Puerto Rico Case Commentaries

Pretrial Self-Defense Immunity Under SDCL 22-18-4.8 Is Moot After Conviction: The Bendel Rule

Date: Jun 12, 2026

Pretrial Self-Defense Immunity Under SDCL 22-18-4.8 Is Moot After Conviction: The Bendel Rule 1. Introduction In State v. Bendel, 2026 S.D. 35, the Supreme Court of South Dakota addressed a homicide...

State v. Hawley (2026 S.D. 37) Commentary

Date: Jun 12, 2026

“When Required” Means Sometimes Not Required: Traffic Stops Cannot Rest on Objectively Unreasonable Mistakes of South Dakota Turn-Signal Law (SDCL 32-26-18.1 & 32-26-22) Introduction In State v....

Woodbury (Fla. 2026): Procedural Bars and Preservation Apply Fully to Pro Se Capital Defendants; Brady Pleading Must Allege Defense Unavailability; No IAC Claim Against Standby Counsel

Date: Jun 12, 2026

Woodbury (Fla. 2026): Procedural Bars and Preservation Apply Fully to Pro Se Capital Defendants; Brady Pleading Must Allege Defense Unavailability; No IAC Claim Against Standby Counsel I....

Mandatory Jurisdictional Statements and Issue-by-Issue Standards of Review in Florida Initial Briefs

Date: Jun 12, 2026

Mandatory Jurisdictional Statements and Issue-by-Issue Standards of Review in Florida Initial Briefs Case: In Re: Amendments to Florida Rules of Appellate Procedure Court: Supreme Court of Florida...

Seventh Circuit: Rule 11 “Persist” Omission Not Plain Error When Otherwise Conveyed; Completed Hobbs Act Robbery Remains a § 924(c) Crime of Violence Post-Borden

Date: Jun 12, 2026

Seventh Circuit: Rule 11 “Persist” Omission Not Plain Error When Otherwise Conveyed; Completed Hobbs Act Robbery Remains a § 924(c) Crime of Violence Post-Borden Introduction In United States v....

Eleventh Circuit Certifies Opioid-Litigation Coverage Questions on “Damages Because of Bodily Injury” to Georgia and Florida Supreme Courts

Date: Jun 12, 2026

Eleventh Circuit Certifies Opioid-Litigation Coverage Questions on “Damages Because of Bodily Injury” to Georgia and Florida Supreme Courts I. Introduction In Allied Property & Casualty Insurance...

CAT Relief in the Fifth Circuit: “Acquiescence” Is Not Required When Torture Is Inflicted Under Color of Law

Date: Jun 12, 2026

CAT Relief in the Fifth Circuit: “Acquiescence” Is Not Required When Torture Is Inflicted Under Color of Law I. Introduction Vasquez-Barrera v. Blanche (5th Cir. June 10, 2026) concerns a bisexual...

Controlled Affiliate Is Not a “Third Party,” and a Time-Limited SPE Cannot “Assume” a 99-Year Ground Lease Under § 19 Estoppel Release Language

Date: Jun 12, 2026

Controlled Affiliate Is Not a “Third Party,” and a Time-Limited SPE Cannot “Assume” a 99-Year Ground Lease Under § 19 Estoppel Release Language Case: Rock Spring Plaza, II, LLC v. Investors Warranty...

UCFA § 2904(b) Supersedes CAJTA § 4302(d): Contribution After Arbitration/Settlement and Interest Only After Apportionment Judgment

Date: Jun 12, 2026

UCFA § 2904(b) Supersedes CAJTA § 4302(d): Contribution After Arbitration/Settlement and Interest Only After Apportionment Judgment I. Introduction Telesource CNMI, Inc. v. SSFM International, Inc.,...

Particularized “Necessity” for Title III Wiretaps: Detailed Limits of Traditional Techniques and Surveillance-Evasion Facts Suffice

Date: Jun 12, 2026

Particularized “Necessity” for Title III Wiretaps: Detailed Limits of Traditional Techniques and Surveillance-Evasion Facts Suffice I. Introduction In United States v. Medina (10th Cir. June 11,...

Tenth Circuit: Major Upward Variance in Child Sex-Trafficking Conspiracy Affirmed; District Courts May Reconsider Guideline-Accounted Facts Under § 3553(a) Absent Evidence of Bias

Date: Jun 12, 2026

Tenth Circuit: Major Upward Variance in Child Sex-Trafficking Conspiracy Affirmed; District Courts May Reconsider Guideline-Accounted Facts Under § 3553(a) Absent Evidence of Bias Introduction In...

Data-Breach Standing in the First Circuit: Actual Misuse Can Be Injury-in-Fact, but Traceability Requires Plausible, Nonconclusory Facts Linking the Misuse to the Breach

Date: Jun 12, 2026

Data-Breach Standing in the First Circuit: Actual Misuse Can Be Injury-in-Fact, but Traceability Requires Plausible, Nonconclusory Facts Linking the Misuse to the Breach I. Introduction In...

Crawford v. Salve Regina University: Pleading-Stage “Nexus to Decisionmakers” Requirement for Discrimination/Hostile Environment Claims in Faculty Termination Cases

Date: Jun 12, 2026

Crawford v. Salve Regina University: Pleading-Stage “Nexus to Decisionmakers” Requirement for Discrimination/Hostile Environment Claims in Faculty Termination Cases Introduction In Crawford v. Salve...

Final Conviction Moots Appellate Review of SDCL 22-18-4.8 Pretrial Self‑Defense Immunity Rulings (State v. Braveheart)

Date: Jun 12, 2026

Final Conviction Moots Appellate Review of SDCL 22-18-4.8 Pretrial Self‑Defense Immunity Rulings Introduction In State v. Braveheart, 2026 S.D. 36, the Supreme Court of South Dakota addressed a...

Section 768.72(1) Gatekeeping: Claimant-Only Evidentiary Proffer and No “Clear and Convincing” Overlay at the Pleading Stage

Date: Jun 12, 2026

Section 768.72(1) Gatekeeping: Claimant-Only Evidentiary Proffer and No “Clear and Convincing” Overlay at the Pleading Stage I. Introduction In Isaac “Ike” Perlmutter v. Federal Insurance Company...

Specific Objection Required to Preserve Confrontation-Clause Challenges to Embedded Third-Party Statements (and Casual Private Remarks Are Nontestimonial)

Date: Jun 12, 2026

Specific Objection Required to Preserve Confrontation-Clause Challenges to Embedded Third-Party Statements (and Casual Private Remarks Are Nontestimonial) 1. Introduction In Nakii Holloway v. State...

Res Ipsa Loquitur Requires Probable Defendant Responsibility When Vendor Control Is Shared

Date: Jun 12, 2026

Res Ipsa Loquitur Requires Probable Defendant Responsibility When Vendor Control Is Shared Case: Rateb Khouri v. Highland Park CVS, L.L.C. and CVS Pharmacy Inc. Court: United States Court of Appeals...

Threats Against a Prosecutor Do Not Require Disqualification Under 28 U.S.C. § 528 Absent a Qualifying “Personal Relationship” (Anders Dismissal)

Date: Jun 12, 2026

Threats Against a Prosecutor Do Not Require Disqualification Under 28 U.S.C. § 528 Absent a Qualifying “Personal Relationship” (Anders Dismissal) Introduction In United States v. Ademeko...

No Pre-Deprivation Hearing Required Before Dismissing a Childcare Voucher Provider for Failing to Produce Records During an On-Site Investigation

Date: Jun 12, 2026

No Pre-Deprivation Hearing Required Before Dismissing a Childcare Voucher Provider for Failing to Produce Records During an On-Site Investigation Case: iCare Child Development Center LLC v. Alethea...

United States v. Morilla: Individualized Findings Required for Sophisticated-Laundering Enhancement; Premature Keene Alternative Sentence Cannot Cure Guideline Error

Date: Jun 12, 2026

United States v. Morilla: Individualized Findings Required for Sophisticated-Laundering Enhancement; Premature Keene Alternative Sentence Cannot Cure Guideline Error 1. Introduction In United States...