10th Circuit Case Commentaries

Tenth Circuit: Minimal § 3553(a) Explanation Suffices to Deny a § 3582(c)(2) Reduction When Record and Context Supply a Reasoned Basis

Date: Mar 13, 2025

Tenth Circuit: Minimal § 3553(a) Explanation Suffices to Deny a § 3582(c)(2) Reduction When Record and Context Supply a Reasoned Basis I. Introduction United States v. Solis-Rodriguez (consolidated...

Minimal Explanation Required to Deny § 3582(c)(2) Relief When Record and Context Show § 3553(a) Consideration

Date: Mar 13, 2025

Minimal Explanation Required to Deny § 3582(c)(2) Relief When Record and Context Show § 3553(a) Consideration 1. Introduction In United States v. Solis-Rodriguez (consolidated with United States v....

Unobjected-to PSR Allegations as Sentencing Facts and “Heartland” Limits Confined to Guideline Departures

Date: Mar 13, 2025

Unobjected-to PSR Allegations as Sentencing Facts and “Heartland” Limits Confined to Guideline Departures 1. Introduction In United States v. Vazquez-Garcia (10th Cir. Mar. 12, 2025), the Tenth...

Reinstated Removal Orders Are Not Reopenable: § 1231(a)(5) as an Absolute Bar to BIA Review

Date: Mar 12, 2025

Reinstated Removal Orders Are Not Reopenable: § 1231(a)(5) as an Absolute Bar to BIA Review 1. Introduction In Dominguez-Gutierrez v. Garland (captioned in the order as Enrique Dominguez v. Pamela J....

Post-Expiration State Collateral Motions Do Not Toll AEDPA: COA Denied Absent Debatable Timeliness, Diligence, or New Actual-Innocence Evidence

Date: Mar 12, 2025

Post-Expiration State Collateral Motions Do Not Toll AEDPA: COA Denied Absent Debatable Timeliness, Diligence, or New Actual-Innocence Evidence 1. Introduction Case: Medina v. Hansen, No. 24-1353...

Unobjected PSR Facts and Reliable Hearsay Permit Major Upward Variances (Including to the Statutory Maximum) in § 922(g) Sentencing

Date: Mar 12, 2025

Unobjected PSR Facts and Reliable Hearsay Permit Major Upward Variances (Including to the Statutory Maximum) in § 922(g) Sentencing Case: United States v. Lucero (No. 23-2190) | Court: U.S. Court of...

Singh v. Bondi: “Unable-or-Unwilling” May Be Analyzed Holistically; Nonreporting Requires Proof Reporting Would Be Futile or Dangerous

Date: Mar 12, 2025

Singh v. Bondi: “Unable-or-Unwilling” May Be Analyzed Holistically; Nonreporting Requires Proof Reporting Would Be Futile or Dangerous I. Introduction In Singh v. Bondi (10th Cir. Mar. 11, 2025), the...

Procedural Sentencing Challenges Require Timely Objections; Corroborated Hearsay and Uncontested PSR Facts May Support § 2K2.1(b)(6) Enhancements and Major Upward Variances

Date: Mar 12, 2025

Procedural Sentencing Challenges Require Timely Objections; Corroborated Hearsay and Uncontested PSR Facts May Support § 2K2.1(b)(6) Enhancements and Major Upward Variances I. Introduction In United...

Late-Filed State Postconviction Motions Do Not Toll AEDPA: COA Denied Where Time-Bar Is Plain

Date: Mar 12, 2025

Late-Filed State Postconviction Motions Do Not Toll AEDPA: COA Denied Where Time-Bar Is Plain 1. Introduction In Medina v. Hansen (10th Cir. Mar. 11, 2025), the Tenth Circuit denied Delano Medina—a...

Reinstatement Under 8 U.S.C. § 1231(a)(5) Forecloses BIA Reopening and Reinforces Strict Time-and-Number Limits on Motions to Reopen

Date: Mar 12, 2025

Reinstatement Under 8 U.S.C. § 1231(a)(5) Forecloses BIA Reopening and Reinforces Strict Time-and-Number Limits on Motions to Reopen I. Introduction In Dominguez-Gutierrez v. Garland (captioned in...

Singh v. Bondi: The Tenth Circuit Reaffirms a Unified “Unable-or-Unwilling” Analysis and the Centrality of Reporting (or Proving Futility/Danger) in Private-Persecution Asylum Claims

Date: Mar 12, 2025

Singh v. Bondi: The Tenth Circuit Reaffirms a Unified “Unable-or-Unwilling” Analysis and the Centrality of Reporting (or Proving Futility/Danger) in Private-Persecution Asylum Claims 1. Introduction...

Qualified Immunity and Clearly Established Law in Fourth Amendment Cases: A Tenth Circuit Ruling

Date: Mar 11, 2025

Qualified Immunity and Clearly Established Law in Fourth Amendment Cases: A Tenth Circuit Ruling Introduction The case of Thomas E. Nidiffer; Laurie-Lynn Francese, Plaintiffs – Appellants, v. David...

Standing Traceability Is Plausibly Alleged When an Operating-Agreement Amendment Replaces Fair-Market-Value Redemption with Board-Set Book Value

Date: Mar 11, 2025

Standing Traceability Is Plausibly Alleged When an Operating-Agreement Amendment Replaces Fair-Market-Value Redemption with Board-Set Book Value Introduction Whale Family Investments, LP and Ranslem...

United States v. Gulley: Unlawful Post-Expiration Supervision Cannot Supply “Reasonably Necessary” Delay Under § 3583(i), a Jurisdictional Limit

Date: Mar 11, 2025

United States v. Gulley: Unlawful Post-Expiration Supervision Cannot Supply “Reasonably Necessary” Delay Under § 3583(i), a Jurisdictional Limit 1. Introduction In United States v. Gulley (10th Cir....

Government Threats of Frivolous Civil Litigation as Clearly Established First Amendment Retaliation

Date: Mar 11, 2025

Government Threats of Frivolous Civil Litigation as Clearly Established First Amendment Retaliation I. Introduction Tachias v. Sanders (10th Cir. Mar. 10, 2025) arises from a conflict between...

Municipal Employment Contracts: Post-Execution Board Knowledge Cannot Create Apparent Authority, and Nonratified Mayor-Signed Contracts Create No Due Process Property Interest

Date: Mar 11, 2025

Municipal Employment Contracts: Post-Execution Board Knowledge Cannot Create Apparent Authority, and Nonratified Mayor-Signed Contracts Create No Due Process Property Interest Case: Gresham v. Town...

Anders Dismissal Where Reserved Claims (IAC/Prosecutorial Misconduct) Lack Record Support and Are Not Properly Developed on Direct Appeal

Date: Mar 11, 2025

Anders Dismissal Where Reserved Claims (IAC/Prosecutorial Misconduct) Lack Record Support and Are Not Properly Developed on Direct Appeal Introduction In United States v. Quinn (10th Cir. Mar. 10,...

Post-Execution Knowledge Cannot Create a Mayor’s Apparent Authority to Bind an Oklahoma Statutory Town

Date: Mar 11, 2025

Post-Execution Knowledge Cannot Create a Mayor’s Apparent Authority to Bind an Oklahoma Statutory Town Case: Gresham v. Town of Depew, Oklahoma (No. 24-5021) Court: United States Court of Appeals for...

18 U.S.C. § 3583(i) Is Jurisdictional: Post-Expiration Revocation Fails When Delay Is Justified by an Unlawful Extension of Supervision

Date: Mar 11, 2025

18 U.S.C. § 3583(i) Is Jurisdictional: Post-Expiration Revocation Fails When Delay Is Justified by an Unlawful Extension of Supervision 1. Introduction United States v. Gulley (10th Cir. Mar. 10,...

Consent-to-Extraction Extends to Seizure: A Surgically Removed Bullet May Be Used as Evidence When the Patient Requested Aid and Disclaimed Any Interest

Date: Mar 11, 2025

Consent-to-Extraction Extends to Seizure: A Surgically Removed Bullet May Be Used as Evidence When the Patient Requested Aid and Disclaimed Any Interest I. Introduction Case: United States v. Gaye...