Case Explained: In re ZACHARY RUSK Debtor. —————————— ZACHARY RUSK

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-08-11 The Tenth Circuit affirmed the Bankruptcy Appellate Panel’s decision upholding the bankruptcy court’s denial of Zachary Rusk’s motion to strike and grant of counsel’s motion to withdraw. The court determined that Rusk’s pro se opening brief was frivolous because it failed to advance any coherent argument demonstrating how the lower courts erred. While pro se filings are entitled to liberal construction, the court held it cannot formulate arguments or perform legal research on a litigant’s behalf when they fail to comply with Federal Rule of Appellate Procedure 28(a)(8)(A) by identifying contentions and citing authorities. Rusk’s brief consisted of incomprehensible statements, scattered references to unrelated legal doctrines (including the Supremacy Clause, Second Amendment, and various constitutional amendments), and unsubstantiated claims of criminal activity without explaining their relevance to the bankruptcy proceedings. Consequently, the court affirmed based on forfeiture and the failure to present non-frivolous arguments, while denying Rusk’s outstanding motions and requests for relief as moot. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.