The U.S. Court of Appeals for the Tenth Circuit denied both panel rehearing and en banc review in *Simpson v. Quick*, effectively finalizing a decision in a case involving inmate rights at the Oklahoma State Penitentiary. The court issued its order February 6, 2026, following an unsuccessful attempt by the plaintiff to secure additional review of the panel's decision.
The case involves Kendrick Simpson, an inmate who challenged actions by three Oklahoma Department of Corrections officials in their official capacities. The defendants include Christe Quick, warden of the Oklahoma State Penitentiary; Justin Farris, interim executive director of the Oklahoma Department of Corrections; and Gentner Drummond, Oklahoma's attorney general.
According to court documents, the Tenth Circuit initially issued its order and judgment in the matter on February 4, 2026. However, an active judge of the court subsequently called for a poll to consider en banc review of the panel decision. This procedural step allows the full court to reconsider a three-judge panel's ruling when deemed necessary.
Following the poll call, Simpson filed a petition requesting either panel rehearing or rehearing en banc. The petition was circulated to all judges eligible to participate in en banc proceedings. The defendants were offered an opportunity to respond to Simpson's petition but elected not to file a response.
The court's order reveals that Simpson's request for panel rehearing was denied. Additionally, a majority of judges in regular active service voted against en banc rehearing, causing the poll to fail. As a result, the court also denied Simpson's request for en banc review under Federal Rule of Appellate Procedure 40(c).
The case originated in the U.S. District Court for the Western District of Oklahoma, where it was assigned docket number 5:25-CV-01221-D. The district court case appears to have been filed in 2025 before being appealed to the Tenth Circuit, where it received appellate case number 26-6008.
The Tenth Circuit's decision was presided over by an unusually large panel of judges, including Chief Judge Holmes and Circuit Judges Hartz, Tymkovich, Matheson, Bacharach, Phillips, McHugh, Moritz, Eid, Carson, Rossman, and Federico. This extensive judicial participation reflects the court's consideration of the matter for potential en banc review.
While the specific claims in Simpson's lawsuit are not detailed in the available court documents, the case represents another instance of federal court oversight of state correctional facilities. Cases challenging prison conditions and administrative practices regularly come before federal courts under various constitutional provisions, including the Eighth Amendment's prohibition on cruel and unusual punishment and the Fourteenth Amendment's due process protections.
The involvement of high-ranking Oklahoma corrections officials as defendants suggests the case likely addressed systemic issues rather than isolated incidents. Quick's role as warden places her in direct charge of day-to-day operations at the state penitentiary, while Farris's position as interim executive director gives him oversight of the entire state corrections system. Drummond's inclusion as attorney general indicates the state's legal defense strategy involved the highest levels of Oklahoma's legal apparatus.
The court's decision to publish the order, as indicated by the "PUBLISH" designation on the document, means the ruling will have precedential value for future cases in the Tenth Circuit. Published decisions become part of the binding case law that lower courts must follow when addressing similar legal questions.
The denial of both panel rehearing and en banc review typically signals the end of appellate proceedings in the circuit court. Simpson's legal options would now be limited to filing a petition for writ of certiorari with the U.S. Supreme Court, though the high court accepts only a small percentage of such requests for review.
The Tenth Circuit's jurisdiction includes Oklahoma, Kansas, Colorado, Wyoming, Utah, and New Mexico, meaning its decisions affect federal law interpretation across this six-state region. Cases involving correctional practices often have implications beyond the immediate parties, potentially affecting how similar facilities operate throughout the circuit's jurisdiction.
The case reflects ongoing tensions between inmate advocacy for constitutional rights and state correctional systems' operational needs. Federal courts frequently serve as the forum for resolving these disputes when inmates allege constitutional violations that cannot be addressed through internal prison grievance procedures.
With the Tenth Circuit's final order now issued, the immediate legal challenge to the Oklahoma corrections officials' actions appears concluded at the appellate level, absent successful Supreme Court review.