10th Circuit Case Commentaries

Tenth Circuit Limits Interlocutory Qualified-Immunity Appeals to the District Court’s “Fact Universe” and Treats Viewpoint Discrimination in Limited Public Forums as Clearly Established

Date: May 22, 2026

Tenth Circuit Limits Interlocutory Qualified-Immunity Appeals to the District Court’s “Fact Universe” and Treats Viewpoint Discrimination in Limited Public Forums as Clearly Established Introduction...

Stone v. Powell Forecloses § 2255 Fourth Amendment Relitigation Absent a Debatable Brady/IAC Showing; “Blanket Suppression” Demands Foster-Level Flagrant Disregard

Date: May 22, 2026

Stone v. Powell Forecloses § 2255 Fourth Amendment Relitigation Absent a Debatable Brady/IAC Showing; “Blanket Suppression” Demands Foster-Level Flagrant Disregard I. Introduction In United States v....

Turcios-Ortiz v. Blanche: Serious Nonpolitical Crime Bar Is Fact-Reviewed for Substantial Evidence and Admits No Duress Exception

Date: May 22, 2026

Serious Nonpolitical Crime Bar: Substantial-Evidence Review, Probable-Cause “Serious Reasons to Believe,” and No Duress Exception (Tenth Circuit) 1. Introduction Case: Turcios-Ortiz v. Blanche, No....

Arguable Probable Cause to Arrest for Kansas “Interference” Defeats Clearly-Established Prong in Citizen-Journalist Retaliatory Arrest Claims at the Pleading Stage

Date: May 22, 2026

Arguable Probable Cause to Arrest for Kansas “Interference” Defeats Clearly-Established Prong in Citizen-Journalist Retaliatory Arrest Claims at the Pleading Stage Case: Eravi v. City Commission of...

Drug-Trafficking Nexus to a Residence: Reliable Informant Tips Plus Agent Experience Can Supply Probable Cause; Immaterial Misstatements Defeat a Franks Claim

Date: May 22, 2026

Drug-Trafficking Nexus to a Residence: Reliable Informant Tips Plus Agent Experience Can Supply Probable Cause; Immaterial Misstatements Defeat a Franks Claim Case: United States v. Cangro, No....

Rule 16(a)(1)(G) Rebuttal-Expert Disclosure Is Triggered Only by the Defense’s Timely Disclosed Expert Opinions (Not Undisclosed New Trial Opinions)

Date: May 22, 2026

Rule 16(a)(1)(G) Rebuttal-Expert Disclosure Is Triggered Only by the Defense’s Timely Disclosed Expert Opinions (Not Undisclosed New Trial Opinions) Case: United States v. Crow (No. 24-1377) | Court:...

18 U.S.C. § 2423(a) Requires “Intent,” Not a “Dominant Purpose”; § 1152 Non‑Indian Status May Be Proven by Unchallenged Family Testimony

Date: May 20, 2026

18 U.S.C. § 2423(a) Requires “Intent,” Not a “Dominant Purpose”; § 1152 Non‑Indian Status May Be Proven by Unchallenged Family Testimony Introduction Case: United States v. Thompson (Tenth Circuit,...

Kansas Premises-Liability Duty to Protect Guests from Third-Party Gunfire Requires Prior Similar Shootings; Crime-Density Maps and “More Security” Alone Do Not Create Foreseeability

Date: May 20, 2026

Kansas Premises-Liability Duty to Protect Guests from Third-Party Gunfire Requires Prior Similar Shootings; Crime-Density Maps and “More Security” Alone Do Not Create Foreseeability Case: Blalock v....

Nonparty Appellate Standing Requires Injury and Own-Right Assertion in Receivership-Related Orders

Date: May 19, 2026

Nonparty Appellate Standing Requires Injury and Own-Right Assertion in Receivership-Related Orders Introduction Universitas Education, LLC continues efforts to collect proceeds from life-insurance...

Tafolla v. Rogers: COA Denied Where Petitioner Waives Procedural-Default Challenges and Fails to Show Unreasonable Chapman Harmlessness Under AEDPA

Date: May 19, 2026

Tafolla v. Rogers: COA Denied Where Petitioner Waives Procedural-Default Challenges and Fails to Show Unreasonable Chapman Harmlessness Under AEDPA Introduction In Tafolla v. Rogers (10th Cir. May...

Contextual Credibility Standard for “Assertion of Innocence” in Rule 11(d)(2)(B) Guilty-Plea Withdrawal Motions

Date: May 19, 2026

Contextual Credibility Standard for “Assertion of Innocence” in Rule 11(d)(2)(B) Guilty-Plea Withdrawal Motions 1. Introduction In United States v. Ortega-Moreno (10th Cir. May 18, 2026) (unpublished...

United States v. Back: Speculative Prejudice Cannot Defeat a Timely Indictment; Intermediary Assurances Can “Further” a Drug Conspiracy

Date: May 19, 2026

United States v. Back: Speculative Prejudice Cannot Defeat a Timely Indictment; Intermediary Assurances Can “Further” a Drug Conspiracy Court: U.S. Court of Appeals for the Tenth Circuit (May 18,...

United States v. Colbert: McGirt Does Not Undermine Federal § 3231/MCA Jurisdiction; Failure to Object to an R&R Waives Suppression Appellate Review

Date: May 13, 2026

United States v. Colbert: McGirt Does Not Undermine Federal § 3231/MCA Jurisdiction; Failure to Object to an R&R Waives Suppression Appellate Review Introduction In United States v. Colbert (10th...

Ashby v. Wolfsburger: A Pay.gov Receipt Does Not Prove Timely Filing—Only a Notice of Electronic Filing (NEF) Perfects an ECF Notice of Appeal

Date: May 12, 2026

Ashby v. Wolfsburger: A Pay.gov Receipt Does Not Prove Timely Filing—Only a Notice of Electronic Filing (NEF) Perfects an ECF Notice of Appeal 1. Introduction In Ashby v. Wolfsburger (10th Cir. May...

§ 4241(d) “Subject To” § 4246: Courts May Rehospitalize for a Precertification Dangerousness Evaluation, but May Not Order a § 4246(b) Report Before Certification

Date: May 12, 2026

§ 4241(d) “Subject To” § 4246: Courts May Rehospitalize for a Precertification Dangerousness Evaluation, but May Not Order a § 4246(b) Report Before Certification I. Introduction United States v....

Young v. Colorado Department of Corrections: DEI/Race-Sensitivity Training and Speculative “Aftermath” Allegations, Without Concrete Workplace Harm, Do Not Plausibly Plead a Hostile Work Environment

Date: May 12, 2026

Young v. Colorado Department of Corrections: DEI/Race-Sensitivity Training and Speculative “Aftermath” Allegations, Without Concrete Workplace Harm, Do Not Plausibly Plead a Hostile Work Environment...

Tenth Circuit: § 3553(a) Balancing Can Independently Defeat Compassionate Release, and § 2255—Not § 3582—Is the Vehicle for Attacking a Sentence

Date: May 12, 2026

Tenth Circuit: § 3553(a) Balancing Can Independently Defeat Compassionate Release, and § 2255—Not § 3582—Is the Vehicle for Attacking a Sentence Introduction United States v. Webb (10th Cir. May 11,...

Plain-View From a Public Walkway Through a Curtain Gap: The Tenth Circuit Lets the Panel Rule Stand

Date: May 12, 2026

Plain-View From a Public Walkway Through a Curtain Gap: The Tenth Circuit Lets the Panel Rule Stand Introduction United States v. Watkins (No. 23-6210) concerns the Fourth Amendment consequences of a...

Rule 11(c)(1)(C) Bargained Sentences and Anders Appeals: Limited § 3742 Review and Enforceable Appeal Waivers

Date: May 11, 2026

Rule 11(c)(1)(C) Bargained Sentences and Anders Appeals: Limited § 3742 Review and Enforceable Appeal Waivers Case: United States v. Bailey (No. 25-2094) Court: United States Court of Appeals for the...

Sanders v. TC Transcontinental Tulsa: Enforcing Local Rule 56-1 and Requiring Evidence of Pretext to Defeat Summary Judgment Under McDonnell Douglas

Date: May 11, 2026

Sanders v. TC Transcontinental Tulsa: Enforcing Local Rule 56-1 and Requiring Evidence of Pretext to Defeat Summary Judgment Under McDonnell Douglas Introduction In Sanders v. TC Transcontinental...