10th Circuit Case Commentaries

Streamlined Consideration of §3553(a) Factors in Sentence Reduction Motions

Date: Mar 15, 2025

Streamlined Consideration of §3553(a) Factors in Sentence Reduction Motions Introduction The case United States of America v. Pedro Solis-Rodriguez and United States of America v. Richard Wilborn...

Reaffirming Judicial Discretion in Sentencing: Uncontested PSR Allegations and Upward Variances Based on Criminal History

Date: Mar 15, 2025

Reaffirming Judicial Discretion in Sentencing: Uncontested PSR Allegations and Upward Variances Based on Criminal History Introduction The case of UNITED STATES OF AMERICA v. ISMAEL VAZQUEZ-GARCIA...

Clarifying the "Unable-or-Unwilling" Standard for Private Persecution in Asylum Claims

Date: Mar 14, 2025

Clarifying the "Unable-or-Unwilling" Standard for Private Persecution in Asylum Claims Introduction The judgment in Amarjeet Singh v. Pamela J. Bondi, United States Attorney General represents an...

Numerical Bar and Administrative Finality: Reaffirming Restrictions on Reopened Removal Proceedings

Date: Mar 14, 2025

Numerical Bar and Administrative Finality: Reaffirming Restrictions on Reopened Removal Proceedings Introduction The case of Enrique Dominguez v. Pamela J. Bondi, United States Attorney General,...

Clarifying the Tolling of AEDPA Limitations: The Inapplicability of Late-Filed State Relief Motions

Date: Mar 14, 2025

Clarifying the Tolling of AEDPA Limitations: The Inapplicability of Late-Filed State Relief Motions Introduction This commentary examines the recent decision in the case of Delano Medina, a/k/a...

Enhanced Judicial Discretion: Recognizing Individualized Assessment in Sentencing Variances

Date: Mar 14, 2025

Enhanced Judicial Discretion: Recognizing Individualized Assessment in Sentencing Variances Introduction This commentary analyzes the United States Court of Appeals, Tenth Circuit’s decision in...

Manuel-Ramirez v. Garland — Sua Sponte Enforcement of § 1252(d)(1) Issue Exhaustion in Cancellation Hardship Appeals

Date: Mar 14, 2025

Sua Sponte Enforcement of § 1252(d)(1) Issue Exhaustion in Cancellation Hardship Appeals 1. Introduction In Manuel-Ramirez v. Garland (10th Cir. Mar. 13, 2025), the Tenth Circuit denied a petition...

South Dakota “Concerted Misconduct” Equitable Estoppel: Nonsignatories May Compel Arbitration Without Pleading Conspiracy

Date: Mar 14, 2025

South Dakota “Concerted Misconduct” Equitable Estoppel: Nonsignatories May Compel Arbitration Without Pleading Conspiracy I. Introduction Munoz v. Conduent State & Local Solutions (10th Cir. Mar. 13,...

Manuel-Ramirez v. Garland: The Tenth Circuit Will Sua Sponte Enforce Issue Exhaustion in Cancellation Hardship Appeals Despite Government Forfeiture

Date: Mar 14, 2025

Manuel-Ramirez v. Garland: The Tenth Circuit Will Sua Sponte Enforce Issue Exhaustion in Cancellation Hardship Appeals Despite Government Forfeiture I. Introduction In Manuel-Ramirez v. Garland (10th...

South Dakota Arbitration Estoppel: No Conspiracy Pleading Required to Compel Arbitration by Nonsignatories for “Interdependent and Concerted Misconduct”

Date: Mar 14, 2025

South Dakota Arbitration Estoppel: No Conspiracy Pleading Required to Compel Arbitration by Nonsignatories for “Interdependent and Concerted Misconduct” 1. Introduction Munoz v. Conduent State &...

Clarifying Appellate Jurisdiction: Attorney Misconduct Orders in Non-Final Decisions

Date: Mar 13, 2025

Clarifying Appellate Jurisdiction: Attorney Misconduct Orders in Non-Final Decisions Introduction This commentary examines a recent decision by the United States Court of Appeals for the Tenth...

Establishing Standing Through Causal Connection: The 2022 Operating Agreement Amendment and Investor Redress

Date: Mar 13, 2025

Establishing Standing Through Causal Connection: The 2022 Operating Agreement Amendment and Investor Redress Introduction This commentary examines the recent decision of the United States Court of...

Clarifying Fourth Amendment Protections: Particularity in Warrants and the Consent-Based Seizure of Bodily Evidence

Date: Mar 13, 2025

Clarifying Fourth Amendment Protections: Particularity in Warrants and the Consent-Based Seizure of Bodily Evidence Introduction The case of United States of America v. Joseph Gaye presents a complex...

Affirming Investigatory Stops and Limited Frisks under the Fourth Amendment: A Tenth Circuit Analysis

Date: Mar 13, 2025

Affirming Investigatory Stops and Limited Frisks under the Fourth Amendment: A Tenth Circuit Analysis Introduction The judgment in United States of America v. Adam Douglas Sherwood, decided by the...

Establishing the Threshold for Frivolous Appeals: Dismissal of Ineffective Counsel and Misconduct Claims

Date: Mar 13, 2025

Establishing the Threshold for Frivolous Appeals: Dismissal of Ineffective Counsel and Misconduct Claims Introduction The United States Court of Appeals for the Tenth Circuit rendered a decision on...

Jurisdictional Limits on Post-Expiration Revocation: The "Reasonably Necessary" Standard under 18 U.S.C. § 3583(i)

Date: Mar 13, 2025

Jurisdictional Limits on Post-Expiration Revocation: The "Reasonably Necessary" Standard under 18 U.S.C. § 3583(i) Introduction This commentary examines the decision in UNITED STATES OF AMERICA v....

Threatening Frivolous Litigation as Governmental Retaliation: A New Precedent in First Amendment Protection

Date: Mar 13, 2025

Threatening Frivolous Litigation as Governmental Retaliation: A New Precedent in First Amendment Protection Introduction The case of Rowena Tachias and Monique Dereta v. Dana Sanders and the Los...

New Precedent on Apparent Authority and Contract Ratification in Municipal Employment: Town of Depew v. Gresham

Date: Mar 13, 2025

New Precedent on Apparent Authority and Contract Ratification in Municipal Employment: Town of Depew v. Gresham I. Introduction The case of Kevin Gresham v. Town of Depew, Oklahoma addresses complex...

Unobjected-to PSR Allegations May Be Adopted as Facts and Support an Upward Variance Under § 3553(a)

Date: Mar 13, 2025

Unobjected-to PSR Allegations May Be Adopted as Facts and Support an Upward Variance Under § 3553(a) I. Introduction In United States v. Vazquez-Garcia (10th Cir. Mar. 12, 2025), the Tenth Circuit...

Four-Factor Rule: Minimal § 3553(a) Explanation Suffices When Denying § 3582(c)(2) Relief Within the Amended Guideline Range

Date: Mar 13, 2025

Four-Factor Rule: Minimal § 3553(a) Explanation Suffices When Denying § 3582(c)(2) Relief Within the Amended Guideline Range Introduction In United States of America v. PEDRO SOLIS-RODRIGUEZ and...