Puerto Rico Case Commentaries

Baro v. Blanche: The BIA’s 30-Day Appeal Deadline Is Nonjurisdictional and Equitable-Tolling Decisions Receive Deferential Review

Date: Jun 18, 2026

Baro v. Blanche: The BIA’s 30-Day Appeal Deadline Is Nonjurisdictional and Equitable-Tolling Decisions Receive Deferential Review I. Introduction In Sona Baro v. Todd W. Blanche (6th Cir. June 16,...

§1519 Venue Is Limited to the District of Falsification, Not the District of the Investigation

Date: Jun 18, 2026

§1519 Venue Is Limited to the District of Falsification, Not the District of the Investigation Introduction Abouammo v. United States (U.S. Supreme Court, June 11, 2026) resolves a recurring federal...

Advice-of-Counsel Instruction Requires Full Disclosure of Compensation Structure in Anti-Kickback Cases (United States v. Samuel Harris)

Date: Jun 18, 2026

Advice-of-Counsel Instruction Requires Full Disclosure of Compensation Structure in Anti-Kickback Cases Case: United States v. Samuel Harris (No. 25-5540) Court: U.S. Court of Appeals for the Sixth...

FINRA’s Jurisdiction Over Unregistered “Control Persons” and Strict § 78y(c)(1) Exhaustion of Jarkesy-Based Jury-Trial Objections

Date: Jun 18, 2026

FINRA’s Jurisdiction Over Unregistered “Control Persons” and Strict § 78y(c)(1) Exhaustion of Jarkesy-Based Jury-Trial Objections Introduction In Eric Smith v. SEC (6th Cir. June 16, 2026), the Sixth...

RICO § 1965(b) “Ends of Justice” Requires More Than Convenience: Sixth Circuit Narrows Nationwide Service Over Non-Contact Defendants

Date: Jun 18, 2026

RICO § 1965(b) “Ends of Justice” Requires More Than Convenience: Sixth Circuit Narrows Nationwide Service Over Non-Contact Defendants 1. Introduction In Aaron Hall v. Trivest Partners, L.P. (6th Cir....

Admitting Patient-Death Evidence in “Pill Mill” Prosecutions Requires a Defendant-Specific Connection

Date: Jun 18, 2026

Admitting Patient-Death Evidence in “Pill Mill” Prosecutions Requires a Defendant-Specific Connection I. Introduction In United States v. Evann Herrell (6th Cir. June 16, 2026), the Sixth Circuit...

Conditional Admissibility of Patient-Death Evidence in Pill-Mill Prosecutions Requires a Defendant-Specific “Connectivity” Showing

Date: Jun 18, 2026

Conditional Admissibility of Patient-Death Evidence in Pill-Mill Prosecutions Requires a Defendant-Specific “Connectivity” Showing Case: United States of America v. Evann Herrell; Mark Grenkoski;...

Unambiguous “Licensed Employee” Contract Language and Sufficient Board Minutes Create a Mississippi School Employee Property Interest Triggering § 37-9-105 Notice-and-Hearing Rights

Date: Jun 18, 2026

Unambiguous “Licensed Employee” Contract Language and Sufficient Board Minutes Create a Mississippi School Employee Property Interest Triggering § 37-9-105 Notice-and-Hearing Rights 1. Introduction...

Unsettled-Law Defeats Plain Error and Voluntary Refusal of Transport Permits Sentencing in Absentia (N.H.)

Date: Jun 18, 2026

Unsettled-Law Defeats Plain Error and Voluntary Refusal of Transport Permits Sentencing in Absentia I. Introduction In State of New Hampshire v. Dale E. Holloway, Jr. (N.H. June 17, 2026), the...

Upward Variances After a Taylor Vacatur: Guidelines “Unit Cap” and Dismissed § 924(c) Exposure Can Justify Reimposing the Original Aggregate Sentence

Date: Jun 18, 2026

Upward Variances After a Taylor Vacatur: Guidelines “Unit Cap” and Dismissed § 924(c) Exposure Can Justify Reimposing the Original Aggregate Sentence I. Introduction In United States v....

Standing to Mount a Constitutional Challenge Requires a Disadvantaged Legal Interest: Expungement-Statute Challenge Dismissed and Court of Appeals Opinion Vacated

Date: Jun 18, 2026

Standing to Mount a Constitutional Challenge Requires a Disadvantaged Legal Interest: Expungement-Statute Challenge Dismissed and Court of Appeals Opinion Vacated 1. Introduction In Sela Investments,...

Trespass Lies Where an Easement Holder Overburdens Private Streets; Public Nuisance “Special Injury” Includes Pecuniary Loss and Trespass

Date: Jun 18, 2026

Trespass Lies Where an Easement Holder Overburdens Private Streets; Public Nuisance “Special Injury” Includes Pecuniary Loss and Trespass 1. Introduction Forest Hills Gardens Corp. v West Side Tennis...

Title Insurer Tort Claims Barred Absent an Independent Duty; Time-Barred Amendments Denied Where Relation-Back Fails

Date: Jun 18, 2026

Title Insurer Tort Claims Barred Absent an Independent Duty; Time-Barred Amendments Denied Where Relation-Back Fails Case: Marrero v Thomas, 2026 NY Slip Op 03788 (App. Div. 2d Dep’t June 17, 2026)...

Technology-Competence Duty Expanded: Rhode Island Adds “Benefits and Risks” of Developing Technology to Rule 1.1 and Issues Interim Generative AI Ethics Guidance

Date: Jun 18, 2026

Technology-Competence Duty Expanded: Rhode Island Adds “Benefits and Risks” of Developing Technology to Rule 1.1 and Issues Interim Generative AI Ethics Guidance 1. Introduction In In re Amendments...

Coleman v. State (Del. 2026): No Strickland Prejudice from Carryover Accomplice-Liability Instruction Expressly Limited to Prior Charges; Sentencing-Factor Objection Requires Outcome-Determinative Prejudice

Date: Jun 18, 2026

No Strickland Prejudice from Carryover Accomplice-Liability Instruction Expressly Limited to Prior Charges; Sentencing-Factor Objection Requires Outcome-Determinative Prejudice Introduction In...

Out-of-Possession Landlords Not Liable for Non-“Structural” Garage Rolling Gates Under a Narrow Lease Definition; Futile Administrative Code § 28-301.1 Amendments Properly Denied

Date: Jun 18, 2026

Out-of-Possession Landlords Not Liable for Non-“Structural” Garage Rolling Gates Under a Narrow Lease Definition; Futile Administrative Code § 28-301.1 Amendments Properly Denied 1. Introduction...

Admitted MRI Evidence Must Be Meaningfully Made Available to the Jury During Deliberations; Denial Can Require a New Trial on Proximate Cause Under CPLR 4404(a)

Date: Jun 18, 2026

Admitted MRI Evidence Must Be Meaningfully Made Available to the Jury During Deliberations; Denial Can Require a New Trial on Proximate Cause Under CPLR 4404(a) 1. Introduction In J.T.M. v Parrinello...

No-Fault De Novo Actions: Insurer Must Prove Timely Mailing of Denials (or Face Preclusion), While Causation Defenses Require a Specific, Record-Based Showing

Date: Jun 18, 2026

No-Fault De Novo Actions: Insurer Must Prove Timely Mailing of Denials (or Face Preclusion), While Causation Defenses Require a Specific, Record-Based Showing 1. Introduction American Tr. Ins. Co. v...

State v. Eaker — Sex Offender Parole Under § 31-21-10.1 Attaches at Sentencing Without a Prison-Incarceration Prerequisite

Date: Jun 18, 2026

Sex Offender Parole Under § 31-21-10.1 Attaches at Sentencing Without a Prison-Incarceration Prerequisite Case: State v. Eaker Court: Supreme Court of New Mexico Date: June 17, 2026 Posture: State’s...

Guzman v. Sullivan (2026 S.D. 38) Commentary

Date: Jun 18, 2026

Habeas Rule 12(b)(5) Dismissals Must Use the Twombly/Sisney “Plausibility” Standard—South Dakota Retires the “No Set of Facts” Formulation in Habeas Case: Guzman v. Sullivan, 2026 S.D. 38 (S.D. June...