10th Circuit Case Commentaries

Tenth Circuit: “Reasonable, Good-Faith Efforts” to Find a Transient Witness Suffice for Confrontation-Clause Unavailability

Date: Aug 26, 2026

Tenth Circuit: “Reasonable, Good-Faith Efforts” to Find a Transient Witness Suffice for Confrontation-Clause Unavailability Case: United States v. Barker (No. 24-7100) Court: Court of Appeals for the...

Plain-Error Reversal When Jury Isn’t Told Government Must Disprove Imperfect Self-Defense Beyond a Reasonable Doubt

Date: Aug 26, 2026

Plain-Error Reversal When Jury Isn’t Told Government Must Disprove Imperfect Self-Defense Beyond a Reasonable Doubt Introduction In United States v. Phillips (10th Cir. Aug. 25, 2026), the Tenth...

Objection Deadlines Run from Mailing, Not Receipt: Untimely Objections Trigger the Firm Waiver Rule and Defeat a COA

Date: Aug 26, 2026

Objection Deadlines Run from Mailing, Not Receipt: Untimely Objections Trigger the Firm Waiver Rule and Defeat a COA Introduction In Martinez v. Bergman (10th Cir. Aug. 25, 2026), Jason Martinez, a...

Martinez-Viguerias: The BIA Must Give Cogent, Record-Engaging Reasons to Reject IJ CAT Factfinding Under Clear-Error Review

Date: Aug 26, 2026

Martinez-Viguerias: The BIA Must Give Cogent, Record-Engaging Reasons to Reject IJ CAT Factfinding Under Clear-Error Review 1. Introduction Case: Martinez-Viguerias v. Blanche, No. 25-9556 (10th Cir....

Prior Professional Acquaintance Alone Does Not Require Recusal; Rule 60(b)(6) Cannot Repackage Earlier-Available Arguments in Hague Return Cases

Date: Aug 26, 2026

Prior Professional Acquaintance Alone Does Not Require Recusal; Rule 60(b)(6) Cannot Repackage Earlier-Available Arguments in Hague Return Cases Case: Dumitrascu v. Dumitrascu (10th Cir. Aug. 24,...

Rule 8(a) as a Standalone Basis to Dismiss Prolix § 1983 Complaints—and Appellate Forfeiture When the Rule 8 Ruling Is Not Challenged

Date: Aug 26, 2026

Rule 8(a) as a Standalone Basis to Dismiss Prolix § 1983 Complaints—and Appellate Forfeiture When the Rule 8 Ruling Is Not Challenged 1. Introduction Anderson v. Woods (10th Cir. Aug. 24, 2026) arose...

AEDPA and Mixed IQ Scores: No Clearly Established Right to an Atkins Hearing When One Valid Score Exceeds Oklahoma’s 76 Cutoff

Date: Aug 26, 2026

AEDPA and Mixed IQ Scores: No Clearly Established Right to an Atkins Hearing When One Valid Score Exceeds Oklahoma’s 76 Cutoff Case: Fuston v. Quick, No. 24-6166 (10th Cir. Aug. 21, 2026) (published)...

Broad Catchall Authority Under 18 U.S.C. § 3583(d): “Pay-if-able” Treatment-Cost Contributions as Valid Special Conditions of Supervised Release

Date: Aug 21, 2026

Broad Catchall Authority Under 18 U.S.C. § 3583(d): “Pay-if-able” Treatment-Cost Contributions as Valid Special Conditions of Supervised Release I. Introduction In United States v. Williams (10th...

Qualified Immunity Requires Fact-Specific Precedent: Canine Deployment Against an Armed, Noncompliant Suspect and Deadly Force Triggered by a Gun Aimed at a Police Canine

Date: Aug 21, 2026

Qualified Immunity Requires Fact-Specific Precedent: Canine Deployment Against an Armed, Noncompliant Suspect and Deadly Force Triggered by a Gun Aimed at a Police Canine 1. Introduction In Estate of...

Receipt Notices Are Not “Prima Facie Eligibility”: Limits on U-Visa-Based Termination and Deferential Review of Hardship in Cancellation Cases

Date: Aug 21, 2026

Receipt Notices Are Not “Prima Facie Eligibility”: Limits on U-Visa-Based Termination and Deferential Review of Hardship in Cancellation Cases Case: Castaneda-Ramirez v. Bondi (caption reflects...

State Action in § 1983 Under § 1331 Is a Merits Element (Not Jurisdiction) and Colorado Child Legal Representatives Are Not State Actors

Date: Aug 21, 2026

State Action in § 1983 Under § 1331 Is a Merits Element (Not Jurisdiction) and Colorado Child Legal Representatives Are Not State Actors I. Introduction In Gladstone v. Tarrin (10th Cir. Aug. 18,...

Law-of-the-Case Bars Repackaged Challenges to an Enforced Appeal Waiver in Serial Contempt Appeals

Date: Aug 21, 2026

Law-of-the-Case Bars Repackaged Challenges to an Enforced Appeal Waiver in Serial Contempt Appeals 1. Introduction Case: In re: Contempt Proceedings Against Carpenter (10th Cir. Aug. 18, 2026)....

Coram Nobis After a Guilty Plea: Anonymous “Whistleblower” Allegations Must Show a Diligent, Plea-Related Miscarriage of Justice

Date: Aug 21, 2026

Coram Nobis After a Guilty Plea: Anonymous “Whistleblower” Allegations Must Show a Diligent, Plea-Related Miscarriage of Justice I. Introduction In United States v. Migliaccio (10th Cir. Aug. 18,...

Andrew v. Tinsley and the “Central Jury Issues” Limitation on Due-Process Challenges to Irrelevant, Prejudicial Evidence in Federal Habeas Review

Date: Aug 21, 2026

Andrew v. Tinsley and the “Central Jury Issues” Limitation on Due-Process Challenges to Irrelevant, Prejudicial Evidence in Federal Habeas Review Case: Andrew v. Tinsley, No. 15-6190 (10th Cir.)...

Standing to Appeal Requires a Conviction: Post‑Verdict Dismissal of a Count Moots Challenges to Pretrial Denial of Dismissal

Date: Aug 21, 2026

Standing to Appeal Requires a Conviction: Post‑Verdict Dismissal of a Count Moots Challenges to Pretrial Denial of Dismissal 1. Introduction In United States v. Clements (10th Cir. Aug. 17, 2026),...

AECOM Technical Services v. Flatiron | AECOM: Unaccepted Offers of Judgment Do Not Moot Claims and Unpleaded Theories/Fraud Cannot Be Added After the Final Pretrial Order Absent Manifest Injustice

Date: Aug 21, 2026

Unaccepted Offers of Judgment Do Not Moot Claims; Post-Pretrial Additions of Fraud and Unpled Contract Theories Require “Manifest Injustice” Case: AECOM Technical Services, Inc. v. Flatiron | AECOM,...

Andrew v. Tinsley (10th Cir. 2026): En Banc Denial Leaves in Place a Restrictive AEDPA Due-Process Framework for “Irrelevant and Prejudicial” Evidence

Date: Aug 21, 2026

En Banc Denial Leaves in Place a Restrictive AEDPA Due-Process Framework for “Irrelevant and Prejudicial” Evidence I. Introduction Andrew v. Tinsley (10th Cir. Aug. 14, 2026) is a published order...

COA Required for Merits-Targeting Rule 59(e) Orders in § 2254; Untimely Rule 59(e) Is Procedurally Fatal (and May Become an Unauthorized Successive Petition if Recast as Rule 60(b))

Date: Aug 21, 2026

COA Required for Merits-Targeting Rule 59(e) Orders in § 2254; Untimely Rule 59(e) Is Procedurally Fatal (and May Become an Unauthorized Successive Petition if Recast as Rule 60(b)) 1. Introduction...

Credibility Is Not Enough: Corroboration May Be Required, and Post-BIA Evidence Is Excluded from Judicial Review of Removal Orders

Date: Aug 21, 2026

Credibility Is Not Enough: Corroboration May Be Required, and Post-BIA Evidence Is Excluded from Judicial Review of Removal Orders 1. Introduction Ntwari v. Bondi (10th Cir. Aug. 14, 2026) concerns a...

Temporal Proximity Alone Does Not Make a Separate State Offense “Relevant Conduct” Triggering Mandatory Concurrency Under U.S.S.G. § 5G1.3(c) on Plain-Error Review

Date: Aug 21, 2026

Temporal Proximity Alone Does Not Make a Separate State Offense “Relevant Conduct” Triggering Mandatory Concurrency Under U.S.S.G. § 5G1.3(c) on Plain-Error Review 1) Introduction In United States v....