10th Circuit Case Commentaries

Hall v. Miller: Specific Objections Required to Avoid Firm Waiver; Prison Lockdowns Rarely Support Equitable Tolling of AEDPA Deadlines

Date: Jun 22, 2026

Hall v. Miller: Specific Objections Required to Avoid Firm Waiver; Prison Lockdowns Rarely Support Equitable Tolling of AEDPA Deadlines Court: United States Court of Appeals for the Tenth Circuit...

Credible Innocence Showing Required to Withdraw a Guilty Plea; Bare National Statistics Do Not Establish Unwarranted Sentencing Disparity

Date: Jun 22, 2026

Credible Innocence Showing Required to Withdraw a Guilty Plea; Bare National Statistics Do Not Establish Unwarranted Sentencing Disparity 1. Introduction In United States v. Miller (10th Cir. June...

Abusive Sexual Contact Is “Granular”: Lesser-Included Instructions Must Track the Same Touching, Not a Different Act

Date: Jun 22, 2026

Abusive Sexual Contact Is “Granular”: Lesser-Included Instructions Must Track the Same Touching, Not a Different Act Case: United States v. MacLean (10th Cir. June 18, 2026) (Order and Judgment,...

Substantial Influence Over Government Contracting Triggers the “Sensitive Position” Bribery Enhancement and Treats Fraudulent Change Orders as “Benefit” Under the Guidelines

Date: Jun 22, 2026

Substantial Influence Over Government Contracting Triggers the “Sensitive Position” Bribery Enhancement and Treats Fraudulent Change Orders as “Benefit” Under the Guidelines Introduction In United...

Cato v. Bridges — Requirement of Reasoned District-Court Analysis of AEDPA (d)(1)(B) “State-Created Impediment” and Equitable Tolling When Notice of State Postconviction Ruling Is Delayed

Date: Jun 17, 2026

Requirement of Reasoned District-Court Analysis of AEDPA (d)(1)(B) “State-Created Impediment” and Equitable Tolling When Notice of State Postconviction Ruling Is Delayed Case: Cato v. Bridges, No....

Younger Abstention Applies to Oklahoma Juvenile Deprived Proceedings as Sprint Quasi‑Criminal Civil Enforcement Actions

Date: Jun 17, 2026

Younger Abstention Applies to Oklahoma Juvenile Deprived Proceedings as Sprint Quasi‑Criminal Civil Enforcement Actions Case: Byrd v. Pirrong (No. 25-6161) | Court: United States Court of Appeals for...

Stigma Is Not Enough: Conclusory Retaliation Allegations Cannot Overcome the Presumption Against Pseudonymous Pleading

Date: Jun 17, 2026

Stigma Is Not Enough: Conclusory Retaliation Allegations Cannot Overcome the Presumption Against Pseudonymous Pleading Case: Roe v. Colorado Judical Department, No. 25-1264 (10th Cir. June 16, 2026)...

Coordinated Firearm Sales Create Jointly Undertaken Relevant Conduct for U.S.S.G. § 2K2.1 Enhancements

Date: Jun 17, 2026

Coordinated Firearm Sales Create Jointly Undertaken Relevant Conduct for U.S.S.G. § 2K2.1 Enhancements I. Introduction In United States v. Jackson (10th Cir. June 16, 2026), Darrius Deangelo Jackson...

Heck Bars § 1983/Bivens Damages Claims That Would Undermine an Uninvalidated Federal Conviction, and Frivolous Prisoner Appeals Deny IFP and Add a PLRA Strike

Date: Jun 17, 2026

Heck Bars § 1983/Bivens Damages Claims That Would Undermine an Uninvalidated Federal Conviction, and Frivolous Prisoner Appeals Deny IFP and Add a PLRA Strike Case: Hamett v. City of Broken Arrow...

RCRA § 6961(a) Does Not Adopt State Exclusive Judicial-Review Schemes: Federal Agencies Retain § 1345 Jurisdiction

Date: Jun 17, 2026

RCRA § 6961(a) Does Not Adopt State Exclusive Judicial-Review Schemes: Federal Agencies Retain § 1345 Jurisdiction Case: United States v. New Mexico Environment Department, No. 22-2132 (10th Cir....

Conclusory “Substantial Identity” Allegations Do Not Cure Failure to Name the Correct EEOC Respondent; Leave to Amend Requires a Specific Proposed Cure

Date: Jun 17, 2026

Conclusory “Substantial Identity” Allegations Do Not Cure Failure to Name the Correct EEOC Respondent; Leave to Amend Requires a Specific Proposed Cure I. Introduction In Borsody v. Frontier Heritage...

Mootness of Injunction Appeals When DHS Rescinds Reinstatement and a New Final Removal Order Supersedes the Dispute

Date: Jun 17, 2026

Mootness of Injunction Appeals When DHS Rescinds Reinstatement and a New Final Removal Order Supersedes the Dispute 1. Introduction Arguello v. Mullin (10th Cir. June 15, 2026) concerns a Venezuelan...

Tenth Circuit: Unpreserved Colorado River Challenges Are Waived Absent a Developed Plain-Error Argument; AI-Hallucinated Citations Risk Sanctions

Date: Jun 16, 2026

Tenth Circuit: Unpreserved Colorado River Challenges Are Waived Absent a Developed Plain-Error Argument; AI-Hallucinated Citations Risk Sanctions Case: Jackson v. Santander Consumer USA Inc., No....

Ballard (10th Cir. 2026): § 3553(a) Does Not Require Consideration of an Unrelated Existing Sentence When Imposing Consecutive Statutory-Maximum Terms for Prison Violence

Date: Jun 13, 2026

Ballard (10th Cir. 2026): § 3553(a) Does Not Require Consideration of an Unrelated Existing Sentence When Imposing Consecutive Statutory-Maximum Terms for Prison Violence 1. Introduction In United...

Revocation Sentencing After Esteras: A Retracted § 3553(a)(2)(A) Reference and Public-Safety-Based Reasoning Do Not Create Reversible Procedural Error

Date: Jun 13, 2026

Revocation Sentencing After Esteras: A Retracted § 3553(a)(2)(A) Reference and Public-Safety-Based Reasoning Do Not Create Reversible Procedural Error Case: United States v. Yazzie (10th Cir. June...

Tenth Circuit Jurisdictional Bar to Reviewing Discretionary Denials of Guideline Departures When the District Court Recognizes Its Authority

Date: Jun 13, 2026

Tenth Circuit Jurisdictional Bar to Reviewing Discretionary Denials of Guideline Departures When the District Court Recognizes Its Authority Case: United States v. Trejo-Mendoza (10th Cir. June 11,...

Particularized “Necessity” for Title III Wiretaps: Detailed Limits of Traditional Techniques and Surveillance-Evasion Facts Suffice

Date: Jun 12, 2026

Particularized “Necessity” for Title III Wiretaps: Detailed Limits of Traditional Techniques and Surveillance-Evasion Facts Suffice I. Introduction In United States v. Medina (10th Cir. June 11,...

Tenth Circuit: Major Upward Variance in Child Sex-Trafficking Conspiracy Affirmed; District Courts May Reconsider Guideline-Accounted Facts Under § 3553(a) Absent Evidence of Bias

Date: Jun 12, 2026

Tenth Circuit: Major Upward Variance in Child Sex-Trafficking Conspiracy Affirmed; District Courts May Reconsider Guideline-Accounted Facts Under § 3553(a) Absent Evidence of Bias Introduction In...

Jefferson v. Moore: Immunity Does Not Create a Collateral-Order Right to Appeal Non-Dispositive Procedural Denials

Date: Jun 11, 2026

Jefferson v. Moore: Immunity Does Not Create a Collateral-Order Right to Appeal Non-Dispositive Procedural Denials Court: U.S. Court of Appeals for the Tenth Circuit Date: June 8, 2026 Case:...

Standing and Ripeness Limits on Challenges to Unimplemented Statutory Exceptions: Redressability, Severability, and Generalized Stigmatic Harm

Date: Jun 11, 2026

Standing and Ripeness Limits on Challenges to Unimplemented Statutory Exceptions: Redressability, Severability, and Generalized Stigmatic Harm Case: New Mexico Trappers Association v. Torrez (10th...