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“Reasonably-Equivalent Value” Re-Defined: White v. Wardley and the Tenth Circuit’s Blueprint for Evaluating Guaranties and Debt Satisfaction under the Utah UFTA Introduction White v. Wardley (In re...
Reaffirming the Narrow Scope of the Reeves Exception: Pretext Alone Sends ADA & Rehabilitation Act Claims to a Jury Introduction In Jenny v. L3Harris Technologies, Inc., the United States Court of...
From “Significant Change” to “Some Harm”: The Tenth Circuit’s Adoption of the Muldrow Standard in Scheer v. Sisters of Charity 1. Introduction Case: Bethany Scheer v. Sisters of Charity of...
United States v. Halbert: Clarifying the Evidentiary Burden for Sentencing-Disparity Challenges on Appeal 1. Introduction United States v. Halbert, No. 24-6181 (10th Cir. July 21, 2025) concerns the...
United States v. Kay: Defining “Likely to Thwart” Under U.S.S.G. § 3C1.1 Note 1 Introduction The Tenth Circuit’s published decision in United States v. Kay, No. 24-4018 (10th Cir. July 21, 2025),...
The “Endless-Cycle” Doctrine Reaffirmed: United States v. Frederick and the Scope of § 3583 Revocation Authority Introduction In United States v. Frederick, No. 24-5099 (10th Cir. July 18, 2025), the...
Sullivan v. Graham: Tenth Circuit Clarifies District Courts’ Discretion over Page-Limits, Rule 8 Compliance, and Counsel Appointment for Pro Se Litigants Introduction The consolidated appeals in...
“Reasonable Brevity”: Sullivan v. Hartford Financial Services Group and the Tenth Circuit’s Re-affirmation of District Courts’ Discretion to Impose Page Limits and Dismiss Prolix Pro Se Pleadings 1....
Probable Cause Through Layered Suspicion: The “Vallejos Framework” for Warrantless Automobile Searches & Non-Custodial Traffic-Stop Questioning Introduction United States v. Vallejos, No. 24-2065...
“Firm Waiver” and Anticipatory Procedural Bar Reinforced: Commentary on Burnett v. Harding, Tenth Circuit (2025) Introduction In Burnett v. Harding, the United States Court of Appeals for the Tenth...
Churchill v. Clark: Clarifying Pro-Se Limits—Waiver by Deficient Briefing and Rule 41(b) Dismissals Introduction Case: Churchill v. Clark, No. 24-7065, United States Court of Appeals for the Tenth...
Tenth Circuit Affirms Broad Sentencing-Court Discretion on Acceptance-of-Responsibility and Extreme-Conduct Departures – United States v. Born Introduction On 11 July 2025 the United States Court of...
Loginov v. Sheridan Memorial Hospital: Tenth Circuit Affirms Broad Wyoming COVID-19 Health-Care Immunity and Reinforces Strict Rule 56(d) Affidavit Requirement Introduction In Loginov v. Sheridan...
“From Speculation to Substantial Evidence” The Tenth Circuit’s Clarification of the Personalized-Risk Standard for CAT Protection in Moundih v. Bondi 1. Introduction Case Name: Fonka Arouna Moundih...
Absolute Prosecutorial Immunity Now Encompasses the Initiation of Civil Enforcement Actions: Rodgers v. Torrez, 82 F.4th ___ (10th Cir. 2025) 1. Introduction Rodgers v. Torrez presented the U.S....
United States v. Bayless: Delineating the Outer Limits of Confrontation-Clause Impeachment and Rule 412 Exceptions Introduction United States v. Bayless (10th Cir. July 10, 2025) addresses a...
“Tracing by Spreadsheet”: United States v. Dermen and the Tenth Circuit’s Clarification of Summary-Witness Testimony, Forfeiture Standards, and Post-Apprendi Sentencing Proof 1. Introduction United...
Invited-Error Waiver Solidified: United States v. Maldonado and the Boundaries of Rule 33 Relief Introduction This commentary dissects the Tenth Circuit’s July 2025 decision in United States v....
“From Investigation to Adjudication” – 10th Circuit Holds Temporary-Custody Hearings Are Judicial Proceedings Conferring Absolute Testimonial Immunity on Caseworkers Commentary on Berryman v. Niceta,...