10th Circuit Case Commentaries

Deadly Force Clearly Established at the “Unarmed and Nonthreatening” Level; No Scavenger-Hunt Specificity in Qualified Immunity

Date: Apr 3, 2026

Deadly Force Clearly Established at the “Unarmed and Nonthreatening” Level; No Scavenger-Hunt Specificity in Qualified Immunity I. Introduction Manning v. City of Tulsa (10th Cir. Mar. 30, 2026)...

Larson v. Stucker: COA Denied Under AEDPA Where Claims Rely on Speculative Alternate-Suspect Proof, Proper Fifth Amendment Invocation, and “Novel” Alleyne-Based Plea-Sentencing Theory

Date: Apr 3, 2026

Larson v. Stucker: COA Denied Under AEDPA Where Claims Rely on Speculative Alternate-Suspect Proof, Proper Fifth Amendment Invocation, and “Novel” Alleyne-Based Plea-Sentencing Theory I. Introduction...

Appeal Waivers Bar Contempt Appeals (and Related Rule 35(a) Challenges) When “Jurisdictional” Claims Target the Underlying Civil Case, Not the Contempt Judgment

Date: Apr 2, 2026

Appeal Waivers Bar Contempt Appeals (and Related Rule 35(a) Challenges) When “Jurisdictional” Claims Target the Underlying Civil Case, Not the Contempt Judgment 1. Introduction In re: Contempt...

Jurisdictional Attacks on the Underlying Civil Case Do Not Defeat an Appellate Waiver in a Separate Criminal-Contempt Judgment

Date: Apr 2, 2026

Jurisdictional Attacks on the Underlying Civil Case Do Not Defeat an Appellate Waiver in a Separate Criminal-Contempt Judgment 1. Introduction In re: Contempt Proceedings Against Carpenter (10th Cir....

Independent Operation of Auto Policy Exclusions Under Colorado Law: Exceptions to One Exclusion Do Not Create Ambiguity with Another, and No Bad-Faith Liability Without Coverage

Date: Mar 31, 2026

Independent Operation of Auto Policy Exclusions Under Colorado Law: Exceptions to One Exclusion Do Not Create Ambiguity with Another, and No Bad-Faith Liability Without Coverage 1. Introduction In...

Untimely Appeals and Waiver Bar Collateral Attacks on Chapter 13 Agreed Judgments; Withdrawal of Continuance Waives Due-Process Complaints

Date: Mar 31, 2026

Untimely Appeals and Waiver Bar Collateral Attacks on Chapter 13 Agreed Judgments; Withdrawal of Continuance Waives Due-Process Complaints Case: Ricky Graham v. John Hardeman (In re Ricky Dale...

Exceptions to One Auto-Policy Exclusion Do Not Create Ambiguity or Coverage Against a Separate, Independently Dispositive Exclusion (and No Colorado Bad Faith Without Owed Benefits)

Date: Mar 30, 2026

Exceptions to One Auto-Policy Exclusion Do Not Create Ambiguity or Coverage Against a Separate, Independently Dispositive Exclusion (and No Colorado Bad Faith Without Owed Benefits) Introduction In...

Rule 28 Enforcement Against Pro Se Appellants: Incorporation-by-Reference and Reply-Brief Arguments Justify Dismissal of the Appeal

Date: Mar 29, 2026

Rule 28 Enforcement Against Pro Se Appellants: Incorporation-by-Reference and Reply-Brief Arguments Justify Dismissal of the Appeal I. Introduction In Davis v. Howes (10th Cir. Mar. 27, 2026), Kevin...

Appeal Waivers Bar Challenges to Criminal-Contempt Judgments Despite Jurisdictional Attacks on the Underlying Civil Case

Date: Mar 29, 2026

Appeal Waivers Bar Challenges to Criminal-Contempt Judgments Despite Jurisdictional Attacks on the Underlying Civil Case 1. Introduction In In re: Contempt Proceedings Against Daniel E. Carpenter,...

Rooker-Feldman Bars Federal Constitutional Attacks Seeking to Undo State Foreclosure and Eviction Judgments

Date: Mar 29, 2026

Rooker-Feldman Bars Federal Constitutional Attacks Seeking to Undo State Foreclosure and Eviction Judgments I. Introduction In Surface v. Home Mortgage Alliance, LLC (10th Cir. Mar. 27, 2026)...

Harmless-Error Framework for Rule 32.1(b)(2)(C) Confrontation/Balancing Errors in Supervised-Release Revocations (United States v. Gaines)

Date: Mar 29, 2026

Harmless-Error Framework for Rule 32.1(b)(2)(C) Confrontation/Balancing Errors in Supervised-Release Revocations Introduction In United States v. Gaines (10th Cir. Mar. 27, 2026) (nonprecedential...

Federal Sovereign-Injury Standing in Criminal Prosecutions: Article III Does Not Require a Victim-Type Injury

Date: Mar 29, 2026

Federal Sovereign-Injury Standing in Criminal Prosecutions: Article III Does Not Require a Victim-Type Injury Case: United States v. Roark (10th Cir. Mar. 27, 2026) (order denying certificate of...

COA Denial Under AEDPA: “Double Deference” to Strickland Strategy Findings and Harmless Error for Non‑Open‑Court Jury Note Responses

Date: Mar 28, 2026

COA Denial Under AEDPA: “Double Deference” to Strickland Strategy Findings and Harmless Error for Non‑Open‑Court Jury Note Responses Introduction In Montgomery v. Cotton (10th Cir. Mar. 26, 2026),...

Independent Policy Exclusions Are Read Separately; Cross-Exclusion Exceptions Do Not Create Ambiguity, and Bad-Faith Claims Fail Absent Coverage

Date: Mar 27, 2026

Independent Policy Exclusions Are Read Separately; Cross-Exclusion Exceptions Do Not Create Ambiguity, and Bad-Faith Claims Fail Absent Coverage Case: Garrison Property and Casualty v. Horton (Nos....

Expungement During a Pending First § 2255 Proceeding Still Triggers the Second-or-Successive Bar (Lack of Notice Does Not Invoke Weathersby)

Date: Mar 27, 2026

Expungement During a Pending First § 2255 Proceeding Still Triggers the Second-or-Successive Bar (Lack of Notice Does Not Invoke Weathersby) Introduction In United States v. Smith (10th Cir. Mar. 25,...

Federal Power Act Exit Fees for Cooperative Withdrawals: FERC May Reject Lost-Revenues and Approve a Balance-Sheet Method with Transmission Crediting

Date: Mar 27, 2026

Federal Power Act Exit Fees for Cooperative Withdrawals: FERC May Reject Lost-Revenues and Approve a Balance-Sheet Method with Transmission Crediting Case: Tri-State Generation and Transmission...

No Breach, No Lost Revenues: FERC May Require Balance-Sheet Exit Fees with Transmission Crediting for Cooperative Withdrawals

Date: Mar 27, 2026

No Breach, No Lost Revenues: FERC May Require Balance-Sheet Exit Fees with Transmission Crediting for Cooperative Withdrawals Introduction Tri-State Generation and Transmission Association, Inc....

Tariff-Based Cooperative Withdrawals Need Not Use Lost-Revenues Exit Fees: Tenth Circuit Upholds FERC’s Balance-Sheet Methodology and Transmission Crediting

Date: Mar 27, 2026

Tariff-Based Cooperative Withdrawals Need Not Use Lost-Revenues Exit Fees: Tenth Circuit Upholds FERC’s Balance-Sheet Methodology and Transmission Crediting I. Introduction In Tri-State Generation...

Tenth Circuit Endorses FERC’s Balance-Sheet Exit-Fee Methodology for G&T Cooperatives and Rejects Lost-Revenues “Damages” Absent Breach

Date: Mar 27, 2026

Tenth Circuit Endorses FERC’s Balance-Sheet Exit-Fee Methodology for G&T Cooperatives and Rejects Lost-Revenues “Damages” Absent Breach Case: Tri-State Generation and Transmission Association, Inc....

Biglow v. Dell Technologies: Verification Duty for AI-Generated Citations and Narrow FAA Vacatur

Date: Mar 26, 2026

Biglow v. Dell Technologies: Verification Duty for AI-Generated Citations and the Narrow Path to Vacatur Under the FAA I. Introduction Parties: Kevin Lee Biglow (pro se employee; later briefly...