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

The case involves Scott Johnson, Harlene Hoyt, and Covey Find Kennel, LLC, who challenged the constitutionality of a Kansas statute that allows warrantless inspections of their homestead, where Mr. Johnson operates a business that houses and trains bird dogs. They also claimed that their constitutional right to travel was infringed by a statutory requirement that they make the premises available for inspection within 30 minutes of the arrival of an inspector. The United States District Court for the District of Kansas dismissed their complaint for failure to state a claim.The United States Court of Appeals for the Tenth Circuit affirmed the dismissal of their right-to-travel claim but remanded for further proceedings to determine whether Mr. Johnson’s business is closely regulated and, if so, whether warrantless inspections are reasonable under the Fourth Amendment. The court found that the boarding or training kennel industry was not clearly closely regulated, and the government had not shown that warrantless searches were necessary. The court also held that the regulations did not impose burdens beyond those commonly borne by owners of businesses who travel away from the locations of their businesses, and thus did not violate the plaintiffs' right to travel. View "Johnson v. Smith" on Justia Law

The case involves Robert Lewis Dear Jr., who was charged with attacking a Planned Parenthood clinic in Colorado Springs, Colorado, in 2015. Dear was found incompetent to stand trial due to a diagnosis of delusional disorder, persecutory type. Despite being found incompetent multiple times, the district court ordered Dear to be involuntarily medicated in an attempt to restore his competency, following a motion by the government.Previously, Dear had been in state custody for about four years, during which he was continually found incompetent to stand trial. In December 2019, the federal government indicted Dear on 68 counts. The government moved for a competency evaluation under 18 U.S.C. § 4241, which led to Dear being transferred to the United States Medical Center for Federal Prisoners in Springfield, Missouri. There, a psychiatrist evaluated Dear and determined that although he remained incompetent due to his delusional disorder, he was substantially likely to be restored to competency through the administration of antipsychotics.The United States Court of Appeals for the Tenth Circuit affirmed the district court's order for involuntary medication. The court held that the district court made sufficiently detailed factual findings and that those findings were not clearly erroneous. The court placed greater weight on the government’s experts due to their extensive experience restoring competency and their personal experience observing and interacting with Dear. View "United States v. Dear" on Justia Law

The case revolves around a mobile home fire that resulted in two deaths. The government accused Mr. Joseph Allen Hernandez of intentionally setting the fire, supported by expert testimony from a fire investigator. Mr. Hernandez claimed that he had accidentally started the fire. The trial resulted in convictions on two counts of second-degree murder in Indian Country and one count of arson in Indian Country.The United States District Court for the Eastern District of Oklahoma had allowed the fire investigator to give expert testimony, despite objections from the defense. The court also permitted the investigator to testify that he did not believe Mr. Hernandez's explanation of the fire's cause.On appeal, the United States Court of Appeals for the Tenth Circuit considered whether the district court had erred in allowing the fire investigator's expert testimony and whether the investigator's disbelief of Mr. Hernandez's explanation had intruded on a reasonable expectation of privacy. The appellate court found no error in the district court's decisions. The court held that the district court had not abused its discretion in allowing the fire investigator's expert testimony. It also found that the investigator's disbelief of Mr. Hernandez's explanation did not intrude on a reasonable expectation of privacy. The court affirmed the district court's rulings and Mr. Hernandez's convictions. View "United States v. Hernandez" on Justia Law

Leachco, Inc., an Oklahoma corporation that manufactures and markets various products, appealed the denial of its request for a preliminary injunction to halt administrative enforcement proceedings by the Consumer Product Safety Commission (CPSC). Leachco argued that the statutory removal protections for CPSC commissioners and administrative law judges (ALJs) violated Article II of the Constitution and the separation of powers. The district court denied Leachco's motion for a preliminary injunction, stating that even if Leachco's constitutional arguments were valid, the alleged constitutional violations were insufficient to establish that Leachco would suffer "irreparable harm" if the injunction was denied.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that under current Supreme Court and Tenth Circuit precedent, Leachco's subjection to proceedings before an agency whose officials allegedly have unconstitutional protection against removal is insufficient, by itself, to establish irreparable harm. The court also found that Leachco failed to show that the removal protections for CPSC commissioners and its administrative law judge were unconstitutional. Therefore, Leachco failed to satisfy the irreparable harm requirement necessary to obtain a preliminary injunction. View "Leachco v. Consumer Product Safety Commission" on Justia Law

The case involves Jose Luis Amador-Bonilla, a citizen of Guatemala and Nicaragua, who was charged with violating 8 U.S.C. § 1326, Illegal Reentry After Removal from the United States. Amador-Bonilla had entered the United States without authorization multiple times and had been removed six times. He was arrested in Oklahoma and charged with illegal reentry, an offense for which he had already been convicted twice. He moved to dismiss the indictment, arguing that the illegal reentry provision of the Immigration and Nationality Act violates his right to equal protection under the Fifth Amendment.The United States District Court for the Western District of Oklahoma denied Amador-Bonilla's motion to dismiss the indictment. The court determined that rational basis review applied to Amador-Bonilla’s challenge and that the challenge failed because Amador-Bonilla failed to show there was no “rational relationship between the disparity of treatment and some legitimate governmental purpose.” The court also found that even if the Arlington Heights framework arguably applied, Amador-Bonilla “failed to demonstrate that [8 U.S.C. § 1326] was passed with a discriminatory purpose as a motivating factor.”The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that 8 U.S.C. § 1326 does not violate the Fifth Amendment. The court found that Amador-Bonilla failed to show that Congress enacted the provision in 1952 with a discriminatory purpose as a motivating factor. The court also noted that all parties agreed that the provision otherwise satisfies rational basis review. View "United States v. Amador-Bonilla" on Justia Law

In this case, law enforcement officers responded to a drug overdose at the home of Corban Elmore. After securing the scene and prohibiting anyone from entering the house, the officers waited almost eight hours before applying for a search warrant. Once they had a warrant, they searched Elmore’s home and discovered two firearms in his bedroom. Elmore, a convicted felon, entered a conditional guilty plea to being a felon in possession of a firearm and appealed the denial of his motion to suppress the firearms.The District Court for the District of Colorado denied Elmore's motion to suppress the firearms, finding no Fourth Amendment violation. The court determined that the officers reasonably seized Elmore’s home because they had probable cause to believe the home contained evidence of drug possession and had good reason to fear that evidence would be destroyed before they could secure a search warrant. The court also concluded that the officers acted reasonably throughout the seizure, finding it appropriate for them to prohibit anyone from entering the home and to delay obtaining a warrant so that the lead detective could focus on his investigation.The United States Court of Appeals for the Tenth Circuit reversed the lower court's decision. The appellate court held that the eight-hour seizure of Elmore’s home was unreasonable under the Fourth Amendment and that the exclusionary rule required suppression of the firearms. The court found that the officers made no effort to reconcile their law-enforcement needs with Elmore’s Fourth Amendment interests in his home and extended the seizure longer than reasonably necessary to diligently secure a warrant. The court remanded the case for further proceedings. View "United States v. Elmore" on Justia Law

The case involves Bobby Pena, who pleaded guilty to one count of possession of child pornography. He reserved his right to appeal the district court's denial of his motion to suppress child pornography that was recovered on his devices pursuant to a search warrant. Pena argued that the affidavit upon which the search warrant was based did not present probable cause and that the federal agents did not act in good faith in executing the search warrant. He also argued that in the absence of probable cause and good faith, evidence of child pornography would not have been inevitably discovered on his electronic devices.The district court denied Pena's motion to suppress, concluding that the magistrate judge had a substantial factual basis to find probable cause. The court found that the file and folder names observed by Agent Kucenski indicated the presence of child pornography. The court also concluded that Pena's suspicious statements to officers supported a finding of probable cause. The court found that Pena's practices with his digital devices and Agent Kucenski's declarations regarding the practices of child pornography collectors supported a finding of probable cause.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that the district court did not err in finding that the affidavit established probable cause and provided a sufficient basis for the search warrant. The court also declined to remand Pena's fraud procurement case for resentencing. View "United States v. Pena" on Justia Law

The case revolves around Kimberly Graham, who was convicted for first-degree manslaughter and leaving the scene of a fatal accident. After her convictions became final, she applied for postconviction relief, arguing that she was a Native American and the events took place on a reservation. The state district court granted her relief and vacated her convictions based on the Supreme Court's ruling in McGirt v. Oklahoma, which stated that the State of Oklahoma lacked jurisdiction to prosecute crimes committed by Native Americans within a reservation. However, the Oklahoma Court of Criminal Appeals later overruled the precedent that allowed for the application of McGirt to convictions that had already become final. Consequently, the state district court reinstated Graham's convictions.Graham then sought a writ of prohibition from the Oklahoma Court of Criminal Appeals, arguing that a liberty interest had arisen from the order vacating her convictions. The court denied her request, stating that the new precedent prevented the application of McGirt to convictions that had become final and that the initial order vacating the convictions was unauthorized under Oklahoma law. Graham then sought habeas relief, claiming that the reinstatement of her convictions had arbitrarily stripped her of her liberty interest. The federal district court agreed with Graham and granted habeas relief.The United States Court of Appeals for the Tenth Circuit reversed the grant of habeas relief. The court held that regardless of whether the state appeals court had erred, its rejection of the due process claim was at least reasonable based on the facts and Supreme Court precedent. The court concluded that the state appeals court did not unreasonably determine the facts or apply a Supreme Court holding. Therefore, the federal district court should have deferred to the state appeals court. View "Graham v. White" on Justia Law

The case involves a lawsuit filed by the parents of Shamikle Jackson against four police officers for using unconstitutionally excessive force. Jackson had called 911, claiming that two people were dead inside an apartment and that he was holding others hostage. When the police arrived, they encountered Jackson's sister who informed them that Jackson was alone, unarmed, and might have mental health problems. However, as the officers proceeded to search the apartment, Jackson emerged from a bedroom with a machete and was shot and killed by the officers.The United States District Court for the District of Colorado denied the officers' motion for summary judgment based on qualified immunity. The court concluded that a reasonable jury could find that the officers recklessly created the need to use deadly force, thereby unreasonably violating Jackson's constitutional rights under clearly established law.The United States Court of Appeals for the Tenth Circuit reversed the lower court's decision. The appellate court found that the officers had a split second to respond to a deadly threat posed by Jackson. Under these circumstances, it was not clearly established that the officers recklessly created a situation where the use of deadly force was necessary. Therefore, the officers were entitled to qualified immunity. The court also rejected the claim that the other officers failed to intervene to prevent the violation of Jackson's rights, as there was no underlying constitutional violation. View "Flores v. Henderson" on Justia Law

The case revolves around Mr. Lyndell Daniels, who was detained by law enforcement officers who linked him to a stolen Glock firearm based on his name. Daniels was charged with being a felon in possession of a firearm. Daniels moved to suppress his name as the fruit of an unlawful investigative detention, arguing that the officers had no reasonable suspicion to detain him. The district court agreed with Daniels and granted his motion. The government appealed this decision, arguing that the district court erred because there was reasonable suspicion to detain Daniels.The case originated from a near-anonymous call to the Aurora Police Department, expressing concern about three Black men, wearing dark hoodies and jeans, intermittently taking guns in and out of their pockets and getting in and out of a dark SUV. The caller believed they were “getting ready to do something,” but reported no illegality. The police arrived at the scene and detained Daniels, who was standing near the SUV. The officers did not observe any illegal activity or firearms when they arrived.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that the totality of the circumstances known to the officer when he detained Daniels did not amount to reasonable suspicion. The court noted that the 911 call, the presence and actions of the SUV, the time of the encounter, and the location of the encounter were not sufficient to establish reasonable suspicion. The court concluded that Daniels' detention was unreasonable under the Fourth Amendment, and the district court's grant of Daniels' motion to suppress was proper. View "United States v. Daniels" on Justia Law