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

A police officer, Mathew Grashorn, shot a dog named Herkimer after responding to a business owner's call about a truck in a parking lot after hours. Upon arrival, Officer Grashorn saw the truck and two dogs, Bubba and Herkimer. Bubba initially ran towards the officer but returned to his owner when called. Herkimer then emerged and ran towards the officer, who shot the dog when it was a few feet away. Herkimer was later euthanized due to the injuries.The plaintiffs, Wendy Love and Jay Hamm, sued Officer Grashorn for violating the Fourth Amendment. The United States District Court for the District of Colorado denied the officer's motion for summary judgment based on qualified immunity, concluding that a jury could reasonably find that Herkimer did not pose an immediate danger, and thus the shooting could be a clearly established violation of the Fourth Amendment.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court upheld the district court's denial of summary judgment, agreeing that a jury could find no immediate danger and that the officer had time to consider non-lethal options. The court emphasized that common sense and case law clearly establish that shooting a pet dog without an immediate threat constitutes a Fourth Amendment violation. The court also rejected the officer's argument that a reasonable mistake about the danger would grant him qualified immunity, as the district court's factual conclusions suggested the mistake was unreasonable. The Tenth Circuit affirmed the district court's decision, denying qualified immunity to Officer Grashorn. View "Love v. Grashorn" on Justia Law

Dedric Mayfield, a felon, was convicted by a jury of possessing ammunition in violation of 18 U.S.C. § 922(g)(1) after being recorded by a police-operated camera firing a handgun during an altercation. Mayfield had five prior adult felony convictions. Before trial, he did not stipulate to the authenticity or admissibility of any government exhibits. When the camera operator became unavailable for trial, Mayfield volunteered to stipulate to the authenticity and admissibility of the footage, allowing a detective to testify about it. The district court denied the government's motion for a continuance and instructed Mayfield to stipulate to the authenticity and admissibility of exhibits unless he had a good-faith basis not to do so. Mayfield stipulated to some exhibits, and the jury found him guilty. He was sentenced to 120 months in prison.The United States District Court for the District of Colorado handled the initial trial. Mayfield did not object to the district court's instructions regarding stipulations during the trial. He later argued that these instructions violated his Sixth Amendment fair-trial and Fourteenth Amendment due-process rights by coercing his counsel into stipulating to the government's evidence, thus depriving him of a fair trial.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court assumed without deciding that the district court's instructions were erroneous but found that Mayfield failed to demonstrate a reasonable probability that the outcome of the trial would have been different but for the error. The court also rejected Mayfield's argument that 18 U.S.C. § 922(g)(1) is facially unconstitutional under the Second Amendment, citing precedent that upheld the statute's constitutionality. The Tenth Circuit affirmed the district court's decision. View "United States v. Mayfield" on Justia Law

K.A. and C.P. were married and had three daughters. Their marriage ended in divorce, and the Arapahoe County Department of Human Services (ACDHS) initiated actions against K.A. regarding her relationships with her children, leading to the termination of her parental rights and several contempt judgments. K.A. attempted to appeal the termination, but the Colorado Court of Appeals denied it as untimely, and the Colorado Supreme Court declined review. She also sought to appeal a contempt sentence, but it was again deemed untimely.K.A. filed a complaint under 42 U.S.C. § 1983 in the United States District Court for the District of Colorado against Michelle Barnes, Executive Director of the Colorado Department of Human Services (CDHS), in her official capacity; ACDHS; and Michelle Dossey, Manager of the ACDHS Division of Child and Adult Protective Services, in her official capacity. The Arapahoe County Board of Commissioners was initially named but later dismissed by K.A. The district court dismissed K.A.'s claims and denied her motion to amend her complaint. K.A. filed a timely appeal.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that it lacked jurisdiction to hear K.A.'s claims due to sovereign immunity, the Rooker-Feldman doctrine, and lack of standing. The court found that K.A.'s claims for damages were barred by sovereign immunity, and her requests to reverse the termination of her parental rights and order a new hearing were barred by the Rooker-Feldman doctrine. Additionally, her requests for declaratory relief were either barred by sovereign immunity or lacked standing. The court also upheld the district court's denial of K.A.'s motion to amend her complaint, as she failed to explain how the amendments would cure the jurisdictional defects. View "K.A. v. Barnes" on Justia Law

The case involves Early Willard Woodmore, III, who was convicted for his role in a methamphetamine distribution enterprise in eastern Oklahoma. The Drug Enforcement Administration (DEA) began investigating the Woodmore organization in 2018 after receiving a tip about methamphetamine shipments. Early Woodmore, along with his siblings Calvin and Amber, led the organization. They received methamphetamine from Kimberly Noel in California, who shipped the drugs concealed in everyday objects. The organization distributed the drugs in smaller quantities throughout eastern Oklahoma. Early Woodmore was arrested in April 2019 and continued to communicate with his sister Amber, who took over operations. The DEA intercepted a significant methamphetamine shipment in August 2019, leading to further charges.The United States District Court for the Eastern District of Oklahoma indicted Early Woodmore on five counts, including conspiracy to distribute methamphetamine and money laundering. He proceeded to a joint trial with his brother Calvin in April 2022. The jury convicted Early Woodmore on all counts, and he was sentenced to life imprisonment for the drug charges and 240 months for the money laundering charges, to run concurrently.The United States Court of Appeals for the Tenth Circuit reviewed the case. Early Woodmore raised three main challenges: judicial bias due to the district court's handling of a custody dispute during the trial, an erroneous jury instruction regarding the right of attorneys to interview witnesses, and the lack of a definitional instruction for "methamphetamine (actual)." The Tenth Circuit rejected all three challenges. The court found no judicial bias, upheld the jury instruction on attorney interviews, and determined that the term "methamphetamine (actual)" was sufficiently clear based on the evidence presented at trial. Consequently, the Tenth Circuit affirmed the district court's judgment of conviction. View "United States v. Woodmore" on Justia Law

Brandon K. Thompson was convicted of being a felon in possession of a firearm. The incident occurred when employees at an AT&T store in Sandy, Utah, noticed Thompson tampering with Apple watches. After confronting him about a missing watch, an employee activated a security alarm, alerting the police. When officers arrived, Thompson initially agreed to a pat-down but then fled the store. During the ensuing chase, Thompson grabbed an officer's firearm, partially pulling it out of the holster and firing a round into the ground. He was eventually subdued and detained.The United States District Court for the District of Utah reviewed the case, where Thompson was found guilty and sentenced to 110 months in prison and three years of supervised release. Thompson appealed, arguing that the jury instructions on actual possession were incorrect, the jury was not instructed on his theory of the case, the evidence was insufficient to demonstrate knowing possession, and that 18 U.S.C. § 922(g)(1) was an unconstitutional exercise of Congress’s power under the Commerce Clause.The United States Court of Appeals for the Tenth Circuit reviewed the appeal. The court held that the district court did not abuse its discretion in its jury instructions regarding actual possession, as the instructions accurately stated the law. The court also found that the district court adequately conveyed Thompson’s theory of the case through its instructions. Furthermore, the court determined that there was sufficient evidence to show that Thompson had actual possession of the firearm, given the video evidence and witness testimonies. Lastly, the court affirmed the constitutionality of 18 U.S.C. § 922(g)(1) under the Commerce Clause, citing precedent from the Supreme Court and the Tenth Circuit. The judgment of the district court was affirmed. View "United States v. Thompson" on Justia Law

Federal law criminalizes the possession of a firearm in furtherance of drug trafficking. Jorge Enrique Barragan-Gutierrez was indicted for this crime after a firearm and drugs were found in his home. He admitted to receiving a gun as payment in a drug transaction and pleaded guilty, resulting in a 211-month sentence, later reduced to 181 months. He now challenges his sentence through a habeas petition, arguing that recent Supreme Court decisions in New York State Rifle & Pistol Ass’n, Inc. v. Bruen and United States v. Rahimi render his sentence unconstitutional under the Second Amendment.The United States District Court for the District of Wyoming denied his petition, finding it time-barred. The court concluded that the Supreme Court decisions did not apply retroactively to his case and that his argument would fail on the merits because he was convicted for possessing a firearm in furtherance of a crime, not merely for possession.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the Supreme Court's decisions in Bruen and Rahimi did not recognize a new constitutional right applicable to Barragan-Gutierrez’s circumstances. The court noted that these decisions did not extend to relieve felons convicted before those rulings. Consequently, Barragan-Gutierrez’s petition was deemed untimely, as the one-year period to challenge his conviction had passed in 2016. The Tenth Circuit affirmed the district court’s dismissal of his petition. View "United States v. Barragan-Gutierrez" on Justia Law

Germaine Coulter was found guilty of child sex trafficking and conspiracy to commit child sex trafficking, resulting in a 360-month imprisonment sentence. The district court ordered Coulter to pay $386,000 in restitution to two victims. Coulter appealed, arguing that the government failed to prove he was the but-for cause of the victims' injuries and that the restitution amount was unsupported by evidence.The United States District Court for the Western District of Oklahoma initially handled the case, where Coulter was convicted by a jury on two counts. He appealed his conviction and sentence, but the Tenth Circuit Court of Appeals affirmed both. Following the appeal, the government sought restitution, and the district court awarded $198,000 for Doe 1 and $188,000 for Doe 2, covering ten years of therapy, psychiatric treatment, and medication. The court rejected the government's request for lifetime treatment costs and lost wages, finding them speculative.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the government met its burden of proving Coulter was the but-for cause of the victims' injuries, as the expert testimony established a direct link between the victims' symptoms and the sex trafficking. The court also found no abuse of discretion in the district court's decision to limit the restitution to ten years, as it was a reasonable projection based on the evidence presented. The Tenth Circuit affirmed the district court's restitution award. View "United States v. Coulter" on Justia Law

David Knellinger and Robert Storey discovered that the state of Colorado had taken possession of their property under the Revised Uniform Unclaimed Property Act (RUUPA). They filed a lawsuit under 42 U.S.C. § 1983, claiming that Colorado's unclaimed property scheme violated the Takings Clause of the Fifth Amendment. The plaintiffs alleged that Colorado took their property for public use without just compensation and did not provide them with notice or compensation.The United States District Court for the District of Colorado dismissed the plaintiffs' claims for lack of standing. The court found that Knellinger and Storey failed to sufficiently allege ownership of the property at issue, partly because they did not file an administrative claim to establish ownership as required by RUUPA. The district court also dismissed the plaintiffs' equitable claims, concluding that § 1983 provided an adequate basis for obtaining just compensation.The United States Court of Appeals for the Tenth Circuit reviewed the case and determined that the district court erred in dismissing the plaintiffs' claims for monetary relief. The appellate court held that Knellinger and Storey had plausibly alleged that Colorado took their property for public use without just compensation, which is sufficient to confer standing. The court emphasized that property owners need not file administrative claims with Colorado before suing for just compensation under the Takings Clause. However, the appellate court affirmed the district court's dismissal of the plaintiffs' equitable claims, as § 1983 provides an adequate remedy for obtaining just compensation.The Tenth Circuit reversed the district court's dismissal of the plaintiffs' damages claims and remanded the case for further proceedings consistent with its opinion. View "Knellinger v. Young" on Justia Law

Two elderly individuals, Ms. Penelope Lamle and Ms. Maxine Houston, applied for Medicaid but faced delays and additional questions from the Oklahoma Department of Human Services, allegedly directed by attorney Susan Eads. They refused to answer these questions and subsequently sued, seeking an expedited decision, payment of Medicaid benefits, and damages. Both applicants died during the litigation, and their estates were substituted as parties in the appeal.The United States District Court for the Western District of Oklahoma dismissed the action with prejudice, citing the plaintiffs' failure to state a valid claim. However, the court was unaware that the applicants had died while the action was pending.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the claims for an injunction became moot when the agency denied benefits and the applicants died. The court noted that the requested relief would no longer benefit the estates, as the Oklahoma Department of Human Services had already denied the applications. The court also held that the Eleventh Amendment barred the requested retrospective relief. Consequently, the court remanded the case to the district court with instructions to vacate the judgment on the claim for a prospective injunction and dismiss it without prejudice.Regarding the claim against Ms. Eads in her individual capacity, the Tenth Circuit held that she was entitled to qualified immunity. The court found that the plaintiffs did not allege facts showing the violation of a clearly established right. As a result, the court affirmed the dismissal with prejudice of the claim for damages against Ms. Eads. View "Lamle v. Eads" on Justia Law

Derek Ray Flaming was convicted of distribution and receipt of obscene visual representations of sexual abuse of children, aggravated sexual abuse, and attempting to cause a minor to engage in a sexual act by placing her in fear. The charges stemmed from incidents involving his minor stepdaughter, Jane Doe, in South Korea and Colorado. Flaming showed Doe child pornography, sexually assaulted her, and attempted to obtain oral sex from her. Evidence included Skype messages where Flaming threatened to assault Doe if his wife did not return home immediately.The United States District Court for the Northern District of Oklahoma convicted Flaming on all counts. Flaming appealed, challenging the sufficiency of the evidence and the district court’s evidentiary rulings. He argued that the government failed to prove he was not a South Korean national, that there was insufficient evidence he received child pornography, and that there was insufficient evidence he placed Doe in fear to engage in a sexual act. He also contended that the district court improperly limited cross-examination of Doe and erroneously admitted summaries of Skype chats.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that sufficient evidence supported the jury’s finding that Flaming was not a South Korean national, since the Department of Defense records and other evidence indicated he was solely a U.S. citizen. The court also found sufficient evidence that Flaming received child pornography, since the images were found on a computer he had access to, and his personal Skype account was used to send child pornographic images. Additionally, the court held that sufficient evidence supported the finding that Flaming placed Doe in fear, given his previous sexual abuse and the circumstances of the incident.The court rejected Flaming’s evidentiary challenges, ruling that the district court did not violate his Confrontation Clause rights or abuse its discretion in limiting cross-examination, since Flaming failed to lay a proper foundation for the alleged prior inconsistent statements. The court also upheld the admission of summaries of Skype chats, finding they were accurate and the underlying information was admissible and voluminous. The Tenth Circuit affirmed the district court’s judgment. View "U.S. v. Flaming" on Justia Law