Puerto Rico Case Commentaries

Strong Likelihood-of-Success Required to Stay a State Clean Water Act §401 Certification; Application Commitments May Be Enforceable When Incorporated by Reference

Date: Jun 13, 2026

Strong Likelihood-of-Success Required to Stay a State Clean Water Act §401 Certification; Application Commitments May Be Enforceable When Incorporated by Reference I. Introduction Case: Sierra Club...

Appellate Waiver Enforced Absent Proof of Government Bad Faith in Withholding a § 3E1.1 Recommendation

Date: Jun 13, 2026

Appellate Waiver Enforced Absent Proof of Government Bad Faith in Withholding a § 3E1.1 Recommendation 1. Introduction In United States v. Robert Thompson (3d Cir. June 10, 2026) (not precedential),...

Preservation-First Criminal Appeals: Forfeiture of New Suppression Theories, CI Non-Disclosure, Contextual Texts as Non-Hearsay, and Plain-Error Limits on § 922(g)(1) Second Amendment Challenges

Date: Jun 13, 2026

Preservation-First Criminal Appeals: Forfeiture of New Suppression Theories, CI Non-Disclosure, Contextual Texts as Non-Hearsay, and Plain-Error Limits on § 922(g)(1) Second Amendment Challenges 1....

Perdue’s Lodestar-Multiplier Limits Apply to Federal-Law Contractual Fee-Shifting Awards

Date: Jun 13, 2026

Perdue’s Lodestar-Multiplier Limits Apply to Federal-Law Contractual Fee-Shifting Awards Case: Artem v. Gelis v. BMW of North America, LLC, No. 24-2721 (3d Cir.) Court / Date: U.S. Court of Appeals...

PROMESA Title III Discharge Does Not Extend to Personal-Capacity Claims Against Commonwealth Officials

Date: Jun 13, 2026

PROMESA Title III Discharge Does Not Extend to Personal-Capacity Claims Against Commonwealth Officials I. Introduction Case: Hernández Zorilla v. FOMB (arising within the Commonwealth’s PROMESA Title...

Rule 56(d) Relief in the First Circuit: Summary Judgment Is Generally Premature When the Nonmovant Has Had No Meaningful Discovery Opportunity

Date: Jun 13, 2026

Rule 56(d) Relief in the First Circuit: Summary Judgment Is Generally Premature When the Nonmovant Has Had No Meaningful Discovery Opportunity 1. Introduction Cortes-Ramos v. Martin-Morales (1st Cir....

Rooker–Feldman Bars Federal “Remand” Requests that Functionally Seek Reversal of Final State-Court Dismissals

Date: Jun 13, 2026

Rooker–Feldman Bars Federal “Remand” Requests that Functionally Seek Reversal of Final State-Court Dismissals 1. Introduction In Tony Ping Yew, Executor of Estate of John Y Wei v. Attorney General...

STOLI Illegality Cannot Be Avoided by “Group Policy” Labeling; New York Delivery Statute Does Not Control Choice-of-Law Litigation Analysis

Date: Jun 13, 2026

STOLI Illegality Cannot Be Avoided by “Group Policy” Labeling; New York Delivery Statute Does Not Control Choice-of-Law Litigation Analysis Case: Lincoln National Life Insurance Co v. Retirement...

“Federal Inmate” Is an Element, Not a Jurisdictional Prerequisite, and Retroactive Amendment 821 Requires Resentencing by Removing Status Points

Date: Jun 13, 2026

“Federal Inmate” Is an Element, Not a Jurisdictional Prerequisite, and Retroactive Amendment 821 Requires Resentencing by Removing Status Points 1. Introduction In United States v. Manuel Guillermo...

Specific-and-Concrete Nexus Required to Search a Residence in Drug-Trafficking Investigations (Good-Faith May Still Save the Search)

Date: Jun 13, 2026

Specific-and-Concrete Nexus Required to Search a Residence in Drug-Trafficking Investigations (Good-Faith May Still Save the Search) 1. Introduction People of Michigan v. Craig Lamont Buggs, Jr....

Ballard (10th Cir. 2026): § 3553(a) Does Not Require Consideration of an Unrelated Existing Sentence When Imposing Consecutive Statutory-Maximum Terms for Prison Violence

Date: Jun 13, 2026

Ballard (10th Cir. 2026): § 3553(a) Does Not Require Consideration of an Unrelated Existing Sentence When Imposing Consecutive Statutory-Maximum Terms for Prison Violence 1. Introduction In United...

Revocation Sentencing After Esteras: A Retracted § 3553(a)(2)(A) Reference and Public-Safety-Based Reasoning Do Not Create Reversible Procedural Error

Date: Jun 13, 2026

Revocation Sentencing After Esteras: A Retracted § 3553(a)(2)(A) Reference and Public-Safety-Based Reasoning Do Not Create Reversible Procedural Error Case: United States v. Yazzie (10th Cir. June...

Attempted Child Sex Trafficking: Reckless Disregard of Age Suffices Even Without an Actual Minor (and § 1594 Judgments Do Not Become § 1591 Convictions for First Step Act Purposes)

Date: Jun 13, 2026

Attempted Child Sex Trafficking: Reckless Disregard of Age Suffices Even Without an Actual Minor (and § 1594 Judgments Do Not Become § 1591 Convictions for First Step Act Purposes) I. Introduction...

Rule 41(g) After Sentencing: State Rebuts Presumptive Entitlement by Showing Property Is Likely Stolen; Movant Must Then Prove Lawful Possession

Date: Jun 13, 2026

Rule 41(g) After Sentencing: State Rebuts Presumptive Entitlement by Showing Property Is Likely Stolen; Movant Must Then Prove Lawful Possession 1. Introduction In Jesse Alexander Mostaert v. The...

Leon Good-Faith Applies Despite Close Probable Cause Where Affidavit Shows Substantial Access (Not Residency) and Alleged Misstatements/Omissions Are at Most Negligent

Date: Jun 13, 2026

Leon Good-Faith Applies Despite Close Probable Cause Where Affidavit Shows Substantial Access (Not Residency) and Alleged Misstatements/Omissions Are at Most Negligent I. Introduction In United...

Martin v. Duran: Barnes “Totality” Review Does Not Justify a Second, Gratuitous Taser Use; No Clearly Established Bar to Late-Night Terry Stop in Government Complex

Date: Jun 13, 2026

Martin v. Duran: Barnes “Totality” Review Does Not Justify a Second, Gratuitous Taser Use; No Clearly Established Bar to Late-Night Terry Stop in Government Complex Court: U.S. Court of Appeals for...

Judicial Estoppel in Bankruptcy Nondisclosure Requires a Totality-of-the-Circumstances “Inadvertence or Mistake” Inquiry

Date: Jun 13, 2026

Judicial Estoppel in Bankruptcy Nondisclosure Requires a Totality-of-the-Circumstances “Inadvertence or Mistake” Inquiry Keathley v. Buddy Ayers Construction, Inc., 608 U.S. ___ (2026) (Decided June...

§1519 Venue Is Limited to the District of Falsification (Mens Rea and “Contemplated Effects” Do Not Expand Venue)

Date: Jun 13, 2026

§1519 Venue Is Limited to the District of Falsification (Mens Rea and “Contemplated Effects” Do Not Expand Venue) 1. Introduction Abouammo v. United States (608 U. S. ___ (2026)) addresses where a...

OPRA Treats Logs of Government-Related Emails in Officials’ Personal Accounts as Government Records (But Not Whole Personal-Account Logs)

Date: Jun 13, 2026

OPRA Treats Logs of Government-Related Emails in Officials’ Personal Accounts as Government Records (But Not Whole Personal-Account Logs) I. Introduction In Alex Rosetti v. Ramapo-Indian Hills...

FECA as a “Healthcare Benefit Program” and Full-Account Forfeiture When Commingling Conceals Fraud Proceeds

Date: Jun 13, 2026

FECA as a “Healthcare Benefit Program” and Full-Account Forfeiture When Commingling Conceals Fraud Proceeds Introduction In United States v. Nourian (5th Cir. June 10, 2026) (per curiam) (not...