Justia Constitutional Law Opinion Summaries

Defendant-Appellant Adam Frost was tried and convicted for the rape of a 17-year-old girl, and was sentenced to 200 months' imprisonment. On appeal, Defendant challenged his conviction on the grounds that the trial court plainly erred in admitting hearsay testimony of several witnesses, including the victim's sister, a nurse, and law enforcement officers. Defendant also challenged his sentence, arguing that the district court violated his due process rights by not allowing him to make a statement at sentencing until after the court had already decided his sentence. Upon review, the Tenth Circuit found the district court did not plainly err in admitting the challenged testimony. Although some of the challenged testimony was admitted in error, none was so obvious or prejudicial as to warrant reversal. Furthermore, the Court concluded the district court's alleged error at sentencing did not seriously impair the fairness of the proceedings.

Defendant-Appellant Ronald Dougan was convicted of robbing a post office. He appealed the district court's imposition of special sex-offender conditions of release. The court imposed these requirements based on Defendant's criminal history, which included a thirty-three year old conviction for sexual battery and a seventeen-year old conviction for aggravated battery, originally charged as sexual battery. Because the underlying sexual offenses, when viewed in the factual context in which they arose, were too remote to be reasonably related to the present offense, the Tenth Circuit remanded the case with directions to vacate the special sex-offender conditions of release imposed as a part of Defendant's sentence. The Court dismissed Defendant's challenge to the district court's recommendation for treatment during incarceration for lack of jurisdiction.

Petitioners Leroy and Glenda Morris brought suit under 42 U.S.C. 1983 and the Supremacy Clause to challenge the Oklahoma Department of Human Services' ("OKDHS") denial of Mrs. Morris' application for Medicaid benefits as inconsistent with federal law. After calculating the couple's resources and the Community Spouse Resource Allowance (CSRA), OKDHS determined that the Morrises were ineligible for benefits. In an effort to "spend down" their excess resources, the Morrises purchased an actuarially sound annuity payable to Mr. Morris. Despite this purchase, OKDHS determined that Mrs. Morris remained ineligible. The district court granted summary judgment in favor of OKDHS, upholding the agency's application of the Medicaid statutes. Upon review, the Tenth Circuit reversed and remanded the case for further proceedings. A couple may convert joint resources (which may affect Medicaid eligibility) into income for the community spouse (which does not impact eligibility) by purchasing certain types of annuities. In other words, a couple may purchase a qualifying annuity payable to the community spouse in addition to the community spouse's retention of the CSRA.

Plaintiff-Appellant Cinnamon Hills Youth Crisis Center ran a residential treatment facility in St. George, Utah for young people with mental and emotional disorders. It wanted to expand its operations with a "step-down" program hereby participants would live in a separate facility with more responsibility and autonomy that other students in preparation for reentry to society. Cinnamon Hills applied to the City for a zoning variance to use the top floor of a hotel it owned for the program, the City denied its request. Cinnamon Hills subsequently sued the City for discrimination against the disabled. The district court granted summary judgment in favor of the City, and Cinnamon Hills appealed. Upon review of the district court record, the Tenth Circuit found that Cinnamon Hills could not prove by the evidence on record, instances of discrimination as it alleged. Accordingly, the Court affirmed the district court's decision in dismissing Cinnamon Hills' claims.

Plaintiff-Appellee Larry Frederick brought a putative class action suit against Hartford Underwriters Insurance Company (Hartford) in Colorado state court; Hartford removed the case to federal court. Looking to the face of Plaintiff’s complaint, the district court concluded that the amount in controversy did not exceed $5,000,000 (which was required for federal jurisdiction under the Class Action Fairness Act (CAFA)). Accordingly, the district court remanded the case to state court. In reaching its decision, the district court acknowledged that the Tenth Circuit had not defined the burden a defendant must carry to prevent a remand in a CAFA suit. Faced with this question, the Tenth Circuit held that a defendant in these circumstances is entitled to present his own estimate of the amount at stake and must show by a preponderance of the evidence that the amount in controversy exceeds the amount in 28 U.S.C. 1332(d)(2) (currently $5,000,000). The Court emphasized that the preponderance standard applies to punitive damages as well, and that such damages cannot be assumed when calculating the amount in controversy. Accordingly, the Court reversed the district court and remanded the case for further proceedings.

Plaintiff-Appellant Teresa Hernandez sued Defendant-Appellee Valley View Hospital Association for race and national origin discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e to 2000e17. The district court granted summary judgment for Valley View on Plaintiff's claims for hostile work environment and constructive discharge, and dismissed her retaliation claim as time-barred. The court characterized Plaintiff's evidence as only "a handful of racially insensitive jokes and comments over a period of more than three years, which, while not laudable, would not support a racial or national origin hostile work environment claim." Plaintiff appealed the grant of summary judgment to the hospital. Upon review, the Tenth Circuit reversed, finding that Plaintiff did "marshal" sufficient hostile work environment evidence to withstand summary judgment. The Court also reversed the grant of summary judgment as to Plaintiff's constructive discharge claim. Accordingly, the case was remanded to the district court for further proceedings.

Plaintiff-Appellant Dr. Ann Elaine Campbell put horses out to pasture on land she owns in two Oklahoma municipalities, Defendants-Appellees the City of Spencer (the City) and the Town of Forest Park (the Town). After an animal-welfare investigation, City and Town authorities executed search warrants and seized 44 horses from her properties. The two municipalities successfully petitioned a state court to order forfeiture of the horses unless the owner posted a security bond to pay for their maintenance from the date of seizure. After unsuccessfully appealing the forfeiture and bond determinations in state court, Plaintiff filed an action under 42 U.S.C. 1983 in federal court against the City and the Town, alleging that they violated the Fourth Amendment by unlawfully searching her property and seizing her horses; the Fifth Amendment by depriving her of her horses without due process or just compensation; and the Eighth Amendment by obtaining an excessive fine through an unreasonable forfeiture bond. The court held that it lacked jurisdiction under the "Rooker-Feldman" doctrine. On appeal Plaintiff contended that the district court erred in applying the Rooker-Feldman doctrine. Upon review, the Tenth Circuit affirmed in part, reversed in part, and remanded for further proceedings: "[The Court] agree[d] that the district court lacked jurisdiction to consider the Fifth and Eighth Amendment claims, which [were] barred by Rooker-Feldman because they challenged the state court judgment; but it erred in dismissing the Fourth Amendment claims to the extent that they concern[ed] preforfeiture events."

Plaintiff-Appellant Michael Turner, a member of the Kiowa Tribe, was charged by Oklahoma state authorities with instituting or encouraging cockfighting. The state court rejected his argument that the crime took place in Indian Country. While state prosecution was ongoing, Plaintiff requested that the Court of Indian Offenses for the Kiowa Tribe enjoin the state proceeding. That court dismissed for lack of subject matter jurisdiction. Plaintiff was subsequently convicted in state court. Plaintiff then sued the judges of the Court of Indian Offenses in federal district court. The district court denied relief, concluding that the defendants were entitled to sovereign immunity as tribal officials. After its review, the Tenth Circuit concluded that Plaintiff lacked standing because he could not establish redressability. Given the procedural posture of this case, it was unclear what, if any, action the district court could have taken to undermine Plaintiff's conviction.

Defendant-Appellant Michael Madden pled guilty to one count of being a felon in possession of a firearm, and reserved the right to appeal the district court's denial of his motions to suppress and to quash the indictment for excessive delay. He argued the district court erred in denying his motion to suppress because his detention and subsequent search of his vehicle violated the Fourth Amendment. Furthermore, he argued that the district court abused its discretion by denying his motion to quash the indictment because of a preindictment delay of four years violated his Fifth Amendment right to due process and his Sixth Amendment right to a speedy trial. Upon review, the Tenth Circuit concluded that the district court properly denied both motions. Neither Defendant's detention nor the search of his vehicle violated Defendant's constitutional rights: his investigatory detention was justified by articulable and reasonable suspicion and his subsequent arrest was supported by probable cause. Moreover, the search of Defendant's vehicle fell within the good-faith exception to the exclusionary rule. In addition, the preindictment delay did not violate the Fifth or Sixth Amendments. Defendant failed to show the requisite prejudice to establish a violation of his Fifth Amendment right to due process. Furthermore, because the delay occurred prior to Defendant's indictment, his Sixth Amendment right to a speedy trial was not violated.

Defendants William L. Pickard and Clyde Apperson were convicted of drug-related crimes in the United States District Court for the District of Kansas. An important witness for the prosecution was informant Gordon Todd Skinner, a criminal associate of Defendants. After the convictions were affirmed on appeal, Defendants filed motions for relief under 28 U.S.C. 2255 claiming, among other things, that the prosecution had violated their rights under "Brady v. Maryland",(373 U.S. 83 (1963)), and "Giglio v. United States", (405 U.S. 150 (1972)), by suppressing evidence of Skinner's criminal and informant background. The district court rejected the claims. Defendants applied for certificates of appealability (COAs) to appeal the district court's decision, but we denied their applications. They also filed district-court motions under Fed. R. Civ. P. 60(b) to set aside the court's judgment in the Section 2255 proceedings, raising multiple claims. Upon review, the Tenth Circuit agreed with the district court that Defendants' claims of "Brady/Giglio" violations at trial were second-or-successive claims; and because Defendants did not establish the requisites for authorizing a second-or-successive claim, the Court denied authorization. On the other hand, Defendants' claims that prosecutorial misconduct in the Section 2255 proceedings affected the integrity of those proceedings are proper Rule 60(b) claims; and the Court remanded those claims to the district court for resolution.