10th Circuit Case Commentaries

United States v. Martinez: No Strickland Prejudice Where Direct Appeal Found “No Error,” Even Under Plain-Error Review; Unraised Cumulative-Error Theories Are Waived in § 2255

Date: Feb 7, 2026

United States v. Martinez: No Strickland Prejudice Where Direct Appeal Found “No Error,” Even Under Plain-Error Review; Unraised Cumulative-Error Theories Are Waived in § 2255 Introduction In United...

Ambiguous Travel-Plan Discrepancies Alone Do Not Create Reasonable Suspicion to Extend a Traffic Stop for a Canine Sniff (United States v. Robbins)

Date: Feb 7, 2026

Ambiguous Travel-Plan Discrepancies Alone Do Not Create Reasonable Suspicion to Extend a Traffic Stop for a Canine Sniff (United States v. Robbins) Introduction In United States v. Robbins (10th Cir....

Rooker-Feldman Bars § 1983 “State Process” Attacks that Functionally Seek Reversal of a State Court Ripeness Ruling

Date: Feb 6, 2026

Rooker-Feldman Bars § 1983 “State Process” Attacks that Functionally Seek Reversal of a State Court Ripeness Ruling Introduction In Simpson v. Quick (10th Cir. Feb. 4, 2026), death-sentenced Oklahoma...

§ 1307(b) Voluntary Dismissal Is Not Immediate or Self-Executing: Bankruptcy Court May Decide Stay Relief First and Condition Dismissal (Including § 109(g)(2) Bar)

Date: Feb 5, 2026

§ 1307(b) Voluntary Dismissal Is Not Immediate or Self-Executing: Bankruptcy Court May Decide Stay Relief First and Condition Dismissal (Including § 109(g)(2) Bar) 1. Introduction In Lorenzo Luciano...

Consent to Search Remains Voluntary Where Police Link a Medical Furlough to Bond-Condition Firearm Surrender Absent Express Conditioning of Medical Care

Date: Feb 5, 2026

Consent to Search Remains Voluntary Where Police Link a Medical Furlough to Bond-Condition Firearm Surrender Absent Express Conditioning of Medical Care Case: United States v. Shobert (10th Cir. Feb....

COA Denied for Rule 60(b) Re-Litigation of § 2244(d) Timeliness: Colorado Prison Mailbox Rule Requires Proof of Legal-Mail Use

Date: Feb 5, 2026

COA Denied for Rule 60(b) Re-Litigation of § 2244(d) Timeliness: Colorado Prison Mailbox Rule Requires Proof of Legal-Mail Use Introduction In Victorino v. Jacques (10th Cir. Feb. 3, 2026), Angel D....

Cryptocurrency and Loan Proceeds Count as “Assets” Under 28 U.S.C. § 1915; Indigency Is Measured at Filing, Not After Self-Inflicted Depletion

Date: Feb 1, 2026

Cryptocurrency and Loan Proceeds Count as “Assets” Under 28 U.S.C. § 1915; Indigency Is Measured at Filing, Not After Self-Inflicted Depletion I. Introduction In Smith v. Oklahoma Attorney General's...

Pattern-and-Practice Standing for Highway-Stop Injunctions; Federalism Limits Remedies to Necessity; Two-Step Injunction Rejected Under Tenth Circuit Consent/Seizure Precedent

Date: Feb 1, 2026

Pattern-and-Practice Standing for Highway-Stop Injunctions; Federalism Limits Remedies to Necessity; Two-Step Injunction Rejected Under Tenth Circuit Consent/Seizure Precedent Case: Shaw, Bosire,...

Out-of-State Motorists Have Standing to Enjoin a State Police Pattern of Unconstitutional Stops, but Relief Must Be Narrow and Cannot Restrict the “Kansas Two-Step” Contrary to Circuit Precedent

Date: Feb 1, 2026

Out-of-State Motorists Have Standing to Enjoin a State Police Pattern of Unconstitutional Stops, but Relief Must Be Narrow and Cannot Restrict the “Kansas Two-Step” Contrary to Circuit Precedent...

Consecutive Revocation Sentences Are Reasonable When Grounded in Chapter 7 Policy and § 3553(a) Breach-of-Trust Factors (United States v. Harris)

Date: Jan 31, 2026

Consecutive Revocation Sentences Are Reasonable When Grounded in Chapter 7 Policy and § 3553(a) Breach-of-Trust Factors (United States v. Harris) Introduction In United States v. Harris (10th Cir....

Shaw v. Smith: Standing to Enjoin Systemic Highway-Patrol Stops, but Injunctions Must Be Minimally Intrusive and Cannot Redefine the “Kansas Two-Step”

Date: Jan 31, 2026

Shaw v. Smith: Standing to Enjoin Systemic Highway-Patrol Stops, but Injunctions Must Be Minimally Intrusive and Cannot Redefine the “Kansas Two-Step” Court: United States Court of Appeals for the...

Negligent Post-Charge Delay in a Federal Misdemeanor Does Not Violate the Sixth Amendment Absent Active Assertion and Concrete Prejudice (United States v. Antunez)

Date: Jan 31, 2026

Negligent Post-Charge Delay in a Federal Misdemeanor Does Not Violate the Sixth Amendment Absent Active Assertion and Concrete Prejudice (United States v. Antunez) I. Introduction In United States v....

Enforcing Hahn Appeal Waivers in Anders Appeals After a Valid Rule 11 Plea (United States v. Hanks)

Date: Jan 31, 2026

Enforcing Hahn Appeal Waivers in Anders Appeals After a Valid Rule 11 Plea (United States v. Hanks) I. Introduction In United States v. Hanks (10th Cir. Jan. 29, 2026) (Order and Judgment), the Tenth...

Balance v. Johnson County: Initial Jail Classification Decisions Trigger § 1983 Accrual; “Continuing” Restrictions Alone Do Not Extend Limitations

Date: Jan 30, 2026

Balance v. Johnson County: Initial Jail Classification Decisions Trigger § 1983 Accrual; “Continuing” Restrictions Alone Do Not Extend Limitations Court: United States Court of Appeals for the Tenth...

United States v. Ruiz: Birthplace-and-Database Evidence Cannot Prove Non-Indian Status Beyond a Reasonable Doubt Under 18 U.S.C. § 1152

Date: Jan 29, 2026

United States v. Ruiz: Birthplace-and-Database Evidence Cannot Prove Non-Indian Status Beyond a Reasonable Doubt Under 18 U.S.C. § 1152 Court: U.S. Court of Appeals for the Tenth Circuit Date:...

Strack’s “Ranges” Are Guidelines, Not Ceilings: Upholding a 33.33% Common-Fund Fee (2.15 Lodestar Multiplier) Under Oklahoma Reasonableness Review

Date: Jan 29, 2026

Strack’s “Ranges” Are Guidelines, Not Ceilings: Upholding a 33.33% Common-Fund Fee (2.15 Lodestar Multiplier) Under Oklahoma Reasonableness Review Case: Chieftain Royalty Company v. Enervest Energy...

United States v. Kimble: Written Plea Agreements Can Sustain Appellate-Waiver Enforcement Despite a Missing Rule 11 Transcript

Date: Jan 29, 2026

United States v. Kimble: Written Plea Agreements Can Sustain Appellate-Waiver Enforcement Despite a Missing Rule 11 Transcript Introduction In United States v. Kimble (10th Cir. Jan. 23, 2026)...

Bonilla-Espinoza v. Bondi: Sua Sponte Enforcement of Issue Exhaustion and a Demanding Proof Standard for CAT “Torture”

Date: Jan 29, 2026

Bonilla-Espinoza v. Bondi: Sua Sponte Enforcement of Issue Exhaustion and a Demanding Proof Standard for CAT “Torture” Court: United States Court of Appeals for the Tenth Circuit Date: January 27,...

Rule 60(b) as a Successive Habeas End-Run: No COA Needed, but Authorization Still Required

Date: Jan 29, 2026

Rule 60(b) as a Successive Habeas End-Run: No COA Needed, but Authorization Still Required 1. Introduction Mathis v. Bridges (10th Cir. Jan. 27, 2026) addresses a recurring post-conviction pattern: a...

Reasonableness Over Benchmarks: Strack’s 20–30% and 1.5 Multiplier Ranges Are Flexible When Oklahoma § 2023(G)(4)(e) Factors Justify a Higher Class-Fee Award

Date: Jan 29, 2026

Reasonableness Over Benchmarks: Strack’s 20–30% and 1.5 Multiplier Ranges Are Flexible When Oklahoma § 2023(G)(4)(e) Factors Justify a Higher Class-Fee Award Case: Chieftain Royalty Company v....