10th Circuit Case Commentaries

Living at the Drug-Distribution Location “Easily Proves” Maintaining a Premises Under U.S.S.G. § 2D1.1(b)(12) Without Ownership, and Unobjected PSR Facts Control

Date: Jun 2, 2026

Living at the Drug-Distribution Location “Easily Proves” Maintaining a Premises Under U.S.S.G. § 2D1.1(b)(12) Without Ownership, and Unobjected PSR Facts Control I. Introduction In United States v....

Duress in Illegal-Reentry Cases: Telephone Threats and Speculative Surveillance Are Insufficient to Show an “Immediate Threat”

Date: Jun 2, 2026

Duress in Illegal-Reentry Cases: Telephone Threats and Speculative Surveillance Are Insufficient to Show an “Immediate Threat” 1. Introduction In United States v. Bustillos-Perea (10th Cir. May 29,...

Telephone Threats and Speculative Surveillance Are Insufficient “Immediacy” for a Duress Defense to Unlawful Reentry

Date: Jun 2, 2026

Telephone Threats and Speculative Surveillance Are Insufficient “Immediacy” for a Duress Defense to Unlawful Reentry 1. Introduction In United States v. Bustillos-Perea (10th Cir. May 29, 2026)...

Uncharged Tax-Year Loss Counts as Relevant Conduct When a Defendant Continues the Same Evasion Scheme, and “Sophisticated Means” Applies Even if the Scheme Was Purchased

Date: Jun 2, 2026

Uncharged Tax-Year Loss Counts as Relevant Conduct When a Defendant Continues the Same Evasion Scheme, and “Sophisticated Means” Applies Even if the Scheme Was Purchased Introduction In United States...

Plain-Error Barrier to Allen-Charge Challenges: Pattern Tenth Circuit Instruction Not “Plainly” Coercive Without Controlling Authority

Date: Jun 2, 2026

Plain-Error Barrier to Allen-Charge Challenges: Pattern Tenth Circuit Instruction Not “Plainly” Coercive Without Controlling Authority 1. Introduction In United States v. Miller (10th Cir. May 28,...

§ 2254 Habeas Is Unavailable to Contest Oklahoma Survivors’ Act (§ 1090.5) Resentencing-Request Denials as Post-Conviction Procedure Errors

Date: Jun 2, 2026

§ 2254 Habeas Is Unavailable to Contest Oklahoma Survivors’ Act (§ 1090.5) Resentencing-Request Denials as Post-Conviction Procedure Errors 1. Introduction In Parker v. Tensley (10th Cir. May 29,...

Harrell v. Scott — Plausible Eighth Amendment and First Amendment Claims from Withdrawal/Misadministration of a Medical Diet at § 1915A Screening

Date: Jun 1, 2026

Plausible Eighth Amendment and First Amendment Claims from Withdrawal/Misadministration of a Medical Diet at § 1915A Screening (Harrell v. Scott) I. Introduction In Harrell v. Scott (10th Cir. May...

Rule 28 Waiver in Pro Se TCPA Appeals and the Nexus Limit on Inherent-Power Sanctions After Remand (Trupia v. Bob Moore Enterprises)

Date: Jun 1, 2026

Rule 28 Waiver in Pro Se TCPA Appeals and the Nexus Limit on Inherent-Power Sanctions After Remand I. Introduction Case: Trupia v. Bob Moore Enterprises, No. 25-6130 (10th Cir. May 29, 2026) (Order...

Telephone Threats and Speculative Surveillance Are Insufficient “Immediate Threats” for a Duress Defense to Illegal Reentry

Date: Jun 1, 2026

Telephone Threats and Speculative Surveillance Are Insufficient “Immediate Threats” for a Duress Defense to Illegal Reentry I. Introduction In United States v. Bustillos-Perea (10th Cir. May 29,...

United States v. Harris (10th Cir. 2026): “Record Reveals a Basis” Forecloses Plain-Error Relief from a Mental-Health Treatment Condition

Date: May 27, 2026

United States v. Harris (10th Cir. 2026): “Record Reveals a Basis” Forecloses Plain-Error Relief from a Mental-Health Treatment Condition I. Introduction In United States v. Harris (10th Cir. May 26,...

ADA Part‑Time Accommodation Requires Ability to Perform Essential Functions; No “Adverse Action” by Host County Where Staffing Firm Offers Alternative Placement

Date: May 27, 2026

ADA Part‑Time Accommodation Requires Ability to Perform Essential Functions; No “Adverse Action” by Host County Where Staffing Firm Offers Alternative Placement I. Introduction In Hayes v. Shawnee...

“Copy Means the Entire Policy”: Colorado § 10-3-1117 Requires Full Policy Production for Potentially Relevant Policies and Imposes a Single $100/Day Penalty Per Claim

Date: May 26, 2026

“Copy Means the Entire Policy”: Colorado § 10-3-1117 Requires Full Policy Production for Potentially Relevant Policies and Imposes a Single $100/Day Penalty Per Claim I. Introduction Case: Fogel v....

Colorado § 10-3-1117 Requires Full-Policy Production for Any Potentially Relevant Coverage and Imposes a Single $100/Day Penalty Per Claim

Date: May 24, 2026

Colorado § 10-3-1117 Requires Full-Policy Production for Any Potentially Relevant Coverage and Imposes a Single $100/Day Penalty Per Claim Case: Fogel v. Shelter Mutual Insurance Company, Nos....

Claim-Specific Rooker-Feldman: General Constitutional Challenges Survive, but Requests to Enjoin Enforcement of a Specific Child Support Order Do Not

Date: May 23, 2026

Claim-Specific Rooker-Feldman: General Constitutional Challenges Survive, but Requests to Enjoin Enforcement of a Specific Child Support Order Do Not 1. Introduction Balderama v. Bulman (10th Cir....

Rule 11(c)(1)(C) Plea Sentences and Anders Appeals: Jurisdictional Limits and Language-Access Compliance in the Tenth Circuit

Date: May 23, 2026

Rule 11(c)(1)(C) Plea Sentences and Anders Appeals: Jurisdictional Limits and Language-Access Compliance in the Tenth Circuit I. Introduction United States v. Gamboa-Saenz (10th Cir. May 21, 2026) is...

Sherman Act Conspiracy Allegations Do Not Plead an “Occurrence” Under Colorado CGL Policies (No Duty to Defend)

Date: May 22, 2026

Sherman Act Conspiracy Allegations Do Not Plead an “Occurrence” Under Colorado CGL Policies (No Duty to Defend) Case: Chaussee v. Auto-Owners Insurance Company, No. 25-1120 (10th Cir. May 21, 2026)...

ERISA Remand Orders Without a Sum-Certain Benefits Award Are Not Final and Are Appealable Only After Post-Remand District Court Disposition

Date: May 22, 2026

ERISA Remand Orders Without a Sum-Certain Benefits Award Are Not Final and Are Appealable Only After Post-Remand District Court Disposition 1. Introduction In W. v. California Physicians Service...

Colorado Auto-Insurance Disclosure: “Copy” Means the Full Policy, Relevance Is Broad, and the § 10-3-1117 Penalty Accrues Once Per Claim

Date: May 22, 2026

Colorado Auto-Insurance Disclosure: “Copy” Means the Full Policy, Relevance Is Broad, and the § 10-3-1117 Penalty Accrues Once Per Claim Case: Fogel v. Shelter Mutual Insurance Company (10th Cir. May...

United States v. Trevino — Commentary

Date: May 22, 2026

Police Return of Firearms Does Not Justify Acquittal: Courts May Strike Closing Arguments That Drift from Mens Rea to an Impermissible “Trust the Police” Theory 1. Introduction United States v....

Warrant Checks Remain “Ordinary Inquiries” During a Traffic Stop; ACCA Enhancement Vacated Where Conceded Predicates Leave Only Two Violent Felonies

Date: May 22, 2026

Warrant Checks Remain “Ordinary Inquiries” During a Traffic Stop; ACCA Enhancement Vacated Where Conceded Predicates Leave Only Two Violent Felonies I. Introduction In United States v. Wiggins (10th...