10th Circuit Case Commentaries

Tenth Circuit: Sua Sponte Enforcement of FRAP 4(b) and Mootness/Finality Limits on Appeals from Rule 33–to–§ 2255 Recharacterization Notices

Date: Apr 8, 2026

Tenth Circuit: Sua Sponte Enforcement of FRAP 4(b) and Mootness/Finality Limits on Appeals from Rule 33–to–§ 2255 Recharacterization Notices Case: United States v. Jacobo (Nos. 25-5115 & 25-5121) |...

Second-Degree Murder and U.S.S.G. § 5K2.6: Weapon-Use Departures Require Atypical, Heartland-Exceeding Findings; Erroneous Departures May Taint a Variance

Date: Apr 8, 2026

Second-Degree Murder and U.S.S.G. § 5K2.6: Weapon-Use Departures Require Atypical, Heartland-Exceeding Findings; Erroneous Departures May Taint a Variance I. Introduction In United States v. Tillman...

Cloud-Account Warrants Must Be Particularized, But Officers May Receive Leon Good-Faith Protection; Rule 12 Severance “Reasonably Available” Determinations Reviewed for Abuse of Discretion — United States v. Tew

Date: Apr 8, 2026

Cloud-Account Warrants Must Be Particularized, But Officers May Receive Leon Good-Faith Protection; Rule 12 Severance “Reasonably Available” Determinations Reviewed for Abuse of Discretion — United...

Belle Terre Controls: Unrelated-Occupancy Zoning Limits Do Not Trigger Intimate-Association Strict Scrutiny

Date: Apr 8, 2026

Belle Terre Controls: Unrelated-Occupancy Zoning Limits Do Not Trigger Intimate-Association Strict Scrutiny 1. Introduction Homeroom, Inc. v. City of Shawnee, Kansas (10th Cir. Apr. 6, 2026) concerns...

Morphew v. Chaffee County, Colorado — Probable Cause as a Dispositive Pleading Barrier; Due Process Fabrication Requires Plausible Causation

Date: Apr 8, 2026

Probable Cause as a Dispositive Pleading Barrier in § 1983 Wrongful-Prosecution Suits; Fourteenth Amendment Fabrication Claims Require Nonconclusory Causation Allegations 1. Introduction Morphew v....

Saini v. Hospital Care Consultants: Independent Reporting Duties Break Retaliation Causation and DOL Wage Proceedings Do Not Toll Discrimination Deadlines

Date: Apr 8, 2026

Independent Reporting Duties Break Retaliation Causation and DOL Wage Proceedings Do Not Toll Discrimination Deadlines Introduction In Saini v. Hospital Care Consultants (10th Cir. Apr. 6, 2026),...

United States v. Tew — Particularity Limits for Cloud-Account Warrants; Good-Faith Reliance and Rule 12 Timeliness for Severance

Date: Apr 8, 2026

United States v. Tew: Cloud-Account Warrants Must Be Meaningfully Particularized, Yet Officers May Receive Leon Good-Faith Protection; Severance Motions Are Due When the Basis Is “Reasonably...

SafeSport Arbitration Review: Investigative Reports and Hearsay May Support Discipline Without Violating Fundamental Fairness

Date: Apr 5, 2026

SafeSport Arbitration Review: Investigative Reports and Hearsay May Support Discipline Without Violating Fundamental Fairness 1. Introduction French v. U.S. Center for SafeSport (10th Cir. Apr. 3,...

“In Furtherance Of” Under § 924(c) Is a Stricter Subset of “In Relation To,” and Creates No Possession Safe Harbor

Date: Apr 5, 2026

“In Furtherance Of” Under § 924(c) Is a Stricter Subset of “In Relation To,” and Creates No Possession Safe Harbor Introduction In United States v. Jimenez-Marquez (10th Cir. Apr. 3, 2026), the Tenth...

Sharp v. Cox (10th Cir. Apr. 3, 2026): Forfeited § 523(a)(2)(A) “Financial Condition” Theories Receive Only Plain-Error Review, Even if “Purely Legal”

Date: Apr 5, 2026

Forfeited § 523(a)(2)(A) “Financial Condition” Theories Receive Only Plain-Error Review (and Appellant Must Negate Alternative Nondischargeability Grounds) 1) Introduction Case: Sharp v. Cox...

United States v. Jackson: Odor of Burnt Marijuana Plus Inconsistent Travel Stories, Extreme Nervousness, and Drug-Trafficking History Can Supply Probable Cause to Search a “Trunk-Equivalent” Area of an SUV

Date: Apr 5, 2026

United States v. Jackson: Odor of Burnt Marijuana Plus Inconsistent Travel Stories, Extreme Nervousness, and Drug-Trafficking History Can Supply Probable Cause to Search a “Trunk-Equivalent” Area of...

Ruan-Based § 841 Mens Rea Instruction Error Does Not Vacate § 1347 Healthcare-Fraud Convictions Without Strickland Prejudice

Date: Apr 4, 2026

Ruan-Based § 841 Mens Rea Instruction Error Does Not Vacate § 1347 Healthcare-Fraud Convictions Without Strickland Prejudice I. Introduction United States v. Otuonye (10th Cir. Apr. 2, 2026) is a...

Barker v. Weatherford Police Department: Post-Taser Force Against an Active Resister and the “Effectively Subdued” Limit on Clearly Established Law

Date: Apr 4, 2026

Barker v. Weatherford Police Department: Post-Taser Force Against an Active Resister and the “Effectively Subdued” Limit on Clearly Established Law 1. Introduction In Barker v. Weatherford Police...

Parker v. Hudson: Heck Bars § 1983 Claims That Would Undermine a Guilty Plea Even When Plaintiff Styled Suit as “Pretrial Detainee”; New Theories Raised on Appeal Are Waived

Date: Apr 4, 2026

Parker v. Hudson: Heck Bars § 1983 Claims That Would Undermine a Guilty Plea Even When Plaintiff Styled Suit as “Pretrial Detainee”; New Theories Raised on Appeal Are Waived 1. Introduction In Parker...

§ 3553(a)(6) Targets National (Not Intra-District) Disparities; Circuit Splits Defeat “Plain” Guideline Error

Date: Apr 4, 2026

§ 3553(a)(6) Targets National (Not Intra-District) Disparities; Circuit Splits Defeat “Plain” Guideline Error Case: United States v. Cole (10th Cir. Apr. 1, 2026) (Order and Judgment,...

Failure to Report at Release Is a Standalone Supervised-Release Violation; Transfer Efforts Don’t Cure It and Duress Must Be Properly Briefed

Date: Apr 4, 2026

Failure to Report at Release Is a Standalone Supervised-Release Violation; Transfer Efforts Don’t Cure It and Duress Must Be Properly Briefed Case: United States v. Thornton (10th Cir. Apr. 1, 2026)...

Rule 11 Pleas: A “Record-as-a-Whole” Factual Basis and Non-Prejudicial Element-Omission When Indictment/Counsel Supply the Missing Content

Date: Apr 4, 2026

Rule 11 Pleas: A “Record-as-a-Whole” Factual Basis and Non-Prejudicial Element-Omission When Indictment/Counsel Supply the Missing Content Introduction United States v. Huerta-Torres (10th Cir. Mar....

United States v. Xie: Organizational Charts Not Governed by Rule 1006 Absent “Voluminous Records,” and “Organizer” Enhancement Applies to Financial/Logistical Architects Without Hierarchical Control

Date: Apr 4, 2026

United States v. Xie: Organizational Charts Not Governed by Rule 1006 Absent “Voluminous Records,” and “Organizer” Enhancement Applies to Financial/Logistical Architects Without Hierarchical Control...

Defensive Appellate Rights Are Property of the Bankruptcy Estate Under Colorado Law, Allowing a Chapter 7 Trustee to Waive Them in a Rule 9019 Settlement (Roberts v. Sender)

Date: Apr 4, 2026

Defensive Appellate Rights Are Property of the Bankruptcy Estate Under Colorado Law, Allowing a Chapter 7 Trustee to Waive Them in a Rule 9019 Settlement (Roberts v. Sender) Introduction In Roberts...

Staffing-Agency Limits Under ADA § 12112(b)(2): No Liability for Client’s Internal-Hire Disability Inquiry Absent Participation or Corrective Control; § 12112(d) Damages Require Tangible Injury

Date: Apr 4, 2026

Staffing-Agency Limits Under ADA § 12112(b)(2): No Liability for Client’s Internal-Hire Disability Inquiry Absent Participation or Corrective Control; § 12112(d) Damages Require Tangible Injury I....