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

The defendant was indicted on three federal charges related to the sexual abuse of a minor family member, with the alleged conduct spanning several years. The charges carried varying statutory penalties, with one count carrying a potential life sentence. The parties negotiated three separate plea agreements. The first agreement involved the defendant pleading guilty to the most serious count in exchange for dismissal of the other two, with a stipulated sentence of thirteen to fifteen years. The second agreement had the defendant pleading guilty to the two lesser counts, with the most serious count dismissed and no agreement as to sentence. The third agreement involved guilty pleas to all counts and a stipulated maximum sentence of 235 months. The victim and her family supported the plea agreements to avoid the trauma of trial.The United States District Court for the Northern District of Oklahoma rejected the first plea agreement, finding the stipulated sentence insufficient given the seriousness and duration of the abuse. After the parties’ motion to reconsider was denied, they entered the second plea agreement. The district court also rejected this agreement, reasoning that it improperly limited the court’s sentencing discretion by dismissing the count with the greatest sentencing exposure. The court accepted the third plea agreement and imposed a 235-month sentence. The defendant appealed, arguing the court abused its discretion in rejecting the first two agreements. The government agreed that the court erred in rejecting the second agreement.The United States Court of Appeals for the Tenth Circuit held that the district court acted within its discretion in rejecting the first, hybrid plea agreement, but abused its discretion in rejecting the second, which was a charge bargain. The appellate court found that the district court failed to show proper deference to prosecutorial discretion in charge bargains. The court vacated the convictions and sentence, remanding for reconsideration of the second plea agreement, but declined to reassign the case to a different judge. View "United States v. Papke" on Justia Law

Police in Cheyenne, Wyoming, responded to a call about an unconscious man in a vehicle and arrested Derek Ascherin after finding drug paraphernalia and nearly 24 grams of suspected fentanyl pills. During the investigation, law enforcement suspected that Traquevis Dewayne Hardy was supplying fentanyl to Ascherin. Officers obtained a warrant to search Hardy’s Facebook messages, which revealed communications about fentanyl transactions. Hardy was later arrested in April 2023 with nine fentanyl pills in his possession.A grand jury in the United States District Court for the District of Wyoming indicted Hardy for conspiracy to distribute at least 40 grams of fentanyl between July and December 2022. After a three-day trial, a jury found Hardy guilty. At sentencing, the district court attributed 1,773 grams of fentanyl to Hardy, relying in part on statements from a confidential source, and sentenced him to 168 months in prison. Hardy objected to the drug quantity calculation, arguing it was based on unreliable hearsay, but the district court overruled his objection. Hardy appealed his conviction and sentence.The United States Court of Appeals for the Tenth Circuit reviewed three issues: whether Hardy’s absence from an in-chambers evidentiary ruling violated due process, whether the district court erred in admitting evidence of his later possession of fentanyl under Federal Rule of Evidence 404(b), and whether the sentencing court erred in relying on uncorroborated hearsay to determine drug quantity. The Tenth Circuit held that Hardy’s absence from the in-chambers conference did not violate due process and that any error in admitting the Rule 404(b) evidence did not affect the verdict. However, the court found clear error in the sentencing court’s reliance on uncorroborated hearsay for drug quantity. The Tenth Circuit affirmed Hardy’s conviction, vacated his sentence, and remanded for resentencing. View "United States v. Hardy" on Justia Law

Raul Guzman was living in a camper trailer parked on property in Albuquerque, New Mexico, where the City had declared two buildings substandard and posted notices prohibiting anyone from residing in the structures or on the property. Despite these warnings, Guzman stayed in the trailer with the property owner’s permission. In September 2022, city code enforcement officers, accompanied by police, inspected the property. Upon finding Guzman in the trailer, officers entered, detained him, and discovered a firearm inside.A grand jury indicted Guzman for being a felon in possession of a firearm. He moved to suppress the evidence, arguing he had a reasonable expectation of privacy in the trailer because he had the owner’s permission to stay there and the posted notices did not specifically mention the trailer. The United States District Court for the District of New Mexico held an evidentiary hearing and denied the motion. The court found that, although Guzman may have had a subjective expectation of privacy, this expectation was not objectively reasonable because the posted notices made clear that residing on the property was unlawful. The court also found, in the alternative, that exceptions to the warrant requirement would have justified the officers’ actions. Guzman subsequently pleaded guilty but reserved the right to appeal the suppression ruling.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 Guzman lacked Fourth Amendment standing to challenge the search because he did not have a reasonable expectation of privacy in the trailer. The court reasoned that, given the explicit posted notices prohibiting residence on the property and Guzman’s admission that he read them, society would not recognize his expectation of privacy as reasonable. The court therefore affirmed the denial of the suppression motion. View "United States v. Guzman" 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

John Snyder, after working for Guardian Life Insurance Company and obtaining a national customer list (the Guardian Broker List), was employed by Beam Technologies, Inc. Snyder claims that Beam induced him to join and disclose the list, promising compensation. While at Beam, Snyder created state-specific broker lists derived from the Guardian Broker List and inadvertently included the full list in emails to several Beam employees. He did not mark the lists as confidential, restrict access, or inform Beam of their confidential nature. After his employment ended, Snyder did not attempt to recover the list or notify Beam of its confidential status, and he later confirmed to Beam’s CEO that the disclosure was intentional.Snyder sued Beam in the United States District Court for the District of Colorado, alleging misappropriation of trade secrets under federal and state law, as well as several state law claims. The district court granted summary judgment to Beam on the trade secret claims, finding Snyder failed to show he “owned” the Guardian Broker List. The court also granted Beam’s motion to exclude Snyder’s damages expert under Federal Rule of Evidence 702 and, in doing so, barred Snyder from presenting any evidence or witnesses on lost wages for his remaining claims. Snyder’s motion to reconsider this order was denied, and the parties settled or dismissed the remaining claims, leading to a final judgment.The United States Court of Appeals for the Tenth Circuit affirmed summary judgment on the trade secret claims, holding that Snyder failed to take reasonable measures to maintain the secrecy of the Guardian Broker List, a requirement under both the Defend Trade Secrets Act and the Colorado Uniform Trade Secrets Act. However, the Tenth Circuit reversed the district court’s Rule 702 order to the extent it excluded all evidence and witnesses on lost wages, finding that such a dispositive ruling required notice and the procedural protections of summary judgment. The case was remanded for further proceedings on that issue. View "Snyder v. Beam Technologies" on Justia Law

A female firefighter with a long and decorated career in the Salt Lake City Fire Department alleged that her supervisors discriminated against her based on her sex and subjected her to a hostile work environment. She claimed that her male supervisors made derogatory comments about women, held her to different standards than male colleagues, and retaliated against her for complaining about sexist behavior. Over several years, she was passed over for promotions, reassigned to less prestigious roles, and eventually demoted. She filed multiple complaints with the Equal Employment Opportunity Commission and appealed her demotion to the Salt Lake City Civil Services Commission, which ultimately reversed the demotion, finding that the reasons given for it were unsupported and appeared to be manufactured.The United States District Court for the District of Utah denied the defendants’ motion for summary judgment, which sought qualified immunity on the plaintiff’s claims under 42 U.S.C. § 1983 for sex discrimination and hostile work environment in violation of the Fourteenth Amendment. The defendants, who were her supervisors, appealed the denial of qualified immunity to the United States Court of Appeals for the Tenth Circuit. The City also sought pendent appellate jurisdiction over the denial of its own summary judgment motion, but the appellate court declined to exercise such jurisdiction.The United States Court of Appeals for the Tenth Circuit dismissed the appeal as to the sex discrimination claim for lack of jurisdiction, finding that the defendants had not properly raised qualified immunity on that claim in the district court. The court also dismissed most of the appeal regarding the hostile work environment claim, holding that it lacked jurisdiction to review factual disputes and evidentiary rulings at this interlocutory stage. However, the court vacated the district court’s denial of qualified immunity on the hostile work environment claim and remanded for further proceedings, instructing the district court to conduct a more thorough analysis of whether the law was clearly established as to each defendant’s specific conduct. View "Ellis v. Salt Lake City Corporation" on Justia Law

Raymundo Guevara-Lopez was stopped by a New Mexico State Police officer for a minor traffic violation in September 2021. During the stop, inconsistencies in the travel plans provided by Guevara-Lopez and his passenger raised the officer's suspicions. A search of the vehicle revealed $60,980 in cash hidden behind screwed-in panels. Guevara-Lopez admitted to transporting the money to Mexico for drug cartels and estimated he had made 25 to 30 trips, typically transporting between $110,000 to $118,000 each trip.A federal grand jury indicted Guevara-Lopez in June 2023 for attempted bulk-cash smuggling and aiding and abetting. He pleaded guilty without a plea agreement. The Presentence Report (PSR) calculated a guidelines range of 24 to 30 months based on a total offense level of 17 and a criminal-history category of I. The district court, however, varied upward and sentenced him to the statutory maximum of 60 months, citing the large amount of money smuggled and his pending state charges in Texas.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found the district court's sentence substantively unreasonable, noting that the district court failed to adequately address the need to avoid unwarranted sentence disparities and relied on incorrect information about Guevara-Lopez's Texas charges. The Tenth Circuit vacated the 60-month sentence and remanded for resentencing, emphasizing the need for a more detailed explanation to justify the significant upward variance. View "United States v. Guevara-Lopez" on Justia Law

In 2021, Ralph Marcus Hardy, an inmate at Adams County Detention Facility (ACDF) in Colorado, fell from his wheelchair and suffered serious injuries. Despite his repeated requests for medical attention, jail officials allegedly ignored his pleas. Hardy claims that Detention Specialist Daniel DeHerrera ignored emergency distress signals from his cell, and Deputy Dennis Rabie, who later found Hardy in pain, also failed to provide medical assistance.The United States District Court for the District of Colorado reviewed the case. Deputy Rabie and Detention Specialist DeHerrera moved to dismiss Hardy’s claims, asserting qualified immunity. The district court denied their motion, finding that Hardy plausibly alleged violations of his Fourteenth Amendment rights. The court held that the defendants were not entitled to qualified immunity, leading to this appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Hardy sufficiently alleged that both Deputy Rabie and Detention Specialist DeHerrera acted with deliberate indifference to his medical needs. The court found that Hardy’s constitutional rights were violated and that these rights were clearly established at the time of the incident. The court concluded that both defendants were aware of Hardy’s serious medical needs and failed to take reasonable measures to address them, thus denying them qualified immunity. View "Hardy v. Rabie" on Justia Law

On February 4, 2022, the Tulsa Police Department responded to calls about a violent domestic dispute involving Dakota Wayne Campus and his pregnant fiancée, M.D. Campus chased M.D. with a firearm, dragged her back to her apartment, and strangled her. He fled the scene but was apprehended seven days later. Campus was charged with multiple crimes, including assault and firearm offenses.The United States District Court for the Northern District of Oklahoma found Campus guilty on all counts. The jury's verdict included charges of assault by strangulation, assault with a dangerous weapon, brandishing a firearm during a crime of violence, and possession of a firearm and ammunition. The district court sentenced Campus to 240 months in prison, including a two-level adjustment under the United States Sentencing Guidelines for physically restraining the victim.Campus appealed to the United States Court of Appeals for the Tenth Circuit, arguing that the district court improperly applied the two-level adjustment for physical restraint under § 3A1.3 of the Guidelines. He contended that this adjustment constituted impermissible double counting because his offense already involved a degree of restraint.The Tenth Circuit reviewed the district court's application of the Sentencing Guidelines de novo and factual findings for clear error. The court held that the two-level adjustment for physical restraint was appropriate because Campus's actions of holding M.D. at gunpoint and dragging her back into the apartment were separate from the strangulation offense. The court concluded that the adjustment did not constitute double counting and affirmed the district court's sentence. View "United States v. Campus" on Justia Law

The defendant was indicted on charges of possession of child pornography and sexual abuse of a minor. Before the trial, the government filed a notice to introduce evidence of the defendant's prior similar conduct under Federal Rule of Evidence 404(b). The district court allowed this evidence, and after a jury trial, the defendant was found guilty of several counts related to coercion and enticement and child sex offenses. He was sentenced to 340 months in prison. The defendant appealed, arguing that the district court abused its discretion by admitting the prior conduct evidence, claiming it was not for a proper purpose and was unfairly prejudicial.The United States District Court for the Northern District of Oklahoma admitted the evidence, finding it relevant to show the defendant's identity, intent, motive, and plan. The court also provided a limiting instruction to the jury to mitigate any potential prejudice. The jury found the defendant guilty of the charges involving one minor but acquitted him of charges involving another.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the evidence of the defendant's prior conduct was admissible under Rule 404(b) for proper purposes, including showing identity, intent, plan, and motive. The court found that the evidence was relevant and that its probative value was not substantially outweighed by the danger of unfair prejudice. The limiting instruction given to the jury was deemed sufficient to address any potential prejudice. The appellate court concluded that the district court did not abuse its discretion in admitting the evidence and upheld the defendant's conviction and sentence. View "United States v. Summers" on Justia Law