Puerto Rico Case Commentaries

Totality-of-the-Circumstances Nexus in Search-Warrant Affidavits: Common-Sense Inferences and Presumed Reliability of Law-Enforcement Sources

Date: Jul 15, 2026

Totality-of-the-Circumstances Nexus in Search-Warrant Affidavits: Common-Sense Inferences and Presumed Reliability of Law-Enforcement Sources Introduction In Christopher Allen Campbell v. The State...

State v. Morgan: Courts Must Decide Reasonable Suspicion Before Applying the New-Crime/Attenuation Exception

Date: Jul 15, 2026

State v. Morgan: Courts Must Decide Reasonable Suspicion Before Applying the New-Crime/Attenuation Exception 1. Introduction In State v. Morgan (N.M. July 13, 2026), the Supreme Court of New Mexico...

LMRA § 301 Complete Preemption of State Tort Claims That Require CBA Interpretation (Including “Publication” for Defamation and “Outrageousness” for IIED)

Date: Jul 15, 2026

LMRA § 301 Complete Preemption of State Tort Claims That Require CBA Interpretation (Including “Publication” for Defamation and “Outrageousness” for IIED) 1. Introduction Case: Pete Szmurlo v. TK...

Rule 3(c)(4) “Merger” and Local-Rule Admissions: Interlocutory Orders Reviewable on Appeal and Unrebutted Facts Supporting Summary Judgment in an ADA Termination Case

Date: Jul 15, 2026

Rule 3(c)(4) “Merger” and Local-Rule Admissions: Interlocutory Orders Reviewable on Appeal and Unrebutted Facts Supporting Summary Judgment in an ADA Termination Case 1. Introduction In Jacqualine...

ADEA Claims Challenging Federal Contract “Suitability” Decisions Require Age-Causation Evidence; Undisclosed Comparators and Non-Decisionmaker Remarks (Even with Alleged Cat’s Paw) Are Insufficient Where an Independent Review Breaks the Chain

Date: Jul 15, 2026

ADEA Claims Challenging Federal Contract “Suitability” Decisions Require Age-Causation Evidence; Undisclosed Comparators and Non-Decisionmaker Remarks (Even with Alleged Cat’s Paw) Are Insufficient...

Estates with Multiple Beneficiaries Must Appear Through Counsel in Federal Court; Persistent Failure to Retain Counsel Warrants Rule 41(b) Dismissal With Prejudice (and a Belated Rule 54(b) Judgment Ripens a Premature Appeal)

Date: Jul 15, 2026

Estates with Multiple Beneficiaries Must Appear Through Counsel in Federal Court; Persistent Failure to Retain Counsel Warrants Rule 41(b) Dismissal With Prejudice (and a Belated Rule 54(b) Judgment...

Plain-Error Relief Denied for Alleged Hearing-Access Defect in Civil Commitment Absent Objection and Where Record Shows Participation (Matter of L.S.)

Date: Jul 15, 2026

Plain-Error Relief Denied for Alleged Hearing-Access Defect in Civil Commitment Absent Objection and Where Record Shows Participation (Matter of L.S.) 1. Introduction In Matter of L.S., 2026 MT 154N...

Enforcing a Final Marital Property Settlement Agreement: Limits on Post-Decree Relitigation and Procedural Leniency for Pro Se Appeals

Date: Jul 15, 2026

Enforcing a Final Marital Property Settlement Agreement: Limits on Post-Decree Relitigation and Procedural Leniency for Pro Se Appeals Introduction Marriage of McLaughlin (Mont. Sup. Ct. 2026 MT...

U‑Visa Waiting‑List Relief Is Disjunctive: USCIS May Grant Deferred Action or Parole (Not Both), and Overseas Parole‑Process Claims Become Moot Once Conditional Parole Is Provided

Date: Jul 15, 2026

U‑Visa Waiting‑List Relief Is Disjunctive: USCIS May Grant Deferred Action or Parole (Not Both), and Overseas Parole‑Process Claims Become Moot Once Conditional Parole Is Provided 1. Introduction...

Preservation Rule: No Appellate Review of Search-Warrant Probable Cause Absent a Pretrial Suppression Motion (Delaware Supreme Court Rule 26(c))

Date: Jul 15, 2026

Preservation Rule: No Appellate Review of Search-Warrant Probable Cause Absent a Pretrial Suppression Motion (Delaware Supreme Court Rule 26(c)) 1. Introduction Tucker v. State (Del. July 10, 2026)...

Eleventh Circuit Reaffirms Sentencing Commission Authority to Treat State Drug Felonies as “Controlled Substance Offenses” for Career-Offender Status

Date: Jul 15, 2026

Eleventh Circuit Reaffirms Sentencing Commission Authority to Treat State Drug Felonies as “Controlled Substance Offenses” for Career-Offender Status Introduction In United States v. Yaphet Martin...

Duress Requires a Continuous, Immediate Threat and No Realistic Chance to Seek Help: Proffer Insufficiency Bars Both Defense and Instruction

Date: Jul 15, 2026

Duress Requires a Continuous, Immediate Threat and No Realistic Chance to Seek Help: Proffer Insufficiency Bars Both Defense and Instruction Case: United States v. Joseph Ricard (with co-appellants...

Writ Quashed with Horsley Disclaimer: No Implied Endorsement of Lower-Court Reasoning in an Abandonment-Based TPR Appeal

Date: Jul 15, 2026

Writ Quashed with Horsley Disclaimer: No Implied Endorsement of Lower-Court Reasoning in an Abandonment-Based TPR Appeal 1. Introduction In Ex parte M.P. (Ala. July 10, 2026), the Supreme Court of...

Plea-Hearing “Not My Co‑Conspirator” Denials Are Not Statements Against Penal Interest; Prior Drug Sales Prove Intent in Specific-Intent Drug Cases

Date: Jul 14, 2026

Plea-Hearing “Not My Co‑Conspirator” Denials Are Not Statements Against Penal Interest; Prior Drug Sales Prove Intent in Specific-Intent Drug Cases Introduction In United States v. Gary Cunningham,...

State v. Mendez: Totality-of-Statements Review for Juror Actual Bias and Reaffirmation of Fuson’s Presumed Prejudice Rule

Date: Jul 14, 2026

State v. Mendez: Totality-of-Statements Review for Juror Actual Bias and Reaffirmation of Fuson’s Presumed Prejudice Rule 1. Introduction In State v. Mendez (N.M. July 13, 2026), the Supreme Court of...

State v. Woody: Two-Step Standard for State Continuances Based on Witness Unavailability; Rejection of the Lee Test

Date: Jul 14, 2026

State v. Woody: A Two-Step Standard for State Continuances Based on Witness Unavailability (HRPP Rule 48 Due Diligence First; Common-Law Good Cause Totality Second) and Rejection of the “Lee Test”...

Contract Duration at the Pleading Stage: “In Effect” Covenants Survive Patent Expiration Unless Expiration Is Compelled as a Matter of Law

Date: Jul 14, 2026

Contract Duration at the Pleading Stage: “In Effect” Covenants Survive Patent Expiration Unless Expiration Is Compelled as a Matter of Law Case: Teva Pharmaceuticals USA, Inc. v. Eli Lilly and...

State v. Morgan: Reasonable Suspicion First—No “New Crime Exception” Analysis Without an Unconstitutional Seizure

Date: Jul 14, 2026

State v. Morgan (N.M. 2026): Courts Must Decide Reasonable Suspicion Before Reaching the “New Crime Exception,” and Officer Identification Does Not Negate Reasonable Suspicion I. Introduction In...

Koehler v. Infosys: Rule 702 Requires Proven Reliability for Name-Matching Demographic Proof, and Courts May Exclude It Sua Sponte

Date: Jul 14, 2026

Koehler v. Infosys: Rule 702 Requires Proven Reliability for Name-Matching Demographic Proof, and Courts May Exclude It Sua Sponte 1. Introduction In Brenda Koehler v. Infosys Technologies Limited,...

State v. Polizzi (2026-Ohio-2588) Commentary

Date: Jul 13, 2026

Consecutive-Sentencing Proportionality and Appellate Review: No Aggregate-Term Requirement Under R.C. 2929.14(C)(4) and R.C. 2953.08(G)(2) I. Introduction State v. Polizzi, Slip Opinion No....