10th Circuit Case Commentaries

No Right to Nullify Materiality: Tenth Circuit Holds False Denial of Felony Indictment on Form 4473 Is Actionable Because § 922(n) Is Facially Valid

Date: Oct 1, 2025

No Right to Nullify Materiality: Tenth Circuit Holds False Denial of Felony Indictment on Form 4473 Is Actionable Because § 922(n) Is Facially Valid Introduction In United States v. Reilly...

After Rahimi, McCane Still Rules: Tenth Circuit Reaffirms § 922(g)(1) Against Nonviolent-Felon As-Applied Challenges (United States v. Forbis & Smith)

Date: Oct 1, 2025

After Rahimi, McCane Still Rules: Tenth Circuit Reaffirms § 922(g)(1) Against Nonviolent-Felon As-Applied Challenges (United States v. Forbis & Smith) Court: U.S. Court of Appeals for the Tenth...

Lying About Indictment Status on Form 4473 Is “Material” Under § 922(a)(6) Where § 922(n) Is Facially Valid: Commentary on United States v. Reilly (10th Cir. 2025)

Date: Sep 30, 2025

Lying About Indictment Status on Form 4473 Is “Material” Under § 922(a)(6) Where § 922(n) Is Facially Valid: Commentary on United States v. Reilly (10th Cir. 2025) Introduction In United States v....

Mandamus Is Not a Vehicle to Challenge § 636(b) Referrals or Routine Case-Management Orders: In re Huber (10th Cir. 2025)

Date: Sep 28, 2025

Mandamus Is Not a Vehicle to Challenge § 636(b) Referrals or Routine Case-Management Orders: In re Huber (10th Cir. 2025) Introduction In In re Huber, No. 25-4109 (10th Cir. Sept. 26, 2025), the...

“Found In” Means Each Discovery Is a Separate § 1326 Offense—No Intervening Removal Required (United States v. Herrera‑Salazar, 10th Cir. 2025)

Date: Sep 28, 2025

“Found In” Means Each Discovery Is a Separate § 1326 Offense—No Intervening Removal Required Case: United States v. Herrera‑Salazar, No. 24‑7029 (10th Cir. Sept. 26, 2025) (nonprecedential Order and...

United States v. Stacy: Tenth Circuit Opens §1292(a)(1) Path to Enjoin DOJ Spending Under the Medical Marijuana Appropriations Rider and Limits Protection to At Least Substantial Compliance with State Law

Date: Sep 28, 2025

United States v. Stacy: Tenth Circuit Opens §1292(a)(1) Path to Enjoin DOJ Spending Under the Medical Marijuana Appropriations Rider and Limits Protection to At Least Substantial Compliance with...

Davis v. Curtis: Tenth Circuit Reaffirms Continuing Court‑Martial Jurisdiction After ETS and Strict “Full and Fair Consideration” Limits on § 2241 Review

Date: Sep 27, 2025

Continuing Court‑Martial Jurisdiction After ETS and the Strict Dodson Gatekeeper for Military Habeas Review: Commentary on Davis v. Curtis (10th Cir. Sept. 25, 2025) Introduction In Davis v. Curtis,...

No Interlocutory Appeal From Denial of Motion to Dismiss Criminal Contempt: Tenth Circuit Reaffirms “Substance Over Form” and the Narrow Reach of the Collateral-Order Doctrine and 28 U.S.C. § 1292(a)

Date: Sep 27, 2025

No Interlocutory Appeal From Denial of Motion to Dismiss Criminal Contempt: Tenth Circuit Reaffirms “Substance Over Form” and the Narrow Reach of the Collateral-Order Doctrine and 28 U.S.C. § 1292(a)...

Financing Is Not “Labor or Material” Under Subcontract Payment Bonds; Oklahoma’s Parol‑Evidence Stranger Exception Applies; Prevailing Defendants May Recover Fees Under § 936 Based on the Suit’s Gravamen

Date: Sep 27, 2025

Financing Is Not “Labor or Material” Under Subcontract Payment Bonds; Oklahoma’s Parol‑Evidence Stranger Exception Applies; Prevailing Defendants May Recover Fees Under § 936 Based on the Suit’s...

Failure to Argue Plain Error Waives New Appellate Issues—Even for Pro Se Prisoners: A Tenth Circuit Reaffirmation in Rhodes v. Wyoming Department of Corrections

Date: Sep 26, 2025

Failure to Argue Plain Error Waives New Appellate Issues—Even for Pro Se Prisoners: A Tenth Circuit Reaffirmation in Rhodes v. Wyoming Department of Corrections Introduction This commentary analyzes...

No Bond Coverage for Financing Disguised as Sale–Leaseback; Surety May Invoke Parol Evidence as a “Stranger”; Prevailing Defendants Can Recover § 936 Fees Based on Suit’s Gravamen

Date: Sep 26, 2025

No Bond Coverage for Financing Disguised as Sale–Leaseback; Surety May Invoke Parol Evidence as a “Stranger”; Prevailing Defendants Can Recover § 936 Fees Based on Suit’s Gravamen Introduction In...

Law-of-the-Case Bars Codefendants’ Relitigation in Successive Appeals; Managerial Control and Proceeds Suffice to Uphold § 846 Marijuana Conspiracy Conviction

Date: Sep 25, 2025

Law-of-the-Case Bars Codefendants’ Relitigation in Successive Appeals; Managerial Control and Proceeds Suffice to Uphold § 846 Marijuana Conspiracy Conviction Introduction In United States v. Weng,...

Specifics or No Second Chance: Tenth Circuit Confirms FMSHRC’s Discretion to Deny Reopening of Mine Act Defaults Absent Detailed Causation and Prospective Safeguards

Date: Sep 24, 2025

Specifics or No Second Chance: Tenth Circuit Confirms FMSHRC’s Discretion to Deny Reopening of Mine Act Defaults Absent Detailed Causation and Prospective Safeguards Introduction In Tintic...

Between Silence and Speech: No Plain Doyle Error in Mixed Post‑Miranda “Partial Silence” Cases — United States v. White (10th Cir. 2025)

Date: Sep 24, 2025

Between Silence and Speech: No Plain Doyle Error in Mixed Post‑Miranda “Partial Silence” Cases — United States v. White (10th Cir. 2025) Court: United States Court of Appeals for the Tenth Circuit...

Tenth Circuit Clarifies: No Post‑Judgment Right to Unseal or Obtain Records Absent a Particularized Legal Need or Pending Proceeding — United States v. Geddes

Date: Sep 11, 2025

Tenth Circuit Clarifies: No Post‑Judgment Right to Unseal or Obtain Records Absent a Particularized Legal Need or Pending Proceeding — United States v. Geddes Introduction In United States v. Geddes,...

Equitable Estoppel Cannot Broaden “Between the Parties” Arbitration Clauses; Principal’s Waiver Extinguishes an Agent’s Ability to Compel Arbitration — Fucci v. First American Title Insurance Co. (10th Cir. 2025)

Date: Sep 11, 2025

Equitable Estoppel Cannot Broaden “Between the Parties” Arbitration Clauses; Principal’s Waiver Extinguishes an Agent’s Ability to Compel Arbitration — Fucci v. First American Title Insurance Co....

Tenth Circuit Clarifies Appeal-Waiver Cap Tied to a Fixed Offense Level: A Sentence Below the Level-35 Top End Is Unappealable Even If the Court Calculates a Higher Offense Level

Date: Sep 11, 2025

Tenth Circuit Clarifies Appeal-Waiver Cap Tied to a Fixed Offense Level: A Sentence Below the Level-35 Top End Is Unappealable Even If the Court Calculates a Higher Offense Level Introduction In...

Quiet Title Act Exclusivity Forecloses APA/DJA Routes for Split‑Estate Subsurface Traversal Disputes: Commentary on True Oil, LLC v. Bureau of Land Management (10th Cir. 2025)

Date: Sep 10, 2025

Quiet Title Act Exclusivity Forecloses APA/DJA Routes for Split‑Estate Subsurface Traversal Disputes: Commentary on True Oil, LLC v. Bureau of Land Management (10th Cir. 2025) Introduction In True...

Timing and Audience as “Guardrails” for Political Purpose: Tenth Circuit Upholds New Mexico’s Pre‑Election Donor Disclosure for Mention‑Only Ads

Date: Sep 10, 2025

Timing and Audience as “Guardrails” for Political Purpose: Tenth Circuit Upholds New Mexico’s Pre‑Election Donor Disclosure for Mention‑Only Ads Introduction In Rio Grande Foundation v. Oliver, the...

When a Vehicle Poses a Traffic Hazard, Police May Impound and Conduct a Caretaking Search Without Sanders Analysis — United States v. Brown (10th Cir. 2025)

Date: Sep 9, 2025

When a Vehicle Poses a Traffic Hazard, Police May Impound and Conduct a Caretaking Search Without Sanders Analysis — United States v. Brown (10th Cir. 2025) Introduction In United States v. Brown,...