jmc

Notice how two of the points, $(4,-1)$ and $(4,5)$, lie on the same line parallel through the $y$-axis with $x$-intercept $(4,0)$. Let these points lie on the base of the triangle, so the base has length $5-(-1)=6$. The height is the perpendicular distance from $(10,3)$ to this line, which is $10-4=6$. The area is thus $\frac{1}{2}(6)(6)=\boxed{18}$.