Puerto Rico Case Commentaries

Anders Withdrawal Granted Where Rule 11 Plea Colloquy and Within-Guidelines Sentence Reveal No Nonfrivolous Appellate Issues

Date: Jul 9, 2026

Anders Withdrawal Granted Where Rule 11 Plea Colloquy and Within-Guidelines Sentence Reveal No Nonfrivolous Appellate Issues 1. Introduction In United States v. Luis Gomez (3d Cir. July 6, 2026)...

Within-Guidelines Sentences Presumptively Satisfy § 3553(a)(6): Disparity Claims Require Comparator Evidence

Date: Jul 9, 2026

Within-Guidelines Sentences Presumptively Satisfy § 3553(a)(6): Disparity Claims Require Comparator Evidence Introduction In United States v. Pantoja-Hernandez, consolidated appeals involving the...

Admissions + No Objection = Plain-Error Review and Anders Dismissal in Supervised-Release Revocation Appeals

Date: Jul 9, 2026

Admissions + No Objection = Plain-Error Review and Anders Dismissal in Supervised-Release Revocation Appeals I. Introduction In United States v. Underwood (10th Cir. July 7, 2026), the Tenth Circuit...

Nondefective Equipment Placement Is Not a “Physical Defect” Under R.C. 2744.02(B)(4)

Date: Jul 9, 2026

Nondefective Equipment Placement Is Not a “Physical Defect” Under R.C. 2744.02(B)(4) 1. Introduction Steigerwald v. Berea, 2026-Ohio-2554 presented a recurring governmental-immunity question: when a...

Nonprecedential Case Announcements: Sua Sponte Dismissal and Procedural Disposition of Habeas, Tax, and Appellate Motions (Supreme Court of Ohio, July 7, 2026)

Date: Jul 9, 2026

Nonprecedential Case Announcements: Sua Sponte Dismissal and Procedural Disposition of Habeas, Tax, and Appellate Motions (Supreme Court of Ohio, July 7, 2026) 1. Introduction The Supreme Court of...

Federal Law Governs Prejudgment Interest on Fee Awards in Mixed Federal–State Settlements, and Trial Courts Must Explain the Math Behind Across-the-Board Hour Cuts

Date: Jul 9, 2026

Federal Law Governs Prejudgment Interest on Fee Awards in Mixed Federal–State Settlements, and Trial Courts Must Explain the Math Behind Across-the-Board Hour Cuts Case: Morgan Pianko v. General R.V....

Probable Cause to Search a Vehicle When a Gun Was Last Seen Inside During an Apparent Assault, Even After the Suspect Flees

Date: Jul 9, 2026

Probable Cause to Search a Vehicle When a Gun Was Last Seen Inside During an Apparent Assault, Even After the Suspect Flees I. Introduction In United States v. Jaeontae Moore (6th Cir. July 7, 2026)...

State “Non-Interference” Protections for 340B Contract Pharmacies Are Not Preempted and Survive Takings, Contracts Clause, and Vagueness Challenges

Date: Jul 9, 2026

State “Non-Interference” Protections for 340B Contract Pharmacies Are Not Preempted and Survive Takings, Contracts Clause, and Vagueness Challenges I. Introduction In Pharm Research and Mfr v....

Third Circuit: CAT Deferral Requires Individualized Proof of Likely Torture—Arrest and “Ill-Treatment” Evidence Alone Is Insufficient

Date: Jul 9, 2026

Third Circuit: CAT Deferral Requires Individualized Proof of Likely Torture—Arrest and “Ill-Treatment” Evidence Alone Is Insufficient I. Introduction In Javokhir Attoev v. Attorney General United...

Eliminated-Position Discrimination Claims: “Replacement” Alone Does Not Create an Inference, and Retaliation Requires More Than Timing at Pretext

Date: Jul 9, 2026

Eliminated-Position Discrimination Claims: “Replacement” Alone Does Not Create an Inference, and Retaliation Requires More Than Timing at Pretext 1. Introduction In Robert Lynn v. Bank of New York...

Evidentiary Hearing on Suppression Requires a Concrete Factual Dispute—Failure to Contest Marijuana-Odor Probable Cause Defeats the Request

Date: Jul 9, 2026

Evidentiary Hearing on Suppression Requires a Concrete Factual Dispute—Failure to Contest Marijuana-Odor Probable Cause Defeats the Request Case: United States v. Clarence Gaffney (3d Cir. July 6,...

NGA Field Preemption of State Consumer-Protection Claims Directly Targeting Interstate Wholesale Natural-Gas Sales Despite Retail Pass-Through Effects

Date: Jul 9, 2026

NGA Field Preemption of State Consumer-Protection Claims Directly Targeting Interstate Wholesale Natural-Gas Sales Despite Retail Pass-Through Effects Case: Deutscher v. Tenaska Marketing Ventures...

Natural Gas Act Field Preemption Bars State Consumer-Protection Claims Directly Targeting Interstate Wholesale Gas Sales

Date: Jul 9, 2026

Natural Gas Act Field Preemption Bars State Consumer-Protection Claims Directly Targeting Interstate Wholesale Gas Sales Case: Stoneberger v. BP Energy Company (consolidated in In re: WINTER STORM...

Within-Guidelines Sentences and § 3553(a)(6): Disparity Claims Require Comparator Evidence; Courts Do Not Err by Ignoring Facts Not Presented

Date: Jul 9, 2026

Within-Guidelines Sentences and § 3553(a)(6): Disparity Claims Require Comparator Evidence; Courts Do Not Err by Ignoring Facts Not Presented 1. Introduction In United States v. Pantoja-Campos...

Lakey v. Bryant: Supervisory Qualified Immunity for Mutual-Aid Policies and the Requirement of a Pattern (Not Post-Incident Ratification Alone) to Prove an Informal Custom

Date: Jul 9, 2026

Lakey v. Bryant: Supervisory Qualified Immunity for Mutual-Aid Policies and the Requirement of a Pattern (Not Post-Incident Ratification Alone) to Prove an Informal Custom I. Introduction Lakey v....

No Fourth Amendment Privacy in Freenet Opennet Block Requests Logged by “Freenet Roundup”

Date: Jul 9, 2026

No Fourth Amendment Privacy in Freenet Opennet Block Requests Logged by “Freenet Roundup” Introduction United States v. Johnson (1st Cir. July 7, 2026) addresses whether law enforcement conducts a...

Uncontroverted Drafter-and-Signatory Testimony Can Resolve Contract Ambiguity as a Matter of Law

Date: Jul 9, 2026

Uncontroverted Drafter-and-Signatory Testimony Can Resolve Contract Ambiguity as a Matter of Law 1. Introduction 20100 Eastex, L.L.C. v. Saltgrass, Incorporated (5th Cir. July 6, 2026) is a Texas...

State 340B Contract-Pharmacy Protection Statutes Survive: No §340B Preemption; No Takings, Contracts Clause, or Vagueness Violation

Date: Jul 9, 2026

State 340B Contract-Pharmacy Protection Statutes Survive: No §340B Preemption; No Takings, Contracts Clause, or Vagueness Violation I. Introduction AstraZeneca v. Murrill (consolidated with appeals...

§ 340B’s Silence on Contract-Pharmacy Delivery Leaves Room for State “Non-Interference” Laws

Date: Jul 9, 2026

§ 340B’s Silence on Contract-Pharmacy Delivery Leaves Room for State “Non-Interference” Laws (and Such Laws Survive Takings, Contracts Clause, and Vagueness Attacks) 1. Introduction In AbbVie v....

Single-Member LLC Truck Operator Is a No-Fault “Owner” Based on Right of Use (No Veil Piercing Required)

Date: Jul 9, 2026

Single-Member LLC Truck Operator Is a No-Fault “Owner” Based on Right of Use (No Veil Piercing Required) I. Introduction Case: Mohammed Abdulla v. Progressive Southeastern Insurance Company (with...