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

Plaintiff-appellant Anil Vazirani was an independent insurance agent who owned and managed Vazirani & Associates Financial, LLC and Secured Financial Solutions, LLC. Vazirani contracted with Aviva Life and Annuity Company. After Defendants Mark Heitz and Jordan Canfield, executives at Aviva, cancelled the contract, Vazirani sued them in federal district court, alleging that they tortuously interfered with the contract. The district court awarded summary judgment to Defendants, holding that an officer of a company could be liable for tortious interference with a company contract only if he was motivated by solely personal interests. The court concluded Vazirani failed to produce evidence that defendants were motivated by solely personal interests in terminating the contract. Finding no error with that decision, the Tenth Circuit affirmed. View "Vazirani v. Heitz" on Justia Law

Petitioners Scott and Audrey Blum appealed a Tax Court decision upholding the actions of the Commissioner of the Internal Revenue Service (IRS) invalidating a financial transaction as lacking economic substance and imposing two accuracy-related penalties for underpayment of taxes. "The intricacies of this offshore financial transaction and the fog of plausible deniability surrounding it cannot make up for the clarity of the big picture: this was a transaction designed to produce nothing more than tax advantages, and the Tax Court was right to uphold the Commissioner’s actions." View "Blum, et al v. CIR" on Justia Law

The issue before the Tenth Circuit in this case centered on a matter of state campaign finance regulations in light of the Supreme Court’s ruling in "Citizens United v. FEC," (558 U.S. 310 (2010)). Before "Citizens United" in 2010, New Mexico had introduced a new state campaign finance law that imposed a host of contribution and other limitations on political parties, political action committees, and donors to such entities. As pertains to this case, the state limited the amount an individual may contribute to a political committee. Potential donors, political parties, and political committees mounted an as-applied challenge to the law in federal district court, contending several of its provisions violated the First Amendment. The district court agreed and issued a preliminary injunction, enjoining the enforcement of two provisions: (1) limits on contributions to political committees for use in federal campaigns, and (2) limits on contributions to political committees that are to be used for independent expenditures. New Mexico appealed the latter ruling, contending that the limit on contributions furthers the state’s compelling interest in preventing corruption or the appearance of corruption in campaign spending. After careful consideration, the Tenth Circuit concluded the district court was correct that the challenged provision could not be reconciled with Citizens United and, as a result, did not err in entering a preliminary injunction. View "Republican Party of New Mexico, et al v. King, et al" on Justia Law

A jury convicted Defendant Nathan Archuleta of possession of methamphetamine, possession of methamphetamine with intent to distribute, conspiracy to possess methamphetamine with intent to distribute, and being a felon in possession of a firearm. On appeal, defendant argued that the trial court erred in admitting a gang expert’s testimony under the federal Rules of Evidence. Of the three evidentiary rules he cited, only Rule 403 was raised by defendant at trial. As a result, the Tenth Circuit's review of his arguments pertaining to Rule 702 and Rule 704(b) were limited to plain error review. Finding no error as to all three rules, the Tenth Circuit affirmed defendant's conviction. View "United States v. Archuleta" on Justia Law

Appellant Steven Carmichael Warren pled guilty to a second armed bank robbery, and the district court imposed a sentence of 25 years. Appellant challenged the procedural reasonableness of that sentence, arguing the factual accuracy of statements in the presentence report and that the district court erred by increasing his sentence after assuming the truth of those disputed statements. Finding no reversible error, the Tenth Circuit affirmed appellant's conviction. View "United States v. Warren" on Justia Law

The sole issue presented to the Tenth Circuit in this appeal stemmed on whether the bankruptcy trustee could avoid an entire annual transfer or only a portion exceeding 15% a restricted debtor's gross annual income to a religious or charitable organization. The bankruptcy court and Bankruptcy Court of Appeals (BAP) said circumstances here only permitted the trustee to avoid the portion of the transfer exceeding 15%. Because that result was contrary to the plain language of the statute, the Tenth Circuit reversed. View "Wadsworth v. The Word of Life Center" on Justia Law

Defendant Vernon Hill was convicted for bank robbery. He appealed the denial of his motion for a new trial. The government changed its theory about defendant's two brother's involvement in the robbery; the government prosecuted defendant and Stanley Hill as the two masked men who committed the robbery. The jury convicted defendant but could not agree on Stanley. Stanley was later retried and convicted. Several months after the trial, the government obtained cell-phone data and other evidence, and charged defendant and DeJuan Hill with conspiring to commit other robberies. In presenting this new case to a grand jury, an FBI agent called to testify revealed that the government's understanding of the bank robbery had changed, and that Stanley was not one of the robbers but the getaway car driver- the two that committed the robbery were defendant and DeJuan. Defendant then moved to set aside his prior conviction based on the FBI agent's testimony. The Tenth Circuit disagreed with defendant's contention that he was entitled to a new trial because the testimony was wrong constituted, and that the cell phone data was new, exculpatory evidence. The Court concluded that the FBI agent's admission that the two-robbers theory was wrong was not admissible evidence, and nothing else defendant described in his appeal was newly discovered evidence. As such, the Court affirmed the district court's denial of his motion for a new trial. View "United States v. Hill" on Justia Law

Cross-Appellee/Appellant Eloisa Taylor appealed a decision of the Bankruptcy Appellate Panel of the Tenth Circuit (BAP) that affirmed a United States Bankruptcy Court decision. The bankruptcy court granted summary judgment in favor of Eloisa’s former spouse, Matthew Taylor. The bankruptcy court determined that a $50,660.59 debt Eloisa owed to Matthew for overpayment of spousal support was nondischargeable because Eloisa incurred the debt “in connection with a separation agreement.” Matthew’s assertion that the debt was nondischargeable under 11 U.S.C. 523(a)(5) as a “domestic support obligation” was previously dismissed by the bankruptcy court for failure to state a claim. Matthew filed a cross appeal from that ruling and from the BAP’s ruling that neither it, nor the bankruptcy court, had authority under the parties’ divorce settlement agreement to award Matthew attorney fees that he incurred during the bankruptcy proceeding. The Tenth Circuit agreed with the bankruptcy court’s ruling that the debt was nondischargeable under section 523(a)(15). With regard to Matthew’s cross appeal, the Court affirmed both the bankruptcy court’s ruling that the debt was not excepted from discharge under 523(a)(5), and the BAP’s denial of Matthew’s request for attorney fees. View "Taylor v. Taylor" on Justia Law

Plaintiff Air Method Corporation terminated a helicopter pilot, Jeff Stackpole, following a 2010 incident. Defendant Office and Professional Employees International Union Local 109 (OPEIU) represented Mr. Stackpole throughout the arbitration process. After the arbitration award was granted in Mr. Stackpole’s favor, Plaintiff filed a complaint against OPEIU Local 109 pursuant to the Railway Labor Act, seeking to vacate the award. On cross-motions for summary judgment, the district court ruled in favor of Defendants, thereby upholding the arbitration award. Plaintiff appealed the district court’s decision. Finding no reversible error, the Tenth Circuit affirmed the arbitration award. View "Air Methods Corporation v. OPEIU, et al" on Justia Law

Defendant-Appellant Jeremiah Jackson appealed his conviction and sentence for the deaths of two women accidentally killed while defendant was fleeing police following a bank robbery. Defendant appealed, arguing that the proper charge against him should have been one count of bank robbery resulting in death, and that the district court erred: (1) in denying his post-trial motion to vacate one of the two remaining counts as multiplicitous because sentencing on both violated double jeopardy; (2) in denying a motion for a mistrial after the prosecutor commented on defendant's silence and failure to testify; and (3) in failing to instruct that a section 2113(e) conviction required a mens rea element. Upon review, the Tenth Circuit affirmed the conviction and remanded the case to the district court to vacate the sentence for resentencing. View "United States v. Jackson" on Justia Law