10th Circuit Case Commentaries

Liberal Post‑Judgment Amendment and Union Repudiation as an Exhaustion Exception in § 301 LMRA Suits

Date: Nov 7, 2025

Liberal Post‑Judgment Amendment and Union Repudiation as an Exhaustion Exception in § 301 LMRA Suits Introduction In Yellow Corporation v. International Brotherhood of Teamsters, the Tenth Circuit...

In re Lawson: Tenth Circuit Reaffirms That § 1915(e)(2)(B) Pre‑Service Screening and Short Delays Do Not Justify Mandamus to Compel Service, Reassignment, or Vacatur

Date: Nov 7, 2025

In re Lawson: Tenth Circuit Reaffirms That § 1915(e)(2)(B) Pre‑Service Screening and Short Delays Do Not Justify Mandamus to Compel Service, Reassignment, or Vacatur Introduction In In re Lawson, No....

Burke v. Pitts: Tenth Circuit Constrains “Blatant Contradiction” Review and Reaffirms Clearly Established Limits on No‑Warning Tasers and Deadly Force Against Unarmed Suspects

Date: Nov 7, 2025

Burke v. Pitts: Tenth Circuit Constrains “Blatant Contradiction” Review and Reaffirms Clearly Established Limits on No‑Warning Tasers and Deadly Force Against Unarmed Suspects Introduction In Burke...

Tenth Circuit Bars Reliance on Bodycam/Dashcam Videos at Rule 12(b)(6) and Reaffirms Garner as Clearly Establishing the Unlawfulness of Shooting an Unarmed, Fleeing Suspect

Date: Nov 7, 2025

Tenth Circuit Bars Reliance on Bodycam/Dashcam Videos at Rule 12(b)(6) and Reaffirms Garner as Clearly Establishing the Unlawfulness of Shooting an Unarmed, Fleeing Suspect Introduction In Fuqua v....

Klingler v. Bridges: Tenth Circuit Reaffirms AEDPA “Double Deference” and Requires Proof of Indian Status to Defeat State Criminal Jurisdiction

Date: Nov 7, 2025

Klingler v. Bridges: Tenth Circuit Reaffirms AEDPA “Double Deference” and Requires Proof of Indian Status to Defeat State Criminal Jurisdiction Introduction This commentary analyzes the Tenth...

No Policy from a Single Incident: Tenth Circuit Clarifies Plausibility Pleading for Title VII Disparate-Impact Claims Based on Criminal-Record Screening

Date: Nov 7, 2025

No Policy from a Single Incident: Tenth Circuit Clarifies Plausibility Pleading for Title VII Disparate-Impact Claims Based on Criminal-Record Screening Introduction In Lawrence v. Nightingale...

No Presumption Against Upward Variances: Tenth Circuit Affirms Use of Uncharged Domestic-Violence Conduct in § 3553(a) Analysis

Date: Nov 7, 2025

No Presumption Against Upward Variances: Tenth Circuit Affirms Use of Uncharged Domestic-Violence Conduct in § 3553(a) Analysis Case: United States v. Bright, No. 24-6238 (10th Cir. Nov. 4, 2025)...

United States v. Johnson: No Plain Error in Admitting Law‑Enforcement Incident Reports via Rule 803(6); Specific Theories Required to Preserve 404(b)/403 Objections; § 3553(a)(6) Satisfied by Record‑Based Justification in ACA Sentences

Date: Nov 7, 2025

United States v. Johnson: No Plain Error in Admitting Law‑Enforcement Incident Reports via Rule 803(6); Specific Theories Required to Preserve 404(b)/403 Objections; § 3553(a)(6) Satisfied by...

United States v. Sockey: Tenth Circuit Adopts the “Words Alone” Limitation on Heat-of-Passion Manslaughter Under 18 U.S.C. §§ 1111–1112

Date: Nov 7, 2025

United States v. Sockey: Tenth Circuit Adopts the “Words Alone” Limitation on Heat-of-Passion Manslaughter Under 18 U.S.C. §§ 1111–1112 Introduction In United States v. Sockey (10th Cir. Nov. 4,...

Tenth Circuit Holds EAJA Applies to Habeas Challenges to Immigration Detention: “Any Civil Action” Includes Immigration Habeas

Date: Nov 5, 2025

Tenth Circuit Holds EAJA Applies to Habeas Challenges to Immigration Detention: “Any Civil Action” Includes Immigration Habeas Introduction This published decision from the U.S. Court of Appeals for...

Audience Matters: Tenth Circuit Confirms External Whistleblowing by Government Lawyers Is Not “Pursuant to” Official Duties Under Garcetti/Pickering

Date: Nov 5, 2025

Audience Matters: Tenth Circuit Confirms External Whistleblowing by Government Lawyers Is Not “Pursuant to” Official Duties Under Garcetti/Pickering Introduction In Timmins v. Plotkin, No. 24-1160...

No Automatic Right to a Fed Master Account: Tenth Circuit Confirms Reserve Bank Discretion and Limits APA Review in Custodia Bank v. FRBKC

Date: Nov 2, 2025

No Automatic Right to a Fed Master Account: Tenth Circuit Confirms Reserve Bank Discretion and Limits APA Review Introduction In a closely watched dispute at the intersection of payments...

COA Requires Developed, Issue-Specific Argument; Prosecutorial “Vouching” Not Clearly Established as a Standalone Due Process Violation under AEDPA — Revilla v. Harpe (10th Cir. 2025)

Date: Nov 2, 2025

COA Requires Developed, Issue-Specific Argument; Prosecutorial “Vouching” Not Clearly Established as a Standalone Due Process Violation under AEDPA — Revilla v. Harpe (10th Cir. 2025) Introduction In...

Direct Control of a Known-Contents Container Equals Actual Possession; Broad Discretion to Give Anti-CSI Instructions: Commentary on United States v. Eddings (10th Cir. 2025)

Date: Nov 2, 2025

Direct Control of a Known-Contents Container Equals Actual Possession; Broad Discretion to Give Anti-CSI Instructions: Commentary on United States v. Eddings (10th Cir. 2025) Introduction United...

Prior Downward Variance as a § 3553(a) “Backdrop”: Tenth Circuit Affirms Broad Discretion to Deny Compassionate Release Despite Plausible Family-Circumstances Showing

Date: Nov 2, 2025

Prior Downward Variance as a § 3553(a) “Backdrop”: Tenth Circuit Affirms Broad Discretion to Deny Compassionate Release Despite Plausible Family-Circumstances Showing Case: United States v. Fraser,...

Licensing‑Board Reports as Adverse Actions and the “Unbroken Chain” in Cat’s Paw Retaliation: The Tenth Circuit’s Decision in Byrnes v. St. Catherine Hospital

Date: Nov 1, 2025

Licensing‑Board Reports as Adverse Actions and the “Unbroken Chain” in Cat’s Paw Retaliation: The Tenth Circuit’s Decision in Byrnes v. St. Catherine Hospital Introduction In Byrnes v. St. Catherine...

Reaffirming the “Collective Inferences” Sufficiency Standard: Tenth Circuit Rejects “Piling Inference upon Inference” Challenge in United States v. Munguia‑Herrera

Date: Nov 1, 2025

Reaffirming the “Collective Inferences” Sufficiency Standard: Tenth Circuit Rejects “Piling Inference upon Inference” Challenge in United States v. Munguia‑Herrera Court: United States Court of...

“Just to Be Safe” Is Not Reasonable Suspicion: The Tenth Circuit Narrows Terry Frisks and Rejects Hypothetical Protective Sweeps in United States v. Huerta

Date: Nov 1, 2025

“Just to Be Safe” Is Not Reasonable Suspicion: The Tenth Circuit Narrows Terry Frisks and Rejects Hypothetical Protective Sweeps in United States v. Huerta Introduction In United States v. Huerta,...

Tenth Circuit: Technical Service Defects Cannot Thwart Merits; APA Review Requires Federal Final Agency Action — Miller v. USDA

Date: Oct 30, 2025

Tenth Circuit: Technical Service Defects Cannot Thwart Merits; APA Review Requires Federal Final Agency Action — Miller v. USDA Introduction In Miller v. USDA, No. 24-6252 (10th Cir. Oct. 28, 2025),...

Tenth Circuit Clarifies: DOL Wage Complaints Do Not Toll Discrimination Filing Deadlines; Retaliation Requires Harm Beyond Consequences of a Physician’s Self‑Reporting Duty

Date: Oct 30, 2025

Tenth Circuit Clarifies: DOL Wage Complaints Do Not Toll Discrimination Filing Deadlines; Retaliation Requires Harm Beyond Consequences of a Physician’s Self‑Reporting Duty Introduction In Saini v....