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

Richard Trent was convicted for being a felon in possession of a firearm. His sentence was enhanced under the Armed Career Criminal Act (“ACCA”) to 196 months in prison. On direct appeal, Trent argued that the ACCA enhancement should not have applied to him because his past conviction under Oklahoma’s general conspiracy statute was not a serious drug offense under the ACCA. The Tenth Circuit rejected this argument and affirmed. Trent subsequently filed a 28 U.S.C. 2255 motion to challenge his sentence. While that motion was pending, the Supreme Court decided Mathis v. United States, 136 S. Ct. 2243 (2016), which abrogated one of the two rationales the Tenth Circuit used to affirm Trent’s sentence. Trent argued that “Mathis” entitled him to relief. The district court denied his motion on several grounds, but granted a certificate of appealability (“COA”). After review of Trent’s appeal of his Section 2255 motion, the Tenth Circuit affirmed denial of the motion under the “law of the case” doctrine. “Although Mathis undercut one of this court’s rationales to affirm Mr. Trent’s sentence, it did not affect our alternative rationale to affirm.” View "United States v. Trent" on Justia Law

In 2014, while skiing an untamed and ungroomed run inside the boundaries of Jackson Hole Ski Resort, Plaintiff Michael Roberts skied into a lightly covered pile of boulders, falling between two of them, and severely injuring himself. He sued Jackson Hole Mountain Resort (“JHMR”) to recover for his injuries, and his wife joined his lawsuit alleging loss of consortium. JHMR moved for summary judgment on the basis of the Wyoming Recreation Safety Act (“WRSA”) which limited a recreational activity provider’s liability for so-called “inherent risks” of the activity. The district court granted summary judgment, holding that Roberts’s injuries were the result of an “inherent risk” of alpine skiing. Finding no reversible error in the district court’s judgment, the Tenth Circuit Court of Appeals affirmed the district court in full. View "Roberts v. Jackson Hole Mountain Resort" on Justia Law

Paul Knopf, the former Director of the Planning and Development Department (“City Planner”) in Evanston, Wyoming (“City”), sued Mayor Kent Williams under 42 U.S.C. 1983. Knopf claimed Mayor Williams did not reappoint him to his position as City Planner because he had sent an email to the City Attorney raising concerns about impropriety relating to a City project. Thus, Knopf alleged that Mayor Williams retaliated against him for exercising his First Amendment rights. Mayor Williams moved for summary judgment based on qualified immunity, which the court denied. In this interlocutory appeal, the Mayor asked the Tenth Circuit Court of Appeals to reverse that denial, arguing that a reasonable person in his position would not have understood Knopf to have spoken outside of his official duties, and that a “reasonable official: would have believed the email at issue here exceeded the scope of Knopf’s official duties. A split panel concluded Knopf failed to show a violation of clearly established federal law on an essential element of his claim, thus the Court reversed the district court’s denial of sovereign immunity to Mayor Williams. View "Knopf v. Williams" on Justia Law

Plaintiffs Maria Fernandez and Laura Chacon’s Fair Labor Standards Act (FLSA) claims against Defendants Clean House and Cesar Barrida were dismissed. On appeal, Plaintiffs alleged Defendants failed to properly compensate them as employees. The general limitations period under the FLSA was two years, but that period is expanded to three years for willful violations. Plaintiffs’ employment ended between two and three years before they filed suit. Although the complaint alleged that Defendants’ violations had been willful, Defendants moved to dismiss the claims as untimely on the ground that Plaintiffs had not supported their allegation of willfulness with sufficiently specific facts. The district court agreed with Defendants and dismissed the claims with prejudice. Plaintiffs argued the statute of limitations was an affirmative defense which they did not need to anticipate in their complaint by alleging willfulness, and, in any event, their allegation of willfulness was adequate. The Tenth Circuit Court of Appeals agreed with this contention and reversed the district court’s dismissal of their claims. View "Fernandez v. Clean House" on Justia Law

The Tenth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after defendant pleaded guilty to possession of a firearm by a convicted felon. The court held that, regardless of whether the district court was correct in concluding that the affidavit was insufficient to establish probable cause, the good-faith exception to the warrant requirement precluded suppression of the fruit of the subsequent search. In this case, the affidavit supporting the warrant had enough indicia of reliability to support the detective's good faith reliance on the warrant. View "United States v. Knox" on Justia Law

The Tenth Circuit affirmed defendant's conviction and sentence for forcibly opposing a federal officer in violation of 18 U.S.C. 111(b), and three lesser crimes. The court held that a district court did not commit clear and obvious error by failing to instruct a jury that assault was an element of a section 111(a)(1) conviction; the invited error doctrine applied in cases such as this one, where the defendant requested the jury instruction he later challenged on appeal; and thus defendant's challenge to the section 111 jury instruction was precluded by the invited error doctrine. The court also held that the district court provided an adequate explanation of "generalized reasons" sufficient to enable the court to conduct a proper review and the imposition of the mental health treatment reasonably related to at least one of the statutory factors: defendant's history and characteristics. View "United States v. Jereb" on Justia Law

The Tenth Circuit affirmed the district court's grant of summary judgment to defendant after plaintiff brought a wrongful death action against it. Plaintiff's husband was killed during a guided horseback ride in a wilderness area of Yellowstone National Park and plaintiff filed suit against the company that provided the ride. The court held that the husband's fatal injuries did not stem from risks that were inherent in the particular sport or recreational activity in which he elected to participate—that is, a guided horseback trail ride in a wilderness area; plaintiff's state law claims for negligent misrepresentation and nondisclosure have no merit; and the court rejected plaintiff's challenge to the district court's award of costs. View "Dullmaier v. Xanterra Parks & Resorts" on Justia Law

The Tenth Circuit affirmed the district court's grant of summary judgment to defendant after plaintiff brought a wrongful death action against it. Plaintiff's husband was killed during a guided horseback ride in a wilderness area of Yellowstone National Park and plaintiff filed suit against the company that provided the ride. The court held that the husband's fatal injuries did not stem from risks that were inherent in the particular sport or recreational activity in which he elected to participate—that is, a guided horseback trail ride in a wilderness area; plaintiff's state law claims for negligent misrepresentation and nondisclosure have no merit; and the court rejected plaintiff's challenge to the district court's award of costs. View "Dullmaier v. Xanterra Parks & Resorts" on Justia Law

The Tenth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to being a felon in possession of firearms and ammunition. The court held that the affidavit submitted in support of the search warrant established a minimally sufficient nexus between the place to be searched and the suspected criminal activity to make the officers' reliance on the warrant reasonable. View "United States v. Chambers" on Justia Law

The Tenth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to being a felon in possession of firearms and ammunition. The court held that the affidavit submitted in support of the search warrant established a minimally sufficient nexus between the place to be searched and the suspected criminal activity to make the officers' reliance on the warrant reasonable. View "United States v. Chambers" on Justia Law