Puerto Rico Case Commentaries

Fake-Identity Bank Account Holders Are Not “Customers” Under Shaw: Bank Fraud Proof and Deferred-Restitution Jurisdiction

Date: Jul 18, 2026

Fake-Identity Bank Account Holders Are Not “Customers” Under Shaw: Bank Fraud Proof and Deferred-Restitution Jurisdiction Case: United States v. Omoruyi (1st Cir. July 15, 2026) | Charges: 18 U.S.C....

Fake-Identity “Customers” and Deferred Restitution: Bank Fraud Property Interests Under § 1344(1) and MVRA Jurisdiction

Date: Jul 18, 2026

Fake-Identity “Customers” and Deferred Restitution: Bank Fraud Property Interests Under § 1344(1) and MVRA Jurisdiction I. Introduction In United States v. Omoruyi (1st Cir. July 15, 2026), the First...

FSIA Commercial-Activity Exception: Sovereign-Coerced Merger “Brokering” Is Not Commercial Activity

Date: Jul 18, 2026

FSIA Commercial-Activity Exception: Sovereign-Coerced Merger “Brokering” Is Not Commercial Activity 1. Introduction Creditincome Limited v. The Swiss Confederation (2d Cir. July 16, 2026) addresses...

Prospective Application of Florida’s Post–SB 450 Nonunanimous Death-Recommendation Scheme Is Procedural and Not Ex Post Facto

Date: Jul 18, 2026

Prospective Application of Florida’s Post–SB 450 Nonunanimous Death-Recommendation Scheme Is Procedural and Not Ex Post Facto I. Introduction In Patrick R. McDowell v. State of Florida (Fla. July 16,...

Wyoming TPR Rule: No “Reasonable Efforts” Prerequisite Under § 14-2-309(a)(v), and Unchallenged Independent Grounds Sustain Termination

Date: Jul 18, 2026

Wyoming TPR Rule: No “Reasonable Efforts” Prerequisite Under § 14-2-309(a)(v), and Unchallenged Independent Grounds Sustain Termination 1. Introduction In In the Matter of the Termination of Parental...

Withdrawing an EEO Complaint Does Not Negate Protected Activity, but Temporal Proximity Alone Will Not Prove Title VII Retaliation Absent Corroboration When the Employer Honestly Relies on Admitted Medication Errors

Date: Jul 18, 2026

Withdrawing an EEO Complaint Does Not Negate Protected Activity, but Temporal Proximity Alone Will Not Prove Title VII Retaliation Absent Corroboration When the Employer Honestly Relies on Admitted...

Pro Se Named Executor May Petition for Letters Testamentary Without Counsel; Lack of a Law License Is Not “Improvidence” or “Want of Understanding” (2026 Guam 5)

Date: Jul 18, 2026

Pro Se Named Executor May Petition for Letters Testamentary Without Counsel; Lack of a Law License Is Not “Improvidence” or “Want of Understanding” In the Matter of the Estate of Jose Aguon...

Delaware: No Article I, § 4 Jury-Trial Right in Delaware Securities Act IPU Administrative Enforcement; Due-Process Challenges Must Be Ripe or Truly Facial

Date: Jul 18, 2026

Delaware: No Article I, § 4 Jury-Trial Right in Delaware Securities Act IPU Administrative Enforcement; Due-Process Challenges Must Be Ripe or Truly Facial I. Introduction Case: Swan Energy, Inc.,...

Omission of an Essential Element Makes an Indictment Substantively Defective and Not Amendable Under Or Const, Art VII (Amended), § 5(6)

Date: Jul 18, 2026

Omission of an Essential Element Makes an Indictment Substantively Defective and Not Amendable Under Or Const, Art VII (Amended), § 5(6) 1. Introduction State v. Heward, 375 Or 449 (2026), required...

Unchallenged Adoption After Custody Transfer Moots CINA Proceedings Under AS 25.23.140(b)

Date: Jul 18, 2026

Unchallenged Adoption After Custody Transfer Moots CINA Proceedings Under AS 25.23.140(b) I. Introduction In Jonah B. v. State of Alaska, Department of Family & Community Services, Office of...

OPC v. Cox (2026 UT 17): Record-Based Notice Requirement for New Disciplinary Charges at the Screening Panel Stage

Date: Jul 18, 2026

Record-Based Notice Requirement for New Disciplinary Charges at the Screening Panel Stage (Reversal of Rule 1.1 Absent Proof of Timely Notice) Case: OPC v. Cox, 2026 UT 17 (Utah Supreme Court) Date:...

Workers’ Compensation IME Obstruction: Suspension Is the Exclusive Statutory Sanction (Dismissal Unavailable)

Date: Jul 18, 2026

Workers’ Compensation IME Obstruction: Suspension Is the Exclusive Statutory Sanction (Dismissal Unavailable) 1. Introduction In Hooker v. Labor Commission, 2026 UT 16, the Utah Supreme Court...

“Majority Vote” in CNMI Attorney-Discipline Elections Means Majority of Votes Cast (Not Majority of All Active Members)

Date: Jul 18, 2026

“Majority Vote” in CNMI Attorney-Discipline Elections Means Majority of Votes Cast (Not Majority of All Active Members) I. Introduction In re Myers, 2026 MP 6 (NMI Sup. Ct. July 15, 2026), resolves a...

White v. Bowling: Expert Causation Proof Required for Jail-Delay Death Claims Amid Intervening Hospital Care; Systemic Monell Liability Still Requires a Constitutional Violation

Date: Jul 18, 2026

White v. Bowling: Expert Causation Proof Required for Jail-Delay Death Claims Amid Intervening Hospital Care; Systemic Monell Liability Still Requires a Constitutional Violation Court: United States...

18 U.S.C. § 4042(d) Exempts Only Military or Naval Prisons: BOP Discipline Authority in Federal Institutions Affirmed

Date: Jul 18, 2026

18 U.S.C. § 4042(d) Exempts Only Military or Naval Prisons: BOP Discipline Authority in Federal Institutions Affirmed 1. Introduction Davis v. Baysore (10th Cir. July 16, 2026) addresses a recurring...

Certification on Whether Hotel Beach-Area Contractors Owe Puerto Rico’s Heightened Innkeeper Duty

Date: Jul 18, 2026

Certification on Whether Hotel Beach-Area Contractors Owe Puerto Rico’s Heightened Innkeeper Duty Case: Wilson v. Iguana Sport Services, Corp. (1st Cir. July 15, 2026) Court: United States Court of...

Ambiguous Sentencing Rationale Requires Remand for Clarification When “Association with Convicted Felons” Obstructs Appellate Review

Date: Jul 18, 2026

Ambiguous Sentencing Rationale Requires Remand for Clarification When “Association with Convicted Felons” Obstructs Appellate Review 1. Introduction United States v. Figueroa-Roman is a First Circuit...

Constructive Tying by Exorbitant Standalone Pricing Is Actionable Under Sherman Act § 2; Automatic Stay Does Not Freeze Debtor-Plaintiff Claims

Date: Jul 18, 2026

Constructive Tying by Exorbitant Standalone Pricing Is Actionable Under Sherman Act § 2; Automatic Stay Does Not Freeze Debtor-Plaintiff Claims 1. Introduction Cumulus Media New Holdings Inc. v. The...

Bergin v. N.Y. State Unified Court System — Abercrombie-Driven Prima Facie Test for Title VII Religious Accommodation Claims

Date: Jul 18, 2026

Abercrombie Abrogates the Second Circuit’s Prior Prima Facie Test for Title VII Religious-Accommodation Claims: “Actually Required Accommodation” + “Motivating-Factor Avoidance” 1. Introduction...

Contractual Fee-Shifting Remains Enforceable for Distinct Nonwage Employment Claims Despite 21 V.S.A. § 347

Date: Jul 18, 2026

Contractual Fee-Shifting Remains Enforceable for Distinct Nonwage Employment Claims Despite 21 V.S.A. § 347 Elizabeth Rossetti v. Bare, Ltd. and Jamie Spano, 2026 VT 28 (Vt. July 17, 2026) I....