10th Cir.

Michael Villecco v. Darcy Renee Kennedy

March 10, 2026 ·1:25-CV-00238-DDD-STV ·Panel Decision · By Maria Santos

The United States Court of Appeals for the Tenth Circuit dismissed an appeal filed by Michael Villecco as procedurally improper. The court held that the matter was not a separately appealable order and should have been raised in the underlying appeal.

Background

Michael Villecco sought to appeal a district court order from March the fourth, two thousand and twenty-six, which overruled his objections to a magistrate judge order. That magistrate judge order had denied his motion to add documents to the record in a separate appeal, number twenty-five, one thousand four hundred thirty-seven.

The court’s reasoning

The court acted sua sponte and determined that the appeal was procedurally improper. The court found that the order Villecco sought to appeal was not a separately appealable order. The court directed that any request for relief related to the record in the underlying appeal should have been raised in that appeal, citing Federal Rule of Appellate Procedure ten, subsection e.

What it means going forward

The dismissal reinforces that parties must raise all record-related objections within the specific appeal where the record is being contested, rather than filing a separate appeal for such procedural matters.