10th Circuit Case Commentaries

Jurisdictional Dismissals Under Rooker-Feldman/Younger Must Be Without Prejudice (and Undeveloped Appellate Arguments Are Waived)

Date: Feb 15, 2026

Jurisdictional Dismissals Under Rooker-Feldman/Younger Must Be Without Prejudice (and Undeveloped Appellate Arguments Are Waived) 1. Introduction In Woodham v. HireRight, LLC (10th Cir. Feb. 13,...

FAA § 3 Default Rule: Nonpayment of Arbitral Fees Permits Lifting a Stay, Distinct from Waiver

Date: Feb 15, 2026

FAA § 3 Default Rule: Nonpayment of Arbitral Fees Permits Lifting a Stay, Distinct from Waiver Introduction In Myers v. Papa Texas, LLC (10th Cir. Feb. 12, 2026), Luke Myers, a pizza delivery driver,...

Pro Se Appellate Waiver Under Rule 28 and the Futility of Amending Claims Barred by Eleventh Amendment and Absolute Judicial Immunity

Date: Feb 15, 2026

Pro Se Appellate Waiver Under Rule 28 and the Futility of Amending Claims Barred by Eleventh Amendment and Absolute Judicial Immunity Introduction In Runkle v. State of Colorado (10th Cir. Feb. 12,...

Spann v. National Conference of Bar Examiners: Preservation and Specificity Requirements for Jurisdictional Discovery and Rule 56(d) Relief; Law-of-the-Case Limits Re-Litigation

Date: Feb 15, 2026

Spann v. National Conference of Bar Examiners: Preservation and Specificity Requirements for Jurisdictional Discovery and Rule 56(d) Relief; Law-of-the-Case Limits Re-Litigation 1. Introduction...

Tenth Circuit Guidance: No Asylum Nexus for Purely Financial Extortion & Caution Against AI-Hallucinated Citations

Date: Feb 13, 2026

Tenth Circuit Guidance: No Asylum Nexus for Purely Financial Extortion & Caution Against AI-Hallucinated Citations Introduction In Chumpitaz-Morales v. Bondi (10th Cir. Feb. 11, 2026) (Order and...

Dodds v. Bridges: Tucker Due Process Requires Sentencing Misinformation—And the Tenth Circuit’s Warning on AI-Fabricated Citations

Date: Feb 13, 2026

Dodds v. Bridges: Tucker Due Process Requires Sentencing Misinformation—And the Tenth Circuit’s Warning on AI-Fabricated Citations Court: United States Court of Appeals for the Tenth Circuit Date:...

United States v. Jensen — Waiver of Unpreserved § 3142(f) Challenges and Affirmance of Detention Based on Proffer Plus Corroborating Evidence

Date: Feb 13, 2026

Waiver of Unpreserved § 3142(f) Detention-Hearing Challenges; Detention May Be Affirmed on Proffer and Corroborating Investigation Introduction In United States v. Jensen (10th Cir. Feb. 11, 2026)...

MVRA Restitution: District Court May Use Updated County “Fair Cash Value” as a Reasonable Proxy for Fair Market Value of Destroyed Property

Date: Feb 13, 2026

MVRA Restitution: District Court May Use Updated County “Fair Cash Value” as a Reasonable Proxy for Fair Market Value of Destroyed Property I. Introduction In United States v. Hemingway (10th Cir....

MVRA Restitution May Be Based on a County Assessor’s Updated “Fair Cash Value” as a Reasonable Proxy for Fair Market Value

Date: Feb 13, 2026

MVRA Restitution May Be Based on a County Assessor’s Updated “Fair Cash Value” as a Reasonable Proxy for Fair Market Value I. Introduction United States v. Hemingway (10th Cir. Feb. 10, 2026)...

Acosta Cruz v. Bondi: Hardship Review After Wilkinson—Courts May Review the Hardship Standard’s Application, But Not Disputes Over Underlying Facts

Date: Feb 12, 2026

Acosta Cruz v. Bondi: Hardship Review After Wilkinson—Courts May Review the Hardship Standard’s Application, But Not Disputes Over Underlying Facts 1. Introduction In Acosta Cruz v. Bondi (10th Cir....

MVRA Restitution May Be Based on Updated Tax-Assessor “Fair Cash Value” as a Reasonable Proxy for Fair Market Value

Date: Feb 12, 2026

MVRA Restitution May Be Based on Updated Tax-Assessor “Fair Cash Value” as a Reasonable Proxy for Fair Market Value I. Introduction In United States v. Hemingway (10th Cir. Feb. 10, 2026), the Tenth...

Rule 38 Sanctions for GenAI-Hallucinated Citations and Misquoted Authority in an Appeal

Date: Feb 11, 2026

Rule 38 Sanctions for GenAI-Hallucinated Citations and Misquoted Authority in an Appeal Introduction In Amarsingh v. Frontier Airlines, Inc. (10th Cir. Feb. 9, 2026), the Tenth Circuit affirmed the...

United States v. Daugherty: Adequate Upward-Variance Explanations May Rely on Unscored Criminal History; Jurisdictional Tribal References Are Not Plain Error; Unraised Disparity-Statistics Arguments Are Waived Without Plain-Error Briefing

Date: Feb 10, 2026

United States v. Daugherty: Adequate Upward-Variance Explanations May Rely on Unscored Criminal History; Jurisdictional Tribal References Are Not Plain Error; Unraised Disparity-Statistics Arguments...

Victim-Sympathy and Deterrence Remarks at Sentencing Do Not Require Recusal Absent an Extrajudicial Source or Deep-Seated Antagonism

Date: Feb 8, 2026

Victim-Sympathy and Deterrence Remarks at Sentencing Do Not Require Recusal Absent an Extrajudicial Source or Deep-Seated Antagonism Case: United States v. Williams (10th Cir. Feb. 6, 2026) (Order...

FRAP 28 Requires Real, Accurate Authority: Pro Se and Generative-AI Use Do Not Excuse Fabricated or Misrepresented Citations (and § 636(c)(4) Cannot Reopen Final Judgments)

Date: Feb 8, 2026

FRAP 28 Requires Real, Accurate Authority: Pro Se and Generative-AI Use Do Not Excuse Fabricated or Misrepresented Citations (and § 636(c)(4) Cannot Reopen Final Judgments) 1. Introduction Sifuentes...

Simpson v. QuickCourt (10th Cir. Feb. 6, 2026) — Commentary

Date: Feb 8, 2026

Denial of En Banc Review Leaves in Place an Expanded Rooker-Feldman Bar for § 1983 Challenges to State “Non-Merits” Dismissals in Capital Litigation 1. Introduction In Simpson v. Quick, Kendrick...

Qualified-Immunity Denials Require a Claim-by-Claim Two-Prong Analysis (and May Pull In a Monell Appeal via Pendent Jurisdiction)

Date: Feb 8, 2026

Qualified-Immunity Denials Require a Claim-by-Claim Two-Prong Analysis (and May Pull In a Monell Appeal via Pendent Jurisdiction) Case: Simmons v. City of Oklahoma City (consolidated appeals Nos....

Simmons v. Shobert: District Courts Must Perform a Claim-Specific Qualified Immunity Analysis (and Cannot Deny Summary Judgment Merely Because “All Facts Are Disputed”)

Date: Feb 8, 2026

Simmons v. Shobert: District Courts Must Perform a Claim-Specific Qualified Immunity Analysis (and Cannot Deny Summary Judgment Merely Because “All Facts Are Disputed”) 1. Introduction Simmons v....

Intrinsic “Res Gestae” Evidence Includes Immediately Preceding Uncharged Homicides When Needed to Complete the Carjacking Narrative (and Due Process Claims Are Waived Without Plain-Error Development)

Date: Feb 7, 2026

Intrinsic “Res Gestae” Evidence Includes Immediately Preceding Uncharged Homicides When Needed to Complete the Carjacking Narrative (and Due Process Claims Are Waived Without Plain-Error Development)...

Simmons v. Shobert: District Courts Must Perform a Claim-by-Claim Qualified-Immunity Analysis Despite Fact Disputes; Intertwined Monell Denials May Be Vacated Under Pendent Jurisdiction

Date: Feb 7, 2026

Simmons v. Shobert: District Courts Must Perform a Claim-by-Claim Qualified-Immunity Analysis Despite Fact Disputes; Intertwined Monell Denials May Be Vacated Under Pendent Jurisdiction Court: U.S....