Every decision we've summarized from United States Court of Appeals for the Tenth Circuit.
The Tenth Circuit enforced Megan Dees's appeal waiver, dismissing her challenge to a 183-month sentence for methamphetamine distribution. The court found the waiver was entered knowingly and voluntarily and that enforcing it would not result in a miscarriage of justice.
The Tenth Circuit affirmed summary judgment on a prisoner's retaliation claim regarding a threat to fire him from a kitchen job due to a lack of specific evidence about the job's value. However, the court reversed summary judgment on a separate retaliation claim involving a disciplinary charge, ruling that a finding of guilt does not preclude liability when the prisoner relies on suspicious timing and departures from prior practice.
The Tenth Circuit affirmed the denial of a motion to suppress evidence found in a home, ruling that the exclusionary rule does not apply even if a search warrant contained a clerical error in the street name. The court held that deputies objectively relied in good faith on a warrant issued by a neutral magistrate, meaning suppression would not deter police misconduct.
The Tenth Circuit affirmed Thomas Fairbanks's securities fraud convictions, ruling that the district court properly denied his motion to sever the counts and that sufficient evidence supported the verdict. The court found the joint trial did not prejudice the defendant and that the evidence established a unified fraudulent scheme against multiple victims.
The Tenth Circuit reversed a district court's dismissal of a prisoner's excessive force claim, holding that video evidence did not blatantly contradict the plaintiff's allegation of twenty-three taser strikes. The court further ruled that the district court abused its discretion by dismissing the case under Heck v. Humphrey without providing the plaintiff notice to address the bar under his own version of events.
The Tenth Circuit reversed a district court's dismissal of a prisoner's Eighth Amendment medical care claims, holding that the lower court erred by applying a pleading standard to a statute of limitations defense that requires factual development. The court clarified that accrual of a deliberate indifference claim depends on when a plaintiff knew or should have known of the defendant's subjective state of mind, a determination inappropriate for resolution on a Rule 12(b)(6) motion.
The Tenth Circuit affirmed the dismissal of claims against Texas officials but reversed the dismissal of claims against a Colorado social services worker. The court held that while the Rooker-Feldman doctrine bars challenges to the underlying Texas child support order, it does not preclude a due process claim regarding the refusal to hold a hearing on modified financial circumstances.
The Tenth Circuit affirmed the dismissal of Adrian Livingston's Section 1983 claims, ruling that his post-acquittal detention was justified by good-faith reliance on an inaccurate detention system. The court rejected arguments regarding malicious prosecution, statute of limitations, and supervisory liability, finding no constitutional violations or policy failures by the county.
The Tenth Circuit affirmed the dismissal of Richita Marie Hackford's pro se lawsuit challenging her classification under the Ute Partition Act. The court held that the statute grants the Secretary of the Interior broad discretion in determining membership rolls and that the statutory window for challenging such determinations has long closed.
The Tenth Circuit affirmed summary judgment for The Nature Conservancy, ruling that an alleged oral promise to allow construction was too indefinite to support a claim of promissory estoppel. The court held that the plaintiffs failed to meet Wyoming's strict proof requirements for a clear promise, reasonable reliance, or the necessity of enforcement to avoid injustice.