal, but did so 111 days after the NTSB issued its final order, exceeding the 60-day limit prescribed by law.The court clarified that the 60-day limit for seeking appellate review stipulated in 49 U.S.C. § 1153(b)(1) is not a jurisdictional requirement, but rather a claim-processing rule. This means that a petitioner’s failure to comply with this time limit does not affect the court’s jurisdiction to hear the appeal. However, the court found that McWhorter had not established reasonable grounds for the delay in filing his petition for review, as required by the same statute for petitions filed after the 60-day limit. The court determined that the primary blame for the delay was on McWhorter, not on any confusion created by the FAA or the NTSB. Therefore, the court denied McWhorter's petition as untimely. View "McWhorter v. FAA" on Justia Law

Five people were killed when a commercial truck rear-ended a line of traffic on an interstate highway. The truck driver was prosecuted and sentenced to prison for his misconduct. The issue on this appeal was the liability, if any, of the manufacturer of the truck. Plaintiffs, suing on behalf of the heirs and estates of the decedents, contended the manufacturer, Daimler Trucks North America, should have been held liable in tort under design-defect and warning-defect theories of products liability because it failed to equip the truck with two collision-mitigation systems—forward-collision warning and automatic emergency braking—and did not warn of the dangers caused by that failure. The district court granted summary judgment to Daimler. After its review of the district court record, the Tenth Circuit Court of Appeals affirmed, finding many of the arguments made by Plaintiffs on appeal were inadequately preserved for appellate review, and the remaining arguments lacked merit. View "Butler, et al. v. Daimler Trucks North America" on Justia Law

Plaintiff-appellant Francisco Serna sued a police officer and local police department that allegedly prevented him from transporting hemp plants on a flight from Colorado to Texas. In the complaint, he asserted a single claim under § 10114(b) of the Agriculture Improvement Act of 2018 (the 2018 Farm Bill), a statute that authorized states to legalize hemp and regulate its production within their borders, but generally precluded states from interfering with the interstate transportation of hemp. The district court dismissed Serna’s complaint under Federal Rule of Civil Procedure 12(b)(6), concluding that Serna failed to state a viable claim because § 10114(b) did not create a private cause of action to sue state officials who allegedly violate that provision. Serna appealed, arguing that § 10114(b) impliedly authorized a private cause of action and that even if it didn't, the district court should have allowed him to amend the complaint to add other potentially viable claims rather than dismissing the case altogether. The Tenth Circuit Court of Appeals affirmed, finding that contrary to Serna’s view, the language in § 10114(b) did not suggest that Congress intended to grant hemp farmers a right to freely transport their product from one jurisdiction to another, with no interference from state officials. Because courts could not read a private cause of action into a statute that lacked such rights-creating language, the Court held the district court properly dismissed Serna’s § 10114(b) claim. The Court also concluded the trial court properly declined to allow Serna to amend his complaint. View "Serna v. Denver Police Department, et al." on Justia Law

Kelly Day appealed the district court’s dismissal of the diversity action she filed against SkyWest Airlines for personal injuries she allegedly sustained when a SkyWest flight attendant carelessly struck her with a beverage cart. The district court granted SkyWest’s motion to dismiss the action as preempted under the Airline Deregulation Act (“ADA”), which preempted state laws “related to a price, route, or service of an air carrier.” The Tenth Circuit Court of Appeals concurred with sister circuits that personal-injury claims arising out of an airline employee’s failure to exercise due care were not “related to” a deregulated price, route, or service. Therefore, the Court reversed the district court’s dismissal of Day’s action and remanded for further proceedings. View "Day v. SkyWest Airlines" on Justia Law

As Plaintiff William Frey proceeded through the Transportation Security Administration (“TSA”) checkpoint at Jackson Hole Airport in Teton County, Wyoming, the body scanner alerted TSA screeners to a potentially suspicious area on Plaintiff’s person. When the security screeners informed Plaintiff that they would have to conduct a pat down, Plaintiff became agitated and repeatedly refused to cooperate. So the security screeners summoned a police officer, Defendant Nathan Karnes, who arrested Plaintiff. After being transported to the Teton County Jail for booking, Plaintiff continued his noncooperation, refusing to participate in the booking process and demanding that jail officials allow him to have an attorney present. Jail officials detained Plaintiff for about three hours before releasing him. Plaintiff sued under 42 U.S.C. § 1983 and state law, alleging many violations of his rights. The district court dismissed Plaintiff’s federal claims under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim, denied leave to file a second amended complaint, declined to exercise supplemental jurisdiction over the remaining state-law claims, awarded attorney’s fees to the Municipal Defendants, and sanctioned Plaintiff’s attorneys. Plaintiff appealed, arguing that some of his claims should have survived dismissal, that the district court should have permitted him to add some of his new proposed claims in a second amended complaint, and that the district court should not have awarded any attorney’s fees. Finding no reversible error, the Tenth Circuit affirmed the district court. View "Frey v. Town of Jackson, WY, et al." on Justia Law

Municipal authorities in Oklahoma fined Plaintiff BNSF Railway Company for violating its Blocked Crossing Statute—setting up a preemption challenge between the federal Interstate Commerce Commission Termination Act (“ICCTA”) and the Blocked Crossing Statute. Defendants argued the Federal Railroad Safety Act (“FRSA”), not the ICCTA, applied to Oklahoma’s statute and did not preempt it. The district court held that the ICCTA preempted Oklahoma’s Blocked Crossing Statute because it regulated railroad operations. The Tenth Circuit agreed with the federal district court and affirmed its decision. View "BNSF Railway v. City of Edmond, et al." on Justia Law

Southern Furniture Leasing, Inc. filed a putative class action against a group of less-than-truckload (“LTL”) freight carriers, all predecessors to or current subsidiaries of YRC, Inc. Southern Furniture alleged YRC “carried out a widespread and systematic practice of overcharging its customers by intentionally using inflated shipment weights when determining shipment prices.” YRC asked the Tenth Circuit to affirm on the alternate ground that Southern Furniture failed to allege Article III standing. The district court rejected YRC’s standing argument, and the Tenth Circuit agreed with its analysis. The district court granted YRC’s motion to dismiss on the grounds that Southern Furniture had only 180 days to contest the alleged overcharges under 49 U.S.C. 13710(a)(3)(B). To this, the Tenth Circuit concurred and affirmed. View "Southern Furniture Leasing v. YRC" on Justia Law

Robert Rabe worked as a pipefitter in an Atchison Topeka & Sante Fe Railroad (“ATSF”) repair shop. In that capacity, he replaced pipe insulation on passenger cars manufactured by The Budd Company (“Budd”). Rabe died from malignant mesothelioma. Nancy Little, individually and as personal representative of Rabe’s estate, brought state common-law tort claims against Budd, claiming Rabe died from exposure to asbestos-containing insulation surrounding the pipes on Budd-manufactured railcars. A jury ruled in Little’s favor. On appeal, Budd contended Little’s state tort claims were preempted by the Locomotive Inspection Act (“LIA”), under a theory that all passenger railcars were “appurtenances” to a complete locomotive. The Tenth Circuit determined that because Budd did not raise this issue before the district court, and because Budd did not seek plain-error review, this particular assertion of error was waived. Alternatively, Budd contended Little’s tort claims were preempted by the Safety Appliance Act (“SAA”. The Tenth Circuit determined that assertion was foreclosed by the Supreme Court’s decision in Atlantic Coast Line Railroad Co. v. Georgia, 234 U.S. 280 (1914). Therefore, finding no reversible error, the Tenth Circuit affirmed the district court's judgment. View "Little v. Budd Company" on Justia Law