United States v. Gigena

Court of Appeals for the Tenth Circuit·Decided August 13, 2026·No. 25-4112·Unpublished

Opinion

FILED

United States Court of Appeals Tenth Circuit

UNITED STATES COURT OF APPEALS August 13, 2026

FOR THE TENTH CIRCUIT

_________________________________ Christopher M. Wolpert Clerk of Court

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 25-4112 (D.C. No. 2:24-CR-00228-TS-CMR-1)

GABRIEL GIGENA, (D. Utah)

Defendant - Appellant.

ORDER AND JUDGMENT *

Before TYMKOVICH, McHUGH, and FEDERICO, Circuit Judges.

A jury convicted pro se appellant Gabriel Gigena of assaulting a federal officer. The district court then imposed a below-guidelines sentence. Gigena appeals the conviction and challenges the sentence as procedurally

After examining the briefs and appellate record, this panel has

*

determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument.

This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Federal Rule of Appellate Procedure 32.1 and Tenth Circuit Rule 32.1.

and substantively unreasonable. Exercising jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a), we affirm.

I

Following a domestic dispute in California, Gigena took his twin daughters to Utah in the middle of the night. A California court issued a warrant for Gigena’s arrest. The United States Marshal’s Service in Utah formed a task force to execute the warrant. The task force deputized local police officers for the assignment.

Task force police officers spotted Gigena and his daughters at a park in Park City, Utah. Gigena walked past a van where Officer Michael Piekarczyk and another officer were watching him. The officers got out of the van to arrest him. Officer Piekarczyk wore a task force badge at his hip and placard on his vest that said “POLICE.” Supp. R. I at 168.

Officer Piekarczyk ran toward Gigena and announced, “Gabriel” and “Police.” Id. at 131. He then knocked Gigena’s hands away from his daughters and tackled him to the ground. In response, Gigena got his arm around Officer Piekarczyk’s neck and put him in headlock. Officer Piekarczyk tried to break free but could not. He was able to call out, “He’s choking me.” Id. at 196.

Additional officers arrived announcing themselves. One officer secured the children while others tried to free Officer Piekarczyk. The

officers ordered Gigena to stop fighting, and Gigena, who claims to be a tribal chief, said, “You can’t arrest me. I’m a chief.” Id. at 203. Police car lights continued to flash, and sirens continued to blare.

The officers eventually succeeded in prying Gigena’s hands apart by peeling his fingers away individually to break his grip. Officer Piekarczyk sustained injuries to his neck, back and head from Gigena’s headlock. The police arrested Gigena. A federal grand jury indicted Gigena for assaulting a federal officer in violation of 18 U.S.C. §§ 111(a)(1) and 1114.

Judge Ted Stewart was assigned to Gigena’s case. He had originally been assigned to a civil case filed by Gigena, but he recused from that case due to another judge’s scheduling conflict and the parties’ request to proceed on the scheduled trial date. Neither Gigena nor the government objected.

Before trial, Gigena submitted several pro se documents. The district court lodged these documents, but it did not consider them because Gigena was represented by counsel.

At trial, Gigena did not challenge the lawfulness of his arrest. Gigena also did not dispute that Officer Piekarczyk was a federal officer engaged in official duties. For his defense, Gigena argued that he had been subdued instantly, he had not assaulted the officer, he reacted to the sudden confrontation, and he had no intent to assault anyone. Gigena did not raise

self-defense, nor did he seek a self-defense instruction. Several officers testified that Gigena would not willingly release the chokehold on Officer Piekarczyk despite receiving orders to do so. The jury convicted Gigena.

After the verdict, Gigena moved to terminate his counsel and represent himself. The district court permitted him to do so. Gigena then filed a series of post-trial motions and moved the district court to adjudicate his pre-trial pro se documents. In a written order, the district court considered and rejected his post-trial motions concluding that: (1) Judge Stewart’s assignment to Gigena’s criminal case and subsequent recusal from Gigena’s civil case was not improper and did not require disqualification; (2) Gigena was not prohibited from testifying; (3) Gigena did not request a self-defense instruction, nor did he argue self-defense; and (4) there was no violation of Gigena’s Sixth Amendment right to a speedy trial. The district court then decided to review Gigena’s pre-trial documents and found no arguments of merit. The district court rejected Gigena’s argument that with no memorandum of understanding between the local law enforcement and the U.S. Marshals, the government could not establish Officer Piekarczyk was a federal officer. It also rejected his assertion that the district court did not have subject matter jurisdiction over the case because as a tribal chief, he was entitled to tribal immunity.

The district court sentenced Gigena to 15 months’ imprisonment and three years of supervised release – a sentence below the United States Sentencing Guidelines advisory range of 21-27 months’ imprisonment. It reasoned Gigena’s conduct was initially understandable given that he was tackled by surprise. Gigena timely appealed.

II

Gigena challenges decisions concerning claims in pre-trial documents he lodged while he was counseled and decisions concerning claims in post-trial motions he filed pro se. 1 As explained below, any issue relating to the pre-trial documents are waived.

As for the post-trial motions, we resolve them as follows: 1) several of Gigena’s post-trial claims fail to survive plain error review; 2) he fails to show the district court lacked subject matter jurisdiction based on tribal immunity; 3) the district court did not err in denying his motion to disqualify the trial judge; and 4) his ineffective assistance of counsel claim must be brought on collateral review. Gigena’s remaining arguments challenging the sufficiency of the evidence and the reasonableness of his sentence also fail.

1 Because Gigena proceeds pro se, we construe his pleadings liberally,

but we do not act as his advocate. See United States v. Sjodin, 139 F.4th 1188, 1205 (10th Cir. 2025) (observing the court will liberally construe a pro se litigant’s filings but will not make arguments for a litigant).

A

Gigena filed pre-trial documents that were lodged in the district court related to issues he raises on appeal – sufficiency of the indictment and vindictive prosecution. Under Federal Rule of Criminal Procedure 12(b)(3), a party must raise these challenges before trial. The district court declined to review them at the time he filed them because he had counsel. See United States v. Pearl, 324 F.3d 1210, 1216 (10th Cir. 2003) (denying motion to file a pro se pleading because the litigant was represented). Post-trial, the district court allowed Gigena to proceed pro se and decided that “[o]ut of an abundance of caution,” it would review “the pre-trial lodged documents in search of any arguments that could support a new trial or acquittal,” but found none of merit. R. I at 96. Gigena does not challenge this decision, so he has waived any argument on these issues. Sawyers v. Norton, 962 F.3d 1270, 1286 (10th Cir. 2020) (“Issues not raised in the opening brief are deemed abandoned or waived.” (internal quotation marks omitted)).

B

1

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