Puerto Rico Case Commentaries

United States v. Castro — Forfeited Rule 33 Timeliness Preserves FRAP 4(b)(3) Tolling; Separate Notice Required for Post‑Judgment Orders

Date: Jul 13, 2026

Forfeited Rule 33 Timeliness Preserves FRAP 4(b)(3) Tolling; Separate Notice Required for Post‑Judgment Orders Introduction United States v. Castro (5th Cir. July 10, 2026) arises from the...

PLRA Exhaustion Applies to Post-Release Supervision Revocation Detainees Housed in County Jail; MDOC ARP Required

Date: Jul 13, 2026

PLRA Exhaustion Applies to Post-Release Supervision Revocation Detainees Housed in County Jail; MDOC ARP Required Introduction In Villarreal v. VitalCore (5th Cir. July 9, 2026) (unpublished), the...

Harmless-Error Affirmance in Supervised-Release Revocations When Uncontested Violations Independently Support Revocation

Date: Jul 13, 2026

Harmless-Error Affirmance in Supervised-Release Revocations When Uncontested Violations Independently Support Revocation Introduction In United States v. Goodwill (5th Cir. July 8, 2026) (per curiam)...

§ 1623(a) Expressly Preempts State Residence-Based In-State Tuition for Unlawfully Present Aliens; Futility Screening Applies to Defense-Side Intervenors

Date: Jul 13, 2026

§ 1623(a) Expressly Preempts State Residence-Based In-State Tuition for Unlawfully Present Aliens; Futility Screening Applies to Defense-Side Intervenors Introduction In United States v. State of...

Fifth Circuit: No Duty to Mitigate Title VII Emotional-Distress Compensatory Damages

Date: Jul 13, 2026

Fifth Circuit: No Duty to Mitigate Title VII Emotional-Distress Compensatory Damages I. Introduction In EEOC v. SkyWest Airlines (5th Cir. July 9, 2026), the Equal Employment Opportunity Commission...

Forfeitable Rule 33 Timeliness Triggers FRAP 4(b)(3) Tolling; Post-Judgment Orders Require a Separate Notice of Appeal

Date: Jul 13, 2026

Forfeitable Rule 33 Timeliness Triggers FRAP 4(b)(3) Tolling; Post-Judgment Orders Require a Separate Notice of Appeal Case: United States v. Castro (5th Cir. July 10, 2026) (per curiam, unpublished)...

Coram Nobis Requires Prompt Action and Cumulative Brady Materiality—Even When the District Court Analyzes Evidence Piecemeal

Date: Jul 13, 2026

Coram Nobis Requires Prompt Action and Cumulative Brady Materiality—Even When the District Court Analyzes Evidence Piecemeal Case: United States v. Jonathan Giannone (4th Cir. July 9, 2026)...

United States v. Carson: Timing Controls Rodriguez—Once Marijuana Odor Establishes Probable Cause, Later “Detours” Do Not Unlawfully Prolong the Stop; Sakyi Continues to Permit Drug-Based Frisks

Date: Jul 13, 2026

United States v. Carson: Timing Controls Rodriguez—Once Marijuana Odor Establishes Probable Cause, Later “Detours” Do Not Unlawfully Prolong the Stop; Sakyi Continues to Permit Drug-Based Frisks I....

Virginia Embezzlement Is Not Categorically a “Fraud or Deceit” Aggravated Felony Under INA § 1101(a)(43)(M)(i)

Date: Jul 13, 2026

Virginia Embezzlement Is Not Categorically a “Fraud or Deceit” Aggravated Felony Under INA § 1101(a)(43)(M)(i) Case: Maximino Ramos v. Todd Blanche Court: United States Court of Appeals for the...

Policy Violations Alone Do Not Establish Eighth Amendment Deliberate Indifference Absent Proof of Subjective Awareness of a Substantial Risk

Date: Jul 13, 2026

Policy Violations Alone Do Not Establish Eighth Amendment Deliberate Indifference Absent Proof of Subjective Awareness of a Substantial Risk Introduction In Randle Jackson v. Gerald Bush (4th Cir....

Fourth Circuit: Nonparty Attorney May Immediately Appeal a Separate Civil-Contempt Sanction, and Civil Contempt Requires Clear Proof of Harm (Not Punishment)

Date: Jul 13, 2026

Fourth Circuit: Nonparty Attorney May Immediately Appeal a Separate Civil-Contempt Sanction, and Civil Contempt Requires Clear Proof of Harm (Not Punishment) I. Introduction In Dmarcian, Inc. v....

Abitron Conduct Test in the Fourth Circuit: Targeting U.S. Customers via a Trademark-Misusing Website Triggers Domestic “Use in Commerce,” and Sanctions Tied to Foreign-Court Corrections Await Final Judgment Review

Date: Jul 13, 2026

Abitron Conduct Test in the Fourth Circuit: Targeting U.S. Customers via a Trademark-Misusing Website Triggers Domestic “Use in Commerce,” and Sanctions Tied to Foreign-Court Corrections Await Final...

Tenth Circuit Endorses Sua Sponte Reopening of a Closed BLBA Record When Needed to Decide Total Disability, Absent Unfairness or Prejudice

Date: Jul 13, 2026

Tenth Circuit Endorses Sua Sponte Reopening of a Closed BLBA Record When Needed to Decide Total Disability, Absent Unfairness or Prejudice I. Introduction Case: Energy West Mining Company v. OWCPC...

WPA Constructive-Discharge Accrual: Dissents Urge Returning to Jacobson’s Resignation-Date Rule (and Treating Joliet as Dicta for WPA Claims)

Date: Jul 13, 2026

WPA Constructive-Discharge Accrual: Dissents Urge Returning to Jacobson’s Resignation-Date Rule (and Treating Joliet as Dicta for WPA Claims) I. Introduction Case: Christina Zink v Genesee...

Mandamus to Compel Legislative Presentment Under Const 1963, art 4, § 33—Court of Appeals Rule Left Intact After Supreme Court Denial of Leave

Date: Jul 13, 2026

Mandamus to Compel Legislative Presentment Under Const 1963, art 4, § 33—Court of Appeals Rule Left Intact After Supreme Court Denial of Leave I. Introduction Senate v. House of Representatives...

Former Employees Not Bound by Post-Employment Union MOA Arbitration of Accrued Statutory Wage Claims Absent Consent

Date: Jul 13, 2026

Second Circuit: A Union Cannot Retroactively Bind Former Bargaining-Unit Members to Mandatory Arbitration of Accrued Statutory Wage Claims by a Later MOA Without Consent; Courts Decide Arbitrability...

Morse v. State (2026 S.D. 45) Commentary

Date: Jul 13, 2026

Inverse Condemnation in South Dakota Requires Government Action that Takes or Damages Private Property for a Public Use—State Mining on State-Owned Land and Mere Mineral-Rights Retention Do Not...

Florida Rejects “More Stringent” Abuse-of-Discretion Review for Fraud-on-the-Court Dismissals; Adopts Traditional Layered Appellate Review

Date: Jul 13, 2026

Florida Rejects “More Stringent” Abuse-of-Discretion Review for Fraud-on-the-Court Dismissals; Adopts Traditional Layered Appellate Review I. Introduction In Publix Supermarkets, Inc. v. Jonida Goga...

Florida: Discretionary Prejudgment Interest as an Equitable-Distribution Remedy Under § 61.075

Date: Jul 13, 2026

Florida: Discretionary Prejudgment Interest as an Equitable-Distribution Remedy Under § 61.075 I. Introduction In Scott Aron Stewart v. Mishelle Addys Perdomo Vindel (Fla. July 9, 2026), the Supreme...

Wrongful-Conviction Compensation Requires Actual Innocence of the Entire Alternative-Means Crime (Not Merely the Charged Means)

Date: Jul 13, 2026

Wrongful-Conviction Compensation Requires Actual Innocence of the Entire Alternative-Means Crime (Not Merely the Charged Means) Case: In re Wrongful Conviction of Arita (Kan. 2026-07-10) Court:...