United States v Snowden

Snowden appealed his sentence for theft of computer files. The panel affirmed. It held that the district court may have errored in including the sunk costs of developing the database that Snowden stole, but , held any error was harmless as the district court provided an alternative rationale independent of the guidelines and sated it would have imposed the same sentence if it had been advised of the correct guideline range. The case was remanded to correct an error in the restitution amount.

J.H. v Bernalillo County

J.H. sued county and the arresting officer alleging constitutional and statutory violations when t eh officer arrested J.H.’s special needs child. The district court granted summary judgment to the defendants. The panel affirmed. It held the officer had probable cause to arrest the child who he saw kick a teacher, handcuff her and take her to a detention facility. It held that claims under the Americans with Disabilities Act were properly rejected as the kick, not perceived disability led to the arrest, the officer did not know of the disability and J.H. failed to identify any reasonable accommodation. Judgment for County was affirmed as there was no failure to train here as there were no constitutional or statutory violations.