10th Circuit Case Commentaries

Rule 41(b) Dismissal Without Prejudice Requires No Ehrenhaus Analysis; Frivolous, Inadequate Appellate Briefing Supports Denial of IFP and Warning of Filing Restrictions

Date: Mar 26, 2026

Rule 41(b) Dismissal Without Prejudice Requires No Ehrenhaus Analysis; Frivolous, Inadequate Appellate Briefing Supports Denial of IFP and Warning of Filing Restrictions 1. Introduction In Strege v....

Tri-State Generation and Transmission Association v. FERC — Commentary

Date: Mar 26, 2026

New Rule for Cooperative Exit Fees: FERC May Reject Lost-Revenues “Damages” and Require a Balance-Sheet, Pro‑Rata Debt Methodology (with Transmission Crediting) Case: Tri-State Generation and...

United States v. Jordan: Sustaining Major Upward Variances in § 922(g) Sentences Without Sentencing-Statistics Benchmarking When the § 3553(a) Explanation Is Cogent

Date: Mar 26, 2026

United States v. Jordan: Sustaining Major Upward Variances in § 922(g) Sentences Without Sentencing-Statistics Benchmarking When the § 3553(a) Explanation Is Cogent Court: U.S. Court of Appeals for...

Invited Error Waives Appellate Review of Omitted “Materiality” Element in 18 U.S.C. § 152(3) Jury Instructions

Date: Mar 26, 2026

Invited Error Waives Appellate Review of Omitted “Materiality” Element in 18 U.S.C. § 152(3) Jury Instructions I. Introduction In United States v. Mitchell (10th Cir. Mar. 23, 2026), Richard...

Objective Due Diligence Triggers AEDPA Limitations Despite Counsel’s Failed Direct-Appeal Steps

Date: Mar 19, 2026

Objective Due Diligence Triggers AEDPA Limitations Despite Counsel’s Failed Direct-Appeal Steps Case: Fernandez v. Rogers (10th Cir. Mar. 17, 2026) — Order Denying Certificate of Appealability 1....

Jiang v. City of Tulsa — Procedural Irregularities and Relaxed Qualifications Do Not Show Pretext Absent Evidence the Employer Disbelieved Its Stated Reason

Date: Mar 19, 2026

Procedural Irregularities and Relaxed Qualifications Do Not Show Pretext Absent Evidence the Employer Disbelieved Its Stated Reason Case: Jiang v. City of Tulsa (10th Cir.) Date: March 17, 2026...

Police Inaction in an Active-Shooter Standoff Is Not “Danger Creation”; New Mexico’s Duty-to-Investigate Liability Is Barred Where Officers Are Unable to Act Due to Immediate Deadly Threat

Date: Mar 19, 2026

Police Inaction in an Active-Shooter Standoff Is Not “Danger Creation”; New Mexico’s Duty-to-Investigate Liability Is Barred Where Officers Are Unable to Act Due to Immediate Deadly Threat 1....

Padilla Clarity Rule: For Truly Clear Deportation Consequences, Counsel Must Warn of Practically Inevitable Removal (Tenth Circuit)

Date: Mar 19, 2026

Padilla Clarity Rule: For Truly Clear Deportation Consequences, Counsel Must Warn of Practically Inevitable Removal (Tenth Circuit) 1. Introduction United States v. Aguayo-Montes (10th Cir. Mar. 17,...

Protective Sweeps of Vehicles After Driver’s Arrest Require Passenger-Specific Reasonable Suspicion of Dangerousness

Date: Mar 19, 2026

Protective Sweeps of Vehicles After Driver’s Arrest Require Passenger-Specific Reasonable Suspicion of Dangerousness Introduction In United States v. Williams (10th Cir. Mar. 17, 2026), the Tenth...

Tenth Circuit Signals (Absent En Banc Review) That Federal Reserve Banks May Deny Master Accounts in Their Discretion, Limiting Mandamus Relief for Eligible State-Chartered Banks

Date: Mar 15, 2026

Tenth Circuit Signals (Absent En Banc Review) That Federal Reserve Banks May Deny Master Accounts in Their Discretion, Limiting Mandamus Relief for Eligible State-Chartered Banks Case: Custodia Bank,...

Armendariz v. City of Colorado Springs: Digital-Search Warrants Must Supply a Crime-Specific Nexus and Seizure-Limiting Principles (Including for Keyword and Facebook Data)

Date: Mar 14, 2026

Armendariz v. City of Colorado Springs: Digital-Search Warrants Must Supply a Crime-Specific Nexus and Seizure-Limiting Principles (Including for Keyword and Facebook Data) Introduction In Armendariz...

United States v. Wofford — Plain-Error Approval of “Witness Identification Is Sufficient” § 924(c) Firearm Instruction (Context-Dependent)

Date: Mar 13, 2026

United States v. Wofford — Plain-Error Approval of “Witness Identification Is Sufficient” § 924(c) Firearm Instruction (Context-Dependent) Court: U.S. Court of Appeals for the Tenth Circuit Date:...

United States v. Zamora-Guerra: No Waiver from Alternative Sentencing Cap Requests; JSIN Statistics Do Not Undermine a Well-Explained Upward Variance

Date: Mar 13, 2026

United States v. Zamora-Guerra: No Waiver from Alternative Sentencing Cap Requests; JSIN Statistics Do Not Undermine a Well-Explained Upward Variance Court: Court of Appeals for the Tenth Circuit...

Unambiguous Cession Language in the 1891 Act Disestablished the Citizen Potawatomi Reservation and Unpreserved Indian-Country Theories Are Waived in Federal Habeas

Date: Mar 13, 2026

Unambiguous Cession Language in the 1891 Act Disestablished the Citizen Potawatomi Reservation and Unpreserved Indian-Country Theories Are Waived in Federal Habeas 1. Introduction Wahpekeche v....

CSPA Conversion Rule: “Age” in § 1151(f)(2) Means CSPA Statutory Age at Naturalization; NVC Reclassification Is Reviewable Final Agency Action

Date: Mar 12, 2026

CSPA Conversion Rule: “Age” in § 1151(f)(2) Means CSPA Statutory Age at Naturalization; NVC Reclassification Is Reviewable Final Agency Action I. Introduction Dekovic v. Rubio (10th Cir. Mar. 10,...

Tenth Circuit: Absolute Legislative Immunity Bars § 1983 Injunctions and Damages Challenging State Legislative Decorum Rules Adopted and Enforced in Committee Hearings

Date: Mar 12, 2026

Tenth Circuit: Absolute Legislative Immunity Bars § 1983 Injunctions and Damages Challenging State Legislative Decorum Rules Adopted and Enforced in Committee Hearings Introduction In Gays Against...

United States v. Becker: Probable-Cause Nexus for Firearm Searches—Database Attribution Plus Surveillance Supports “Residence” and Firearm-at-Home Inference Survives Three-Week Delay

Date: Mar 10, 2026

United States v. Becker: Probable-Cause Nexus for Firearm Searches—Database Attribution Plus Surveillance Supports “Residence” and Firearm-at-Home Inference Survives Three-Week Delay Introduction In...

Preserving Rule 701/403 Objections Requires Specificity and Renewal; Overwhelming Evidence Defeats Plain-Error Prejudice

Date: Mar 10, 2026

Preserving Rule 701/403 Objections Requires Specificity and Renewal; Overwhelming Evidence Defeats Plain-Error Prejudice Introduction In United States v. Smith (10th Cir. Mar. 9, 2026)...

Perry v. Encore at Boulevard One: Surviving § 1915 Screening Does Not Bar Later Rule 12(b)(6) Dismissal; Completed Eviction Moots TRO

Date: Mar 8, 2026

Perry v. Encore at Boulevard One: Surviving § 1915 Screening Does Not Bar Later Rule 12(b)(6) Dismissal; Completed Eviction Moots TRO 1) Introduction Perry v. Encore at Boulevard One LLC (10th Cir....

Davis Successive § 2255 Challenges: Petitioner Must Prove the § 924(c) Sentencing Rested on the Residual Clause

Date: Mar 8, 2026

Davis Successive § 2255 Challenges: Petitioner Must Prove the § 924(c) Sentencing Rested on the Residual Clause Introduction United States v. Sandoval-Flores (10th Cir. Mar. 6, 2026) addresses a...