10th Circuit Case Commentaries

Ambiguous Post-Termination “Trade Name” Clauses Defeat Rule-12 Contract Dispositive Dismissal of Trademark Claims (10th Cir.)

Date: May 11, 2026

Ambiguous Post-Termination “Trade Name” Clauses Defeat Rule-12 Contract Dispositive Dismissal of Trademark Claims (10th Cir.) Introduction In Ascent Classical Academies v. Ascent Classical Academy...

Calling the Police Does Not Make a Private Retailer a State Actor: VanHorn v. Salvation Army

Date: May 11, 2026

Calling the Police Does Not Make a Private Retailer a State Actor: VanHorn v. Salvation Army (10th Cir. May 7, 2026) 1. Introduction In VanHorn v. Salvation Army, Christopher A. VanHorn (pro se) sued...

Eyewitness Identification Plus Near-Immediate Corroboration Suffices for § 922(g)(1) Actual Possession—Forensic Gaps and Credibility Attacks Do Not Defeat Sufficiency Review

Date: May 11, 2026

Eyewitness Identification Plus Near-Immediate Corroboration Suffices for § 922(g)(1) Actual Possession—Forensic Gaps and Credibility Attacks Do Not Defeat Sufficiency Review Introduction In United...

Reopening a Closed Bankruptcy Case Is a Ministerial Act and a Final Order: Untimely Appeals, Forfeiture, and Record Deficiencies Bar Collateral Attacks

Date: May 10, 2026

Reopening a Closed Bankruptcy Case Is a Ministerial Act and a Final Order: Untimely Appeals, Forfeiture, and Record Deficiencies Bar Collateral Attacks 1. Introduction Case: In re Leroy Carrillo, Jr....

Unprocessed Poppy Seeds as CSA “Material”: Knowingly Supplying Seeds for Poppy-Seed-Tea Extraction Triggers § 843(a)(6)–(7) Liability

Date: May 8, 2026

Unprocessed Poppy Seeds as CSA “Material”: Knowingly Supplying Seeds for Poppy-Seed-Tea Extraction Triggers § 843(a)(6)–(7) Liability Case: United States v. McCarthy (10th Cir. May 6, 2026) Court:...

No Sua Sponte Rule 32.1 Confrontation Balancing Required Absent an Objection in Supervised-Release Revocations (United States v. Price)

Date: May 7, 2026

No Sua Sponte Rule 32.1 Confrontation Balancing Required Absent an Objection in Supervised-Release Revocations (United States v. Price) Introduction In United States v. Price (10th Cir. May 5, 2026),...

Revocation Hearings in the Tenth Circuit: No Sua Sponte Rule 32.1 Confrontation Balancing Absent an Objection

Date: May 7, 2026

Revocation Hearings in the Tenth Circuit: No Sua Sponte Rule 32.1 Confrontation Balancing Absent an Objection 1. Introduction In United States v. Price (10th Cir. May 5, 2026), Anthony Steven Price...

Major Upward Variances in Illegal-Reentry Sentencing May Rest on Recency of Serious Prior Crime and Rapid Return, Notwithstanding JSIN Averages

Date: May 7, 2026

Major Upward Variances in Illegal-Reentry Sentencing May Rest on Recency of Serious Prior Crime and Rapid Return, Notwithstanding JSIN Averages I. Introduction In United States v. Diaz-Hernandez...

United States v. Dias: Prior Felon-in-Possession Convictions Are Generally Irrelevant Rule 404(b) “Knowledge” Evidence in Actual-Possession § 922(g)(1) Trials (Absent Unusual Facts)

Date: May 7, 2026

United States v. Dias: Prior Felon-in-Possession Convictions Are Generally Irrelevant Rule 404(b) “Knowledge” Evidence in Actual-Possession § 922(g)(1) Trials (Absent Unusual Facts) Court: United...

United States v. Price: No Sua Sponte Rule 32.1 Confrontation Balancing—Unobjected-to Hearsay Supports Supervised-Release Revocation Under Plain-Error Review

Date: May 7, 2026

United States v. Price: No Sua Sponte Rule 32.1 Confrontation Balancing—Unobjected-to Hearsay Supports Supervised-Release Revocation Under Plain-Error Review 1. Introduction In United States v. Price...

United States v. Price — No Sua Sponte Rule 32.1 Balancing Required Absent a Confrontation/Hearsay Objection at Supervised-Release Revocation

Date: May 6, 2026

United States v. Price — No Sua Sponte Rule 32.1 Balancing Required Absent a Confrontation/Hearsay Objection at Supervised-Release Revocation 1. Introduction In United States v. Price (10th Cir. May...

Rider v. OXY USA: Ascertainability in the Tenth Circuit Requires Clear, Objective Class Definitions—not “Administrative Feasibility” or Classwide Standing Proof

Date: May 6, 2026

Rider v. OXY USA: Ascertainability in the Tenth Circuit Requires Clear, Objective Class Definitions—not “Administrative Feasibility” or Classwide Standing Proof 1. Introduction In Rider v. OXY USA,...

Rule 404(b) Allows Prior Surreptitious “Peeping” Videos to Prove Identity by Voice Comparison and to Rebut “Accidental Recording” Claims

Date: May 6, 2026

Rule 404(b) Allows Prior Surreptitious “Peeping” Videos to Prove Identity by Voice Comparison and to Rebut “Accidental Recording” Claims Case: United States v. Bycroft (No. 24-7069) — Court: U.S....

McGirt-Based Jurisdictional Defects Cannot Be Collaterally Litigated at Federal Sentencing Absent a Complete Denial of Counsel

Date: May 6, 2026

McGirt-Based Jurisdictional Defects Cannot Be Collaterally Litigated at Federal Sentencing Absent a Complete Denial of Counsel I. Introduction In United States v. Campbell (10th Cir. May 5, 2026),...

Avant v. Doke: Appellate Waiver and Forfeiture Strictly Enforced—Inadequate Opening Briefing and Failure to Oppose a Dispositive Defense Require Affirmance

Date: May 6, 2026

Avant v. Doke: Appellate Waiver and Forfeiture Strictly Enforced—Inadequate Opening Briefing and Failure to Oppose a Dispositive Defense Require Affirmance 1. Introduction In Avant v. Doke (10th Cir....

Routine Evidence-Retention Deletions Trigger Youngblood (Not Trombetta) Absent Apparent Exculpatory Value—and Require Proof of Bad Faith

Date: May 5, 2026

Routine Evidence-Retention Deletions Trigger Youngblood (Not Trombetta) Absent Apparent Exculpatory Value—and Require Proof of Bad Faith Introduction In United States v. Orrantia (10th Cir. May 4,...

Smith v. Albany County School District No. 1: Pleading a “Compelled Message” and Limits on Mask-Mandate First Amendment/Due Process Claims

Date: May 5, 2026

Smith v. Albany County School District No. 1: Pleading a “Compelled Message” and Limits on Mask-Mandate First Amendment/Due Process Claims I. Introduction In Smith v. Albany County School District...

Wakat v. Winn: Appellate Review of Remand Orders When § 1442 Is Asserted, and the Finality Trap for Fee-Award Appeals

Date: May 5, 2026

Wakat v. Winn: Appellate Review of Remand Orders When § 1442 Is Asserted, and the Finality Trap for Fee-Award Appeals 1. Introduction Parties and posture. In consolidated appeals, August Wakat (pro...

Martinez Reports May Not Defeat Well-Pleaded Prisoner Claims at § 1915A Screening

Date: May 4, 2026

Martinez Reports May Not Defeat Well-Pleaded Prisoner Claims at § 1915A Screening Introduction In Martin v. Schnurr, the Tenth Circuit reversed the dismissal of a Kansas prisoner’s civil-rights...

Warhol Does Not Require Targeting: Brief Documentary Use of Public Factual Footage Can Be Transformative Fair Use

Date: May 4, 2026

Warhol Does Not Require Targeting: Brief Documentary Use of Public Factual Footage Can Be Transformative Fair Use Introduction In Whyte Monkee Productions v. Netflix, the Tenth Circuit affirmed...