10th Circuit Case Commentaries

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....

United States v. Reed: No Temporal Limitation Required for a Cellphone Warrant Tied to an Ongoing Possession Offense of Unknown Duration

Date: Aug 18, 2026

United States v. Reed: No Temporal Limitation Required for a Cellphone Warrant Tied to an Ongoing Possession Offense of Unknown Duration Court: United States Court of Appeals for the Tenth Circuit...

Marquez-Cortez v. Bondi: Sua Sponte Issue-Exhaustion and Tightened Proof of “Social Distinction,” Nexus, and CAT Acquiescence in Gang-Violence Claims

Date: Aug 18, 2026

Marquez-Cortez v. Bondi: Sua Sponte Issue-Exhaustion and Tightened Proof of “Social Distinction,” Nexus, and CAT Acquiescence in Gang-Violence Claims 1. Introduction In Marquez-Cortez v. Bondi (10th...

Royalty Protest Clauses Bar Decades-Later Recalculations; “Adjoining Lands” Includes All Lands in Any Contiguous Lease

Date: Aug 18, 2026

Royalty Protest Clauses Bar Decades-Later Recalculations; “Adjoining Lands” Includes All Lands in Any Contiguous Lease 1. Introduction Wildcat Coal LLC v. Pacific Minerals Inc., et al. (doing...

ESA Incidental-Take Plans Must Compare the Biological Value of Lost and Replacement Habitat Before Relying on Translocation/Mitigation Assumptions

Date: Aug 18, 2026

ESA Incidental-Take Plans Must Compare the Biological Value of Lost and Replacement Habitat Before Relying on Translocation/Mitigation Assumptions Case: Friends of Animals v. U.S. Fish and Wildlife...

Cross-Commissioned State Officers in Indian Country: Temporary Detention Before Confirming Indian Status Can Be “Under Color of” State Law (and Not a Jurisdictional Bar)

Date: Aug 18, 2026

Cross-Commissioned State Officers in Indian Country: Temporary Detention Before Confirming Indian Status Can Be “Under Color of” State Law (and Not a Jurisdictional Bar) 1. Introduction Walden v. The...

Coram Nobis Relief Demands Diligence and an “Obvious” Miscarriage of Justice; Tailored Filing Restrictions Upheld

Date: Aug 14, 2026

Coram Nobis Relief Demands Diligence and an “Obvious” Miscarriage of Justice; Tailored Filing Restrictions Upheld Case: United States v. Moreno (10th Cir. Aug. 13, 2026) (Order and Judgment,...

United States v. Gigena — Federal-Officer Element Under 18 U.S.C. §§ 111/1114 Satisfied by Task-Force Deputization or “Assisting” Status Without MOU Formalities

Date: Aug 14, 2026

Federal-Officer Element Under 18 U.S.C. §§ 111/1114 Satisfied by Task-Force Deputization or “Assisting” Status Without MOU Formalities 1. Introduction In United States v. Gigena (10th Cir. Aug. 13,...

Standing in FLSA Wage Cases: Courts Must Assume Legal Validity and Avoid Merits Rulings on Rule 12(b)(1)

Date: Aug 12, 2026

Standing in FLSA Wage Cases: Courts Must Assume Legal Validity and Avoid Merits Rulings on Rule 12(b)(1) 1. Introduction In Mighell v. HPG Pizza I (10th Cir. Aug. 11, 2026), plaintiff Steve Mighell,...

Rule 28 Noncompliance in Pro Se Bankruptcy Appeals: Frivolous, Incoherent Briefing Warrants Affirmance

Date: Aug 12, 2026

Rule 28 Noncompliance in Pro Se Bankruptcy Appeals: Frivolous, Incoherent Briefing Warrants Affirmance Introduction Rusk v. Beutler (10th Cir. Aug. 11, 2026) arises from a Chapter 13 bankruptcy in...

Failure to Warn of Medication Side Effects During a Competency Evaluation Does Not Plead Fourteenth Amendment Deliberate Indifference (and Mislabeling “Frivolous” Dismissals Matters for Review and PLRA Strikes)

Date: Aug 12, 2026

Failure to Warn of Medication Side Effects During a Competency Evaluation Does Not Plead Fourteenth Amendment Deliberate Indifference (and Mislabeling “Frivolous” Dismissals Matters for Review and...

Homie Technology v. National Association of Realtors — “Facilitation” Is Not an Exclusionary Agreement: Continuing-Conspiracy Tolling Requires a Plausible Conspiracy in the Challenged Rules Themselves

Date: Aug 12, 2026

“Facilitation” Is Not an Exclusionary Agreement: Continuing-Conspiracy Tolling Requires a Plausible Conspiracy in the Challenged Rules Themselves Case: Homie Technology, Inc. v. National Association...

Appellate Waiver and “Uncontroverted Facts” in Pro Se Summary Judgment: Procedural Defaults Control Title VII/ADA Retaliation Outcomes

Date: Aug 12, 2026

Appellate Waiver and “Uncontroverted Facts” in Pro Se Summary Judgment: Procedural Defaults Control Title VII/ADA Retaliation Outcomes Case: Mitchell-Pennington v. Installtec, Inc. (No. 25-3141) |...

Ortiz y Pino v. Oliver: Enforcement Assurances Cannot Narrow Campaign-Fund Spending Bans to Avoid First Amendment Scrutiny

Date: Aug 12, 2026

Ortiz y Pino v. Oliver: Enforcement Assurances Cannot Narrow Campaign-Fund Spending Bans to Avoid First Amendment Scrutiny I. Introduction Case: Ortiz y Pino v. Oliver, No. 25-2016 (10th Cir. Aug....

Mootness of Interlocutory Appeals After Preliminary Injunction Expiration, and the Tenth Circuit’s Usual Refusal to Vacate

Date: Aug 11, 2026

Mootness of Interlocutory Appeals After Preliminary Injunction Expiration, and the Tenth Circuit’s Usual Refusal to Vacate Case: Edwards Lifesciences LLC & Edwards Lifesciences Corporation v. Michael...

Rule 32 Notice Challenges to Sentencing “Extra-Record Facts” Require a Contemporaneous Objection; Record-Based Inferences Defeat Plain-Error Review

Date: Aug 11, 2026

Rule 32 Notice Challenges to Sentencing “Extra-Record Facts” Require a Contemporaneous Objection; Record-Based Inferences Defeat Plain-Error Review Introduction In United States v. Trujillo (10th...

Tenth Circuit Enforces NLRB Order Requiring Backpay, Record Expungement, and Rescission of Overbroad Employee-Communication Rules

Date: Aug 8, 2026

Tenth Circuit Enforces NLRB Order Requiring Backpay, Record Expungement, and Rescission of Overbroad Employee-Communication Rules Introduction In NLRB v. Titan Medical Center LLC, No. 26-9560 (10th...

Bousley Actual-Innocence Gateway Extends to Equally Serious Dismissed Charges for AEDPA Time-Bar Relief

Date: Aug 8, 2026

Bousley Actual-Innocence Gateway Extends to Equally Serious Dismissed Charges for AEDPA Time-Bar Relief Introduction In United States v. Hahn (10th Cir. Aug. 7, 2026), Marcus Hahn sought...