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

Williams International Company LLC designed, manufactured, and serviced small jet engines. Dodson International Parts, Inc., sold new and used aircraft and aircraft parts. After purchasing two used jet engines that had been manufactured by Williams, Dodson contracted with Williams to inspect the engines and prepare an estimate of repair costs, intending to resell the repaired engines. Williams determined that the engines were so badly damaged that they could not be rendered fit for flying, but it refused to return one of the engines because Dodson had not paid its bill in full. Dodson sued Williams in federal court alleging federal antitrust and state-law tort claims. Williams moved to compel arbitration under the Federal Arbitration Act (FAA), relying on an arbitration clause on the original invoices. The district court granted the motion, and the arbitrator resolved all of Dodson’s claims in favor of Williams. Dodson then moved to reconsider the order compelling arbitration and to vacate the arbitrator’s award. The court denied both motions and, construing Williams’s opposition to the motion for vacatur as a request to confirm the award, confirmed the award. Dodson appealed, challenging the district court’s order compelling arbitration and its order confirming the award and denying the motions for reconsideration and vacatur. After review, the Tenth Circuit affirmed, holding: (1) the claims in Dodson’s federal-court complaint were encompassed by the arbitration clause; (2) the district court did not abuse its discretion in denying Dodson’s untimely motion to reconsider; and (3) that Dodson failed to establish any grounds for vacatur of the arbitrator’s award or for denial of confirmation of the award. View "Dodson International Parts v. Williams International Company" on Justia Law

Dr. Rachel Tudor sued her former employer, Southeastern Oklahoma State University, under Title VII, claiming discrimination on the basis of sex, retaliation, and a hostile work environment after Southeastern denied her tenure, denied her the opportunity to reapply for tenure, and ultimately terminated her from the university. A jury found in favor of Dr. Tudor on her discrimination and retaliation claims and awarded her damages. The district court then applied the Title VII statutory cap to reduce the jury’s award, denied Dr. Tudor reinstatement, and awarded front pay. Both Dr. Tudor and the University appealed: Southeastern challenged certain evidentiary rulings and the jury verdict; Dr. Tudor challenged several of the court’s post-verdict rulings, the district court’s denial of reinstatement, the calculation of front pay, and the application of the statutory damages cap. After review, the Tenth Circuit rejected Southeastern’s challenges. Regarding Dr. Tudor’s appeal however, the Court held that there was error both in denying reinstatement and in calculating front pay, although there was no error in applying the Title VII damages cap. Affirming in part and reversing in part, the Court remanded the case back to the district court for further proceedings. View "Tudor, et al. v. Southeastern OK St. University, et al." on Justia Law

Jose Burciaga-Andasola appealed his convictions for distributing methamphetamine and heroin, arguing that the district court violated Federal Rule of Evidence 605 by improperly testifying as a witness during his jury trial. Andasola’s convictions arose from a February 2017 drug deal: an FBI informant called Andasola, asked to buy three ounces of heroin, and planned to meet up with Andasola later in the week. During this call and others, Andasola discussed the product he was selling using coded language; the meeting was recorded using a hidden camera. The informant delivered packages he received from Andasola to an FBI agent. When weighed and tested, these packages held about two pounds of methamphetamine and half a pound of heroin. Three weeks later, in another recorded meeting with the informant and an undercover agent, Andasola collected payment for the earlier drug deal and discussed prices for future deals. At trial, the government presented testimony from law enforcement in addition to the informant’s phone calls with Andasola arranging the drug deal, hidden-camera video of both the drug deal and the later meeting with the undercover agent to collect payment, and transcripts of and screenshots from the audio recordings and the hidden-camera videos. Andasola testified in his own defense. On cross-examination, Andasola at times suggested that he did not remember the events shown in the video, testifying at one point that though it looked like he was in the videos, Andasola asserted the “video’s been changed” to look like he handed the packages to the informant, which he “never did.” Because defense counsel’s question as to the differences Andasola observed “between that video and this video” implied that there were two videos, the government asked the district court to instruct the jury that there was only one video. In the end, the jury convicted Andasola of both offenses, and the district court imposed concurrent 150-month prison sentences and a five-year term of supervised release. The Tenth Circuit Court of Appeals agreed that the district court erred, but that the government established the error was harmless beyond a reasonable doubt. Therefore, Andasola's convictions were affirmed. View "United States v. Andasola" on Justia Law

Plaintiff John Hayes prosecuted his employment discrimination case to a favorable verdict and judgment. During trial, two instances of misconduct prompted Defendant SkyWest Airlines, Inc. to request a mistrial. But it was Defendant’s own misconduct. Thus, the district court tried to remedy the misconduct and preserve the integrity of the proceedings, but did not grant Defendant’s request. After the trial, exercising its equitable powers, the district court granted Plaintiff’s request for a front pay award. Following final judgment, Defendant moved for a new trial based, in part, on the district court’s handling of the misconduct incidents and on newly discovered evidence. The district court denied that motion. Defendant appealed, asking the Tenth Circuit Court of Appeals to reverse and remand for a new trial or, at the very least, to vacate (or reduce) the front pay award. Finding the district court did not abuse its discretion or authority in this case, the Tenth Circuit affirmed the front pay award. View "Hayes v. Skywest Airlines" on Justia Law

After law enforcement executed a search warrant on Defendants Huanyu Yan and You Lan Xiang’s home (“Doane home”) and seized 878 marijuana plants, Defendants moved to suppress arguing the exception to the good faith rule applied. When law enforcement seizes evidence in good faith reliance on a search warrant issued by a detached and neutral magistrate, that evidence will not be subject to suppression even if a court later invalidates that warrant. The district court disagreed and denied their motion. Defendants proceeded to a joint jury trial where a jury convicted them of: (1) Conspiracy to Manufacture and Possess with Intent to Distribute 100 or more Marijuana Plants; (2) Manufacturing and Possessing with Intent to Distribute 100 or more Marijuana Plants; and (3) Using and Maintaining a Drug-Involved Premises. At the close of the government’s case, Mr. Yan moved for judgment of acquittal, arguing the government offered insufficient evidence to sustain his conspiracy conviction. The district court denied his motion. Defendants appealed the district court’s suppression ruling, and Mr. Yan separately appealed the district court’s denial of his motion for judgment of acquittal. Finding no reversible error, the Tenth Circuit Court of Appeals affirmed the district court. View "United States v. Xiang" on Justia Law

At the time this appeal was initiated, Jason Brooks was a Colorado-state inmate serving a lengthy prison sentence for securities fraud. Brooks had an extreme and incurable case of ulcerative colitis: even when his disease was well treated, Brooks suffered from frequent, unpredictable fecal incontinence. This case involved the Colorado Department of Corrections’s (“CDOC”) efforts, or lack thereof, to deal with the impact of Brooks’s condition on his ability to access the prison cafeteria. Specifically, the issues presented centered on whether the district court erred when it concluded: (1) Brooks’s Americans with Disabilities Act (“ADA”) claim for damages failed because the CDOC’s offer to provide Brooks with adult diapers was a reasonable accommodation of Brooks’s disability; and (2) Brooks’s Eighth Amendment claim against ADA Inmate Coordinator Julie Russell failed because the decision not to access the cafeteria with the use of adult diapers was Brooks’s alone. The Tenth Circuit Court of Appeals determined the district court erred in its treatment of Brooks’s ADA claim for damages. "A reasonable juror could conclude the offer of adult diapers was not a reasonable accommodation of Brooks’s disability. Thus, at least as to the question of the reasonableness of the proposed accommodation, the district court erred in granting CDOC summary judgment on Brooks’s ADA claim for damages." On the other hand, the Court concluded the district court correctly granted summary judgment in favor of Russell on Brooks’s Eighth Amendment claim: "the record is devoid of sufficient evidence for a jury to find Russell acted with a sufficiently culpable state of mind—deliberate indifference to Brooks’s ability to access food—when she declined Brooks’s request for a movement pass." Accordingly, the Court dismissed in part, reversed in part, and remanded this matter to the district court for further proceedings. View "Brooks v. CDOC, et al." on Justia Law

When Seminole Nursing Home, Inc. failed to pay $61,916.19 in federal employment taxes due for 2013, the IRS provided notice to Seminole of its intent to issue a levy to collect these unpaid taxes plus penalties and interest. Seminole challenged the validity of a Tax Code regulation that restricts economic hardship to individual taxpayers who fail to pay delinquent taxes after notice and demand. Seminole contended the economic-hardship exception should be applied to all taxpayers, including corporations. The United States Tax Court rejected the contention on the ground that the regulation was a reasonable interpretation of an ambiguous statute. The Home appealed, but agreeing with the Tax Court, the Tenth Circuit Court of Appeals affirmed. View "Seminole Nursing Home v. Comm'r of Internal Revenue" on Justia Law

Plaintiff Samantha Gerson was allegedly sexually abused when she was 15 years old by an employee (the Perpetrator) at Logan River Academy, a residential treatment facility in Logan, Utah. She filed suit against Logan River a decade later in the United States District Court for the Central District of California, from which the case was transferred to the United States District Court for the District of Utah. Logan River moved to dismiss on the ground that the suit was barred by Utah’s applicable statute of limitations. Gerson responded that the suit was timely under California law. The district court applied California’s choice-of-law doctrine, determined that Utah’s statute of limitations governed, and granted the motion to dismiss. Finding no reversible error in that decision, the Tenth Circuit Court of Appeals affirmed dismissal. View "Gerson v. Logan River Academy, et al." on Justia Law

During a traffic stop, law-enforcement officers ordered the passenger, defendant-appellant Colt Malone, to exit the car. He complied, and the officers found a pistol. Based on the presence of this pistol, the government charged Malone with possession of a firearm after a felony conviction. Malone moved to suppress evidence of the pistol, arguing that the officers had violated the Fourth Amendment by prolonging the traffic stop. The district court denied the motion to suppress, leading Malone to enter a conditional guilty plea and to appeal. After review of the trial court record, the Tenth Circuit affirmed: "[e]ven if the officers had detoured from the mission of the traffic stop, the district court had made a factual finding that the officers did not prolong the stop and Mr. Malone waived any challenge to that finding. So introduction of the pistol into evidence would not have violated the Fourth Amendment." View "United States v. Malone" on Justia Law

Claud “Rick” Koerber was indicted by a grand jury for wire fraud, tax fraud, and mail fraud relating to a real estate investment scheme. A superseding indictment added to his wire fraud and tax evasion counts, charging him with additional counts for securities fraud, wire fraud, money laundering, and tax evasion. More than five years passed without a trial, resulting in the district court’s dismissing the case with prejudice under the Speedy Trial Act. On the government’s appeal of that decision, the Tenth Circuit Court of Appeals reversed the district court’s dismissal-with-prejudice order, identifying errors in its application of the Speedy Trial Act factors. On remand, after reapplying the factors, the district court decided to dismiss without prejudice. So in 2017 the government reindicted Koerber for the offenses earlier charged in the superseding indictment. Koerber’s first trial ended in a hung jury. His second trial ended in jury convictions on all but two counts. The court later imposed a 170-month prison sentence. On appeal, Koerber challenged his prosecution and conviction, claiming a range of errors: from evidentiary rulings, to trial-management issues, to asserted statutory and constitutional violations. After reviewing the briefing, the record, and the relevant law, the Tenth Circuit found no reversible error and affirmed. View "United States v. Koerber" on Justia Law