Puerto Rico Case Commentaries

People v. Russ: Inventory Searches Require Proof of Standardized, Discretion-Limiting Policy (Including Any Canine Use or Intrusive Compartment Access)

Date: Jun 5, 2026

People v. Russ: Inventory Searches Require Proof of Standardized, Discretion-Limiting Policy (Including Any Canine Use or Intrusive Compartment Access) 1. Introduction In People v Russ (2026 NY Slip...

Unsigned Reclassification Paperwork Cannot Expand Civil Service Title Duties for Out-of-Title Work Analysis

Date: Jun 5, 2026

Unsigned Reclassification Paperwork Cannot Expand Civil Service Title Duties for Out-of-Title Work Analysis 1. Introduction Matter of Theopheles v. County of Rensselaer (Appellate Division, Third...

When Parent–Grandparent Conflict Makes “As-Agreed” Visitation Untenable, Family Court Must Set a Definitive Schedule

Date: Jun 5, 2026

When Parent–Grandparent Conflict Makes “As-Agreed” Visitation Untenable, Family Court Must Set a Definitive Schedule Matter of Justine N. v. Michelle P., 2026 NY Slip Op 03497 (App Div 3d Dept June...

Diligent Efforts for Incarcerated Parents: Reasonable Contact Suffices, but Relative Placement Requires Affirmative Investigation

Date: Jun 5, 2026

Diligent Efforts for Incarcerated Parents: Reasonable Contact Suffices, but Relative Placement Requires Affirmative Investigation 1. Introduction In Matter of Aliano E. (Alan E.) (2026 NY Slip Op...

MHL Article 81: Courts May Not Sua Sponte Modify Guardianship Powers, and Compensation Reductions Require Notice and a Reasonableness Hearing

Date: Jun 5, 2026

MHL Article 81: Courts May Not Sua Sponte Modify Guardianship Powers, and Compensation Reductions Require Notice and a Reasonableness Hearing Case: Matter of Karissa W., 2026 NY Slip Op 03490 (App...

Oral Assumption of Debt Between Debtor and Third Party Is Not Barred by N.D.C.C. § 9-06-04(2) or (5)

Date: Jun 5, 2026

Oral Assumption of Debt Between Debtor and Third Party Is Not Barred by N.D.C.C. § 9-06-04(2) or (5) Case: Hofer v. Paulson, 2026 ND 111 (N.D. June 4, 2026) 1. Introduction Hofer v. Paulson arose out...

Reaffirming Progressive Discipline and the “Minimum 60-Day Suspension” Norm Despite a 30-Day Stipulation

Date: Jun 5, 2026

Reaffirming Progressive Discipline and the “Minimum 60-Day Suspension” Norm Despite a 30-Day Stipulation 1. Introduction This matter arises from a Wisconsin attorney-discipline proceeding brought by...

People v. Jackson: When the People Concede They Were Not Actually Ready, CPL 30.30 Requires a Fact-Finding Hearing to Allocate Chargeable Time Despite a Filed COC/SOR

Date: Jun 5, 2026

People v. Jackson: When the People Concede They Were Not Actually Ready, CPL 30.30 Requires a Fact-Finding Hearing to Allocate Chargeable Time Despite a Filed COC/SOR Case: People v Jackson, 2026 NY...

Custody Modification Requires a Threshold “Change in Circumstances” Finding Before Best-Interests Review (Error May Be Harmless if Record Independently Establishes the Change)

Date: Jun 5, 2026

Custody Modification Requires a Threshold “Change in Circumstances” Finding Before Best-Interests Review (Error May Be Harmless if Record Independently Establishes the Change) 1. Introduction Matter...

Administrative Res Judicata Does Not Bar a Workers’ Compensation “Acceleration” Claim Until Benefits Are Terminated and the Dispute Is Ripe

Date: Jun 5, 2026

Administrative Res Judicata Does Not Bar a Workers’ Compensation “Acceleration” Claim Until Benefits Are Terminated and the Dispute Is Ripe 1. Introduction In WSI v. Jones, 2026 ND 115, the North...

Default Does Not Bar Appellate Review of Contested Inquest Issues in Family Court Custody Proceedings

Date: Jun 5, 2026

Default Does Not Bar Appellate Review of Contested Inquest Issues in Family Court Custody Proceedings 1. Introduction Matter of Rachel QQ. v. Jaime QQ. (2026 NY Slip Op 03494) is a Third Department...

Impass-Tie-Breaker Authority in Joint Legal Custody and Required Record Development Before Denying Expanded Parenting Time

Date: Jun 5, 2026

Impass-Tie-Breaker Authority in Joint Legal Custody and Required Record Development Before Denying Expanded Parenting Time 1. Introduction Matter of Andrew O. v Jessica P. (Appellate Division, Third...

People v Pittman: “What’s in there?” Is Custodial Interrogation, and Secured-Bag Searches Incident to Arrest Require Proven Exigency

Date: Jun 5, 2026

People v Pittman: “What’s in there?” Is Custodial Interrogation, and Secured-Bag Searches Incident to Arrest Require Proven Exigency 1. Introduction In People v Pittman (Appellate Division, Third...

“Issued” Means Mailed/Notified Under 7 NYCRR 201.5: DOCCS Must Prove the Mailing Date to Defeat an Article 78 on Exhaustion

Date: Jun 5, 2026

“Issued” Means Mailed/Notified Under 7 NYCRR 201.5: DOCCS Must Prove the Mailing Date to Defeat an Article 78 on Exhaustion 1. Introduction Matter of Moses v New York State Dept. of Corr. & Community...

Petition of Dansdill (2026 ND 109): Pro Hac Vice Deadline Violations as Unauthorized Practice Under N.D.R. Prof. Conduct 5.5(a)

Date: Jun 5, 2026

Pro Hac Vice Rule 3(A)(2) Noncompliance Constitutes Unauthorized Practice Under N.D.R. Prof. Conduct 5.5(a) I. Introduction Petition of Dansdill, 2026 ND 109, is a North Dakota Supreme Court...

People v. Roberts: No Pocket Search Without a True Pat-Down or a Contemporaneous Intent to Arrest

Date: Jun 5, 2026

People v. Roberts: No Pocket Search Without a True Pat-Down or a Contemporaneous Intent to Arrest Introduction In People v Roberts (2026 NY Slip Op 03476 [3d Dept June 4, 2026]), the Appellate...

Vacating Open-Ended CPLR Stays Tied to Foreign Proceedings After Prolonged Delay—Especially in Nazi-Looted Art Cases

Date: Jun 5, 2026

Vacating Open-Ended CPLR Stays Tied to Foreign Proceedings After Prolonged Delay—Especially in Nazi-Looted Art Cases I. Introduction Estate of Margaret Kainer v Christies Inc. (2026 NY Slip Op 03506...

Ohio Disqualification Law After In re Disqualification of Santoli (2026): Enforcing the 15‑Page Limit and Treating “Premature” Rulings as Disqualifying Only When Substantively Prejudicial

Date: Jun 5, 2026

Ohio Disqualification Law After In re Disqualification of Santoli (2026): Enforcing the 15‑Page Limit and Treating “Premature” Rulings as Disqualifying Only When Substantively Prejudicial Case: In re...

Mootness in Custody/Visitation Appeals After Superseding Family Court Orders, While Preserving Review of an Unaddressed Violation Dismissal

Date: Jun 5, 2026

Mootness in Custody/Visitation Appeals After Superseding Family Court Orders, While Preserving Review of an Unaddressed Violation Dismissal 1. Introduction Matter of James EE. v Vanessa EE....

Pre-Dispositional Bail No-Contact Conditions Are Not Punishable as “Temporary Restraining Orders” Under N.D.C.C. § 12.1-10-05(1)

Date: Jun 5, 2026

Pre-Dispositional Bail No-Contact Conditions Are Not Punishable as “Temporary Restraining Orders” Under N.D.C.C. § 12.1-10-05(1) Case: State v. Ferrell, 2026 ND 112 Court: Supreme Court of North...