Tennille v The Western Union Company

Western appealed an order approving a 40 million fee for class counsel. The panel dismissed for lack of standing. It held that Western had no interest in the finds placed in the settlement fund as its right to reimbursement was speculative at this point as there is no way to know how much of the settlement fund will be left to offer to the states who may be entitled to relief under and escheatment theory, how many states will refuse to settle, how many if any judgments will be obtained against Western by non-settling states and no way to tell if any state would actually sue based on a small pro rata share of fees. Thus, there was no injury or traceability and thus no standing.

United States v Quiver

Quiver appealed his sentence. The panel affirmed holding that the district court properly applied the dangerous weapon enhancement because a Taser is a dangerous weapon as it can cause serious injury to eyes or other body parts and Quiver used the Taser here when he gained control of it and delivered a shock through direct contact with the arresting officer’s leg.