10th Circuit Case Commentaries

Tenth Circuit: Generally Applicable Non-Enforcement Policies Do Not Create “Immediate” State-Created Danger; Colorado CPLA Predominant-Cause & Exclusivity Bar Mass-Shooting Premises Claims

Date: Sep 12, 2026

Tenth Circuit: Generally Applicable Non-Enforcement Policies Do Not Create “Immediate” State-Created Danger; Colorado CPLA Predominant-Cause & Exclusivity Bar Mass-Shooting Premises Claims I....

Vance v. G.I.G.: ERPO Non-Enforcement Policies Do Not Satisfy State-Created-Danger “Affirmative Conduct”; Colorado CPLA Exclusivity Bars Negligence and Treats Mass Shooter as Predominant Cause at the Pleading Stage

Date: Sep 12, 2026

Vance v. G.I.G.: ERPO Non-Enforcement Policies Do Not Satisfy State-Created-Danger “Affirmative Conduct”; Colorado CPLA Exclusivity Bars Negligence and Treats Mass Shooter as Predominant Cause at the...

Reinstatement of a Revoked Professional License as Prospective Relief Under Ex parte Young; Younger Abstention Ends When State Review Concludes

Date: Sep 12, 2026

Reinstatement of a Revoked Professional License as Prospective Relief Under Ex parte Young; Younger Abstention Ends When State Review Concludes 1. Introduction In Gardner v. State of New Mexico (10th...

Rule 16(a)(1)(G) Rebuttal Disclosures Are Limited to Countering Timely-Disclosed Defense Expert Opinions

Date: Sep 12, 2026

Rule 16(a)(1)(G) Rebuttal Disclosures Are Limited to Countering Timely-Disclosed Defense Expert Opinions Case: United States v. Crow (No. 24-1377) Court: U.S. Court of Appeals for the Tenth Circuit...

Guidelines Calculation Plus Individualized Explanation Satisfies § 3553(a)(6) in Upward-Variance Sentencing (JSIN Data Not Required): United States v. Miranda-Espinoza

Date: Sep 12, 2026

Guidelines Calculation Plus Individualized Explanation Satisfies § 3553(a)(6) in Upward-Variance Sentencing (JSIN Data Not Required): United States v. Miranda-Espinoza 1. Introduction In United...

Vance v. Aldrich (10th Cir. 2026): Generally Applicable “Red-Flag” Non-Enforcement Policies Are Not Affirmative State-Created Danger; Colorado CPLA Exclusively Governs On-Premises Mass-Shooting Injury Claims

Date: Sep 12, 2026

Vance v. Aldrich (10th Cir. 2026): Generally Applicable “Red-Flag” Non-Enforcement Policies Are Not Affirmative State-Created Danger; Colorado CPLA Exclusively Governs On-Premises Mass-Shooting...

CGIA Emergency-Vehicle Immunity Turns on a Disjunctive “Lights-or-Siren” Showing, and the District Court Must Find Whether the Siren Was Used

Date: Sep 12, 2026

CGIA Emergency-Vehicle Immunity Turns on a Disjunctive “Lights-or-Siren” Showing, and the District Court Must Find Whether the Siren Was Used 1. Introduction Murphy v. Marlow (10th Cir. Sept. 8,...

Open-Air Canine Sniffs of Vehicles Are Not Fourth Amendment “Searches” Despite Potentially Lawful Odors; Pre-Contact Alert Supplies Probable Cause for Any Trespassory Sniff

Date: Sep 12, 2026

Open-Air Canine Sniffs of Vehicles Are Not Fourth Amendment “Searches” Despite Potentially Lawful Odors; Pre-Contact Alert Supplies Probable Cause for Any Trespassory Sniff I. Introduction In United...

Independent Investigation Breaks Cat’s-Paw Causation in ADEA Pretext Challenges

Date: Sep 12, 2026

Independent Investigation Breaks Cat’s-Paw Causation in ADEA Pretext Challenges Case: Tafoya v. City of Fountain (10th Cir. Sept. 8, 2026) (unpublished “Order and Judgment,” persuasive only) Court:...

Tenth Circuit Requires § 2255 Evidentiary Hearings When Plea Counsel May Have Omitted a Plausible Loughrin/Williams Bank-Fraud Defense and Misadvised on Cheek Willfulness

Date: Sep 12, 2026

Tenth Circuit Requires § 2255 Evidentiary Hearings When Plea Counsel May Have Omitted a Plausible Loughrin/Williams Bank-Fraud Defense and Misadvised on Cheek Willfulness 1. Introduction Case: United...

Spiehs v. Morgan: Public Libraries May Bar Sign-Displays Indoors as Content-Neutral Time, Place, and Manner Restrictions

Date: Sep 12, 2026

Spiehs v. Morgan: Public Libraries May Bar Sign-Displays Indoors as Content-Neutral Time, Place, and Manner Restrictions Court: United States Court of Appeals for the Tenth Circuit Date: September 8,...

Rule 4(b)(4) Extensions in § 3582 Compassionate-Release Appeals: Excusable-Neglect Showing Must Be Made in the Extension Motion, Not in a Late Reply

Date: Sep 11, 2026

Rule 4(b)(4) Extensions in § 3582 Compassionate-Release Appeals: Excusable-Neglect Showing Must Be Made in the Extension Motion, Not in a Late Reply 1. Introduction United States v. Norcutt (10th...

Williams v. Crane: Younger Abstention Bars Federal Equitable Relief that Would Disrupt Ongoing State Child-Custody Enforcement; GAL and Court-Appointed Custody Professionals Receive Quasi-Judicial Immunity

Date: Sep 11, 2026

Williams v. Crane: Younger Abstention Bars Federal Equitable Relief that Would Disrupt Ongoing State Child-Custody Enforcement; GAL and Court-Appointed Custody Professionals Receive Quasi-Judicial...

Appellate Waiver for Pro Se Deficient Briefing: Failure to Cite the Record or Attack Dispositive Grounds Requires Affirmance

Date: Sep 11, 2026

Appellate Waiver for Pro Se Deficient Briefing: Failure to Cite the Record or Attack Dispositive Grounds Requires Affirmance Introduction Cook v. Albany County Board of County Commissioners (10th...

Tenth Circuit: Hardship Review Is Deferential, and Cancellation Appeals Cannot Recast Fact Disputes as Legal Error

Date: Sep 5, 2026

Tenth Circuit: Hardship Review Is Deferential, and Cancellation Appeals Cannot Recast Fact Disputes as Legal Error 1. Introduction In Hernandez Hernandez v. Blanche (10th Cir. Sept. 4, 2026)...

Crowe v. Gee (10th Cir. 2026): Default Is Unavailable When Rule 12(a)(3)’s 60-Day Clock Has Not Run From Service on the U.S. Attorney

Date: Sep 3, 2026

Default Is Unavailable When Rule 12(a)(3)’s 60-Day Clock Has Not Run From Service on the U.S. Attorney (and Timely Extensions Defeat Default) 1. Introduction In Crowe v. Gee, No. 25-2118 (10th Cir....

No Collateral-Order Appellate Jurisdiction Over § 4241(b) Competency-Evaluation Orders for Already-Detained Defendants

Date: Sep 3, 2026

No Collateral-Order Appellate Jurisdiction Over § 4241(b) Competency-Evaluation Orders for Already-Detained Defendants Introduction In United States v. Bayne (10th Cir. Sept. 1, 2026), the Tenth...

Major Upward Variances Affirmed When District Courts Tie Gratuity of Violence, Gang Function, and Leadership Role to § 3553(a) Factors

Date: Sep 3, 2026

Major Upward Variances Affirmed When District Courts Tie Gratuity of Violence, Gang Function, and Leadership Role to § 3553(a) Factors Introduction In United States v. George (10th Cir. Sept. 1,...

Title IX “Control” Is a Functional, Fact-Based Inquiry: Indirect Authority Over a Third-Party Harasser Can Satisfy Davis

Date: Sep 3, 2026

Title IX “Control” Is a Functional, Fact-Based Inquiry: Indirect Authority Over a Third-Party Harasser Can Satisfy Davis Case: Jane Doe 1 v. Eastern New Mexico University Board of Regents (10th Cir....

FAA § 1 “Transportation Worker” Exemption Requires a Properly Defined Class Based on Typical Work of the Class as a Whole (Not the Named Plaintiffs)

Date: Sep 3, 2026

FAA § 1 “Transportation Worker” Exemption Requires a Properly Defined Class Based on Typical Work of the Class as a Whole (Not the Named Plaintiffs) I. Introduction In Joyner v. Frontier Airlines...