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

The case revolves around the defendant, Maurice Williams, whose supervised release was revoked after evidence was presented that he sold fentanyl to a confidential informant (CI) during a controlled buy. Williams had previously pleaded guilty to charges of distributing crack cocaine and unlawful possession of a firearm. His supervised release was revoked in 2020 due to violation of his release conditions, and he was sentenced to an additional 18 months’ imprisonment, followed by two years of supervised release. In 2023, his supervised release was recommended for revocation again due to alleged violations including unlawful possession of a controlled substance and committing another crime.The United States District Court for the District of Kansas held a revocation hearing where the government introduced evidence of the controlled buy, including testimony from Kansas City Police Officers and a video of the controlled buy. The court found that Williams sold fentanyl and therefore committed a Grade A violation, but did not find a violation related to the firearm. The court revoked his term of supervised release and sentenced him to 24 months’ imprisonment.On appeal to the United States Court of Appeals for the Tenth Circuit, Williams argued that the district court erred by admitting evidence of the controlled buy without conducting an interest-of-justice balancing test under Federal Rule of Criminal Procedure 32.1(b)(2)(C) to determine whether the CI should have been required to be available for cross-examination at the hearing, and that the evidence was insufficient to show that he sold fentanyl. The Court of Appeals affirmed the district court's decision, stating that no balancing test was required because the court did not rely on any hearsay statements by the CI, and the evidence was sufficient to establish guilt by a preponderance of the evidence. View "United States v. Williams" on Justia Law

The case involves Megan Hess and Shirley Koch, who were convicted of mail fraud for fraudulently obtaining, selling, and shipping dead bodies and body parts to medical research and body-broker companies. The United States District Court for the District of Colorado sentenced Hess to the statutory maximum of 20 years and Koch to 180 months. Both defendants appealed their sentences, arguing that the district court erred in its loss calculations and in applying sentencing enhancements.The United States Court of Appeals for the Tenth Circuit agreed with some of their arguments. The court found that the district court erred in calculating the loss suffered by the body-parts purchasers and in refusing to offset the actual loss suffered by the next-of-kin victims with the value of legitimate goods and services provided to them. The court also found that the district court erred in applying the large-number-of-vulnerable-victims enhancement and the sophisticated-means enhancement to Koch's sentence.The court vacated the sentences of both defendants and remanded the case for further proceedings. The court declined to reassign the case to a different judge on remand. View "United States v. Hess" on Justia Law

The case involves XMission, a Utah-based internet service provider, and PureHealth Research, a Wyoming LLC that sells nutritional supplements online. XMission sued PureHealth in federal district court in Utah, alleging that PureHealth sent thousands of unwanted promotional emails to XMission’s customers in Utah, violating state and federal law. This resulted in increased server maintenance costs and customer complaints for XMission. PureHealth moved to dismiss the case for lack of specific personal jurisdiction, arguing it lacked sufficient contacts with Utah and the lawsuit did not “arise out of or relate to” its forum conduct. The district court granted the motion.The United States Court of Appeals for the Tenth Circuit reversed the district court's decision. The court found that PureHealth knowingly sent marketing emails to XMission’s customers in Utah, which constituted purposeful direction of its activities at residents of the forum state. The court also found that XMission’s claims arose out of or related to those activities. Therefore, the court concluded that Utah had specific personal jurisdiction over PureHealth. The case was remanded for further proceedings. View "XMission, LC v. PureHealth Research" on Justia Law

The case involves a § 1983 excessive-force action brought by Marta Sanchez, the Estate of Stephanie Lopez, and Dominic Martinez against officers from the Littleton and Englewood Police Departments in Colorado. The plaintiffs alleged that the officers fired 66 bullets into their motionless vehicle while they were attempting to surrender, resulting in the death of Stephanie Lopez, severe injuries to Dominic Martinez, and rendering Marta Sanchez a paraplegic. The defendants, however, described a high-speed car chase following an armed carjacking, during which the plaintiffs allegedly used their vehicle as a weapon and endangered the public.The district court granted summary judgment to the defendants, ruling that they were entitled to qualified immunity. The court found that the plaintiffs failed to carry their burden on the clearly established law issue. The plaintiffs appealed this decision.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The appellate court found that the plaintiffs failed to provide a record-based factual universe upon which the court could conduct a clearly established law analysis. The court held that the plaintiffs effectively waived their review of their challenge to the district court’s grant of qualified immunity to the defendants. The court concluded that without a record-based factual universe reflecting the plaintiffs' version of events, it could not opine on whether the district court committed reversible error in concluding that the plaintiffs did not satisfy the clearly established law prong of the qualified-immunity test. View "Sanchez v. Guzman" on Justia Law

The case involves Angel Landa-Arevalo, who was indicted for conspiracy to distribute and possess with intent to distribute fifty grams or more of methamphetamine. He was tried alongside nine co-defendants. Landa-Arevalo was in pretrial confinement for 1,196 days, during which he objected to the protracted timeline and moved to sever his trial from his co-defendants to protect his Sixth Amendment right to a speedy trial. He also requested a mental competency hearing, arguing that his Fifth Amendment rights were violated by not providing him with a second, more extensive evaluation.The district court denied his motions and proceeded with the trial. A forensic psychologist was appointed to examine Landa-Arevalo and concluded that he was competent to stand trial. The court found him competent and proceeded with sentencing.On appeal to the United States Court of Appeals for the Tenth Circuit, Landa-Arevalo argued that the district court violated his Fifth Amendment rights by not ordering a second competency evaluation and his Sixth Amendment right to a speedy trial. The appellate court affirmed the district court's decision. It held that the district court did not abuse its discretion in determining Landa-Arevalo's competency and denying another evaluation. The court also found that Landa-Arevalo's Sixth Amendment right to a speedy trial was not violated, as the delays were caused by co-defendants and not the government. View "United States v. Landa-Arevalo" on Justia Law

The case revolves around the death of Daryl Clinton, who died in the Oklahoma County Jail four days after being booked. Clinton was arrested for driving under the influence and was evaluated at a hospital before being discharged and sent to jail. Despite reporting several health issues, including an inability to move his arms or upper body, Clinton's complaints were largely dismissed by medical personnel. He was found unresponsive in his cell and later pronounced dead at the hospital. The cause of death was listed as blunt force trauma to the cervical spine.The case was initially heard in the United States District Court for the Western District of Oklahoma. Equlla M. Brothers, the personal representative of Clinton's estate, filed a lawsuit against Tommie Johnson III, the Oklahoma County Sheriff, alleging that Johnson was deliberately indifferent to Clinton's serious medical needs, violating his Fourteenth Amendment rights. The district court denied Johnson's motion for summary judgment, and the case proceeded to trial. The jury returned a verdict in favor of Johnson.Upon appeal to the United States Court of Appeals for the Tenth Circuit, Brothers argued that the evidence at trial was insufficient to support the verdict, the jury instructions misled the jury on the systemic failure claim, and the district court erred in denying her motion to contact the jury. However, the appellate court found that Brothers had waived her challenge to the sufficiency of the evidence by failing to raise a Rule 50(a) or 50(b) motion or argue plain error. The court also found that Brothers' objections to the jury instructions were waived as she had not distinctly stated her objections and grounds for them at the district court. Lastly, the court found no abuse of discretion by the district court in denying Brothers' motion to contact the jury. The judgment of the district court was affirmed. View "Brothers v. Johnson" on Justia Law

The case involves the United States Department of Labor (DOL) and Ascent Construction, Inc., its CEO Bradley Knowlton, and the Ascent Construction, Inc. Employee Stock Ownership Plan (the Plan). The DOL investigated Ascent and Knowlton for potential breaches of their fiduciary duties under the Employee Retirement Income Security Act (ERISA). The DOL found that Knowlton had deposited over $311,000 of the Plan’s cash into Ascent’s checking accounts and used it to pay Ascent’s business expenses. The DOL also discovered that a former Ascent employee had requested a distribution from his retirement account but never received it, even though the Plan’s custodian had issued a distribution check at Knowlton’s request.The DOL filed a lawsuit alleging that Knowlton and Ascent had violated ERISA’s fiduciary-duty standard and prohibited-transaction rules. The DOL sought a preliminary injunction to remove Knowlton and Ascent as Plan fiduciaries and appoint an independent fiduciary to prevent further ERISA violations and dissipation of the Plan’s assets. The district court granted the DOL’s motion, and the defendants filed an interlocutory appeal.While the appeal was pending, the case proceeded in the lower court. The DOL filed an amended complaint and discovery commenced. The district court later entered a default judgment against the defendants due to their willful failure to engage in the litigation process and comply with the court’s orders. The court also issued a permanent injunction that superseded the preliminary injunction, permanently barring Knowlton and Ascent from serving as trustee and administrator of the Plan.The United States Court of Appeals for the Tenth Circuit dismissed the defendants' appeal as moot. The court reasoned that the preliminary injunction dissolved automatically with the entry of the final judgment, regardless of whether the final judgment was issued on the merits or by way of default judgment. The court concluded that granting the defendants’ requested relief—vacatur of the preliminary injunction—would have no “effect in the real world.” View "Su v. Ascent Construction" on Justia Law

This case arose from a raid by U.S. Immigration and Customs Enforcement (ICE) at Abel Ramirez-Peñaloza’s family home in Heber City, Utah. After Mr. Ramirez-Peñaloza was indicted for unlawful entry into the U.S., ICE officials attempted to arrest him at his home. During two searches of his home, officials detained and questioned his family members. The plaintiffs, some of Mr. Ramirez-Peñaloza’s family members who were detained during the searches, filed claims against the U.S. and the agents alleging Fourth Amendment and state law violations.The district court dismissed most of the plaintiffs’ claims, but allowed three claims to go to trial, where a jury returned a verdict in favor of the officers. The plaintiffs appealed the district court’s grant of summary judgment in favor of the officers on the excessive use of force and false arrest claims.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the dismissed claims were barred by the Federal Tort Claims Act’s (FTCA) judgment bar, which precludes suits against federal employees after the entry of final judgment on a claim against the U.S. for an analogous cause of action. Since the district court entered final judgment in favor of the U.S. on the plaintiffs’ analogous FTCA claims, the claims against the individual defendants were barred. View "Ramirez v. Reddish" on Justia Law

The defendant, Darnell Tyree-Peppers, was on supervised release after pleading guilty to stealing a firearm from a federally licensed dealer. During his supervised release, his probation officer filed a petition to modify the conditions of his supervision due to alleged violations. Later, the probation officer filed a petition for his arrest and revocation of supervision based on three alleged violations of his supervision conditions. The district court issued the requested warrant. The probation officer later submitted an amended petition alleging that Tyree-Peppers had been arrested by state police officers on charges of first-degree murder, aggravated burglary, and aggravated robbery, potentially violating the condition that he not commit another federal, state, or local crime.The district court for the District of Kansas did not conduct the hearing on the petition until after the expiration of Tyree-Peppers' supervised release term. The court granted the petition in part and ordered an additional one year of supervised release. Tyree-Peppers challenged the district court’s jurisdiction to revoke his supervised release, arguing that the delay in the revocation proceedings was not “reasonably necessary for the adjudication,” as required by 18 U.S.C. § 3583(i).The United States Court of Appeals for the Tenth Circuit disagreed with Tyree-Peppers. The court found that the delay was attributable to an ongoing state prosecution of Tyree-Peppers on the very serious charge of first-degree murder. The outcome of that proceeding was directly related to the question of whether Tyree-Peppers violated the condition of his supervised release forbidding him from committing a state crime. Therefore, the court affirmed the district court’s exercise of jurisdiction. View "United States v. Tyree-Peppers" on Justia Law

The case involves three transgender individuals, Rowan Fowler, Allister Hall, and Carter Ray, who sued the Governor of Oklahoma, the Commissioner of Health for the Oklahoma State Department of Health, and the State Registrar of Vital Records. The plaintiffs challenged an executive order issued by the Governor that directed the Oklahoma State Department of Health to stop amending sex designations on birth certificates. The plaintiffs, who had obtained court orders directing that their sex designations on official documents be amended, had their applications for amended birth certificates denied by the Department of Health, citing the Governor's executive order.The plaintiffs filed a lawsuit alleging that the policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment. The district court dismissed the case, ruling that the plaintiffs failed to state a claim. The plaintiffs appealed the decision.The United States Court of Appeals for the Tenth Circuit reversed the district court's dismissal of the equal protection claim, but affirmed the dismissal of the plaintiffs' substantive due process claim. The court found that the policy of denying sex-designation amendments on birth certificates was not rationally related to any legitimate state interest and therefore violated the Equal Protection Clause. However, the court affirmed the dismissal of the plaintiffs' substantive due process claim, concluding that the plaintiffs failed to allege that their involuntary disclosures of their transgender status amounted to state action. View "Fowler v. Stitt" on Justia Law