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

Plaintiffs Ronica Tabor and Dacia Gray worked as inside salespeople for Hilti, Inc and Hilti of North America, Inc. After being denied promotions to Account Managers (outside sales), they each filed individual claims for gender discrimination under Title VII and moved to certify a class of all female inside salespersons at Hilti who were denied similar promotions. The district court refused to certify the class and granted summary judgment in favor of Hilti on all claims. Upon review, the Tenth Circuit affirmed the district court's grant of summary judgment as to Tabor's claim for retaliation, and Gray's claim for failure to promote. The Court also affirmed the refusal to certify a class. However, the Tenth Circuit reversed the district court with respect to Tabor's individual claims for failure to promote and disparate impact, and remanded Gray's individual disparate impact claim because the district court did not address that claim in its opinion. View "Tabor, et al v. Hilti, Inc., et al" on Justia Law

The issue before the Tenth Circuit in this case was one of first impression: whether the 2005 amendments to the Bankruptcy code exempted Chapter 11 debtors from the absolute priority rule. The bankruptcy court answered this question affirmatively, and therefore confirmed the Debtors' proposed plan of reorganization over certain creditors' objections that the plan violated the absolute priority rule. On appeal, the bankruptcy appellate panel certified the case for direct appeal. The Tenth Circuit reversed the bankruptcy court's order confirming the plan: "here, the statutory language and legislative history lack any clear indication that Congress intended to erode a pillar of creditor bankruptcy protection." The case was remanded for further proceedings. View "Dill Oil Company, LLC, et al v. Stephens, et al" on Justia Law

The issue before the Tenth Circuit in this case arose from a case that originated in Utah state court; one of the parties turned to the federal courts to ask for a stay of all state-court proceedings and an order to compel arbitration of the state-court claims. The federal district court declined to do so, dismissed the case, and awarded attorney's fees to the prevailing party. On appeal, the Tenth Circuit was petitioned to review whether the federal district court correctly determined that it should have stayed out of the "still-unfolding state-court controversy." Upon review of the matter, the Tenth Circuit concluded that the U.S. Supreme Court's "Colorado River" doctrine was the persuasive and controlling law of this case. "We think that in this case the Colorado River doctrine wisely counsels our abstention from duplicative interference with the exceptionally protracted state proceedings present here." The Court affirmed the federal district court, but vacated the award of attorney's fees. The case was remanded for detailed findings of fact to support the fee award. View "D.A. Osguthorpe Family Partner v. ASC Utah, Inc., et al" on Justia Law

Pro se Defendant-Appellant Gregory Graham was previously convicted of distributing crack cocaine and sentenced under a plea agreement to 25 years' incarceration. The district court denied his motion for a sentence reduction. On appeal, Defendant contended his sentence should have been reduced in light of the Fair Sentencing Act of 2010 (FSA) and Amendment 750 to the United States Sentencing Guidelines. Finding that Defendant's sentence was based solely on his plea agreement rather than any Guideline sentencing range, the Tenth Circuit affirmed the district court's decision. View "United States v. Graham" on Justia Law

Petitioner Ronald Lott was convicted by an Oklahoma jury of two counts of first-degree murder in December 2001. The murders were committed over twenty-five years ago. The state trial court sentenced Petitioner to death on both counts in accordance with the jury's verdict. After a direct appeal and application for state post-conviction relief, Petitioner sought federal habeas relief. The federal district court denied the petition. Petitioner was granted a certificate of appealability with respect to several issues, which he appealed to the Tenth Circuit Court of Appeals. In an opinion over one-hundred pages long, the Tenth Circuit affirmed: "The only clear constitutional error that occurred at Lott's trial was the admission of the improper victim impact evidence. However, that error, standing alone, does not implicate cumulative-error analysis. And even if we were to assume the existence of additional constitutional errors, we cannot say, having exhaustively examined the record on appeal, that Lott's trial was "so infected . . . with unfairness as to make the resulting conviction[s] [or sentences] a denial of due process." View "Lott v. Trammell" on Justia Law

The issue on appeal in this case concerned WildEarth Guardians’ challenge to the National Park Service’s (NPS) elk and vegetation management plan for Rocky Mountain National Park. WildEarth filed suit in federal district court challenging the plan and the final environmental impact statement the NPS prepared in conjunction with the plan. WildEarth contended the NPS violated the National Environmental Policy Act (NEPA) by failing to include the reintroduction of a naturally reproducing wolf population as one of the alternatives considered in the environmental impact statement. WildEarth also challenged the agency’s proposal to allow volunteers to assist the agency in reducing the elk population. The district court affirmed the agency action, and WildEarth appealed. Upon review, the Tenth Circuit found that the record supported the agency’s decision to exclude consideration of a natural wolf alternative from its environmental impact statement. The Court also found the agency’s interpretation of the National Parks Organic Act and Rocky Mountain National Park Enabling Act persuasive, and that its elk management plan did not violate those statutes. View "WildEarth Guardians v. National Park Service" on Justia Law

In a direct criminal appeal, Defendant-Appellant Enrique De La Cruz challenged the district court’s decision to deny his motion to suppress evidence the United States obtained during an investigative seizure. ICE agents detained Petitioner while looking for another person they believed to be in the United States illegally. Upon review of his fake identification card, agents discovered that Petitioner was himself unlawfully in the United States after having been previously deported. On that basis, the agents arrested him. A federal grand jury indicted Petitioner for unlawfully reentering the United States after a previous deportation. Petitioner moved to suppress the evidence agents obtained from him arguing that, at the time the agents asked him for his identification, they were no longer justified in detaining him because the agents no longer had reasonable suspicion to believe that he was involved in criminal activity. After conducting an evidentiary hearing, the district court denied Petitioner's motion. He then entered a conditional guilty plea, see Fed. R. Crim. P. 11(a)(2), reserving the right to appeal the district court’s suppression ruling. Upon review of the matter, the Tenth Circuit concluded that the Government failed to establish that an objective officer would have had reasonable suspicion to believe that Petitioner was involved in criminal activity once the agents determined that he was not the original person they were looking for and before Petitioner provided the agents with the false identification card. The Court reversed the district court’s decision denying Petitioner's suppression motion and remanded this case to the district court for further proceedings. View "United States v. De La Cruz" on Justia Law

Pro se Appellant Bennie Walters brought employment discrimination claims against his former employer, Wal-Mart Stores, Inc. The parties reached an apparent settlement during a settlement conference, but Appellant later refused to sign the written agreement. The district court granted Wal-Mart's motion to enforce the agreement and denied Appellant's motion for reconsideration. Appellant appealed both rulings. After review of the matter, the Tenth Circuit affirmed: "[w]hile we liberally construe Walters' pro se filings, we will not 'assume the role of advocate' and make his arguments for him." View "Walters v. Wal-Mart Stores, Inc, et al" on Justia Law

Petitioner Christopher Holyfield appealed a district court's denial of his 28 U.S.C. 2255 motion for relief from judgment. In his motion, Petitioner asserted he received ineffective assistance of counsel when counsel failed to challenge on appeal the district court's use of a 1998 California conviction to sentence him to life imprisonment under the provisions of 21 U.S.C. 841(b)(1)(A). In particular, Petitioner contended his attorney should have argued his 1998 conviction was not final at the time Petitioner committed the violation of section 841(a)(1). Upon review, the Tenth Circuit affirmed: "[w]hen [Petitioner] violated section 841, the 1998 conviction was no longer subject to examination on direct appeal. . . . Thus, [Petitioner] committed a violation of section 841 after his 1998 conviction became final." View "United States v. Holyfield" on Justia Law

Several environmental groups challenged decisions made by the Bureau of Land Management (BLM) and the Interior Board of Land Appeals (IBLA) regarding the legality of thirty-nine oil and gas leases in Southern Utah, owned by Kirkwood Oil and Gas, LLC and William C. Kirkwood. In the 1980s, Kirkwood applied to have its oil and gas leases converted to combined hydrocarbon leases, which would allow Kirkwood to extract oil from tar sands. At the time, BLM never accepted or rejected Kirkwood's applications. Between 2006 and 2008, BLM and IBLA issued several decisions declaring that the underlying oil and gas leases were "suspended" pending review of the conversion applications. The groups alleged that the BLM and IBLA violated the Mineral Leasing Act and other federal laws by retroactively deeming the leases to be suspended, avoiding expiration of the leases according to their terms. The district court held the groups did not have standing to bring its claims and dismissed the suit for lack of subject matter jurisdiction. Although the district court misapplied the law in important respects with regard to standing, the Tenth Circuit ultimately held that this case was not ripe for review. View "S. Utah Wilderness Alliance v. Palma" on Justia Law