Puerto Rico Case Commentaries

Absconding from Probation Justifies Charging Pre-Arrest Speedy-Trial Delay to the Accused; Forensic Mirror Images Satisfy “Substantial Equivalent” Discovery

Date: May 21, 2026

Absconding from Probation Justifies Charging Pre-Arrest Speedy-Trial Delay to the Accused; Forensic Mirror Images Satisfy “Substantial Equivalent” Discovery Case: State v. M. Smith, 2026 MT 106...

Conveying a Life Estate to One Joint Tenant Severs the Joint Tenancy by Destroying the Unity of Interest (Mont. 2026)

Date: May 21, 2026

Conveying a Life Estate to One Joint Tenant Severs the Joint Tenancy by Destroying the Unity of Interest (Mont. 2026) 1. Introduction In MacLaurin v. Fischer Law, PLLC, 2026 MT 109, the Montana...

Mandatory Felony-DUI Fines After Cole: Fine Must Be Imposed, Then Ability-to-Pay Evaluated with Possible Suspension

Date: May 21, 2026

Mandatory Felony-DUI Fines After Cole: Fine Must Be Imposed, Then Ability-to-Pay Evaluated with Possible Suspension Case: State v. C. Spang, 2026 MT 107 (Mont. May 19, 2026) Court: Supreme Court of...

Cline v. Pritchard (Mont. 2026): No Rule 55(b)(2) Default-Hearing Notice Absent an “Appearance,” and Veterans’ Disability Benefits Lose Exemption Once Converted into Marital Real Property

Date: May 21, 2026

Cline v. Pritchard (Mont. 2026): No Rule 55(b)(2) Default-Hearing Notice Absent an “Appearance,” and Veterans’ Disability Benefits Lose Exemption Once Converted into Marital Real Property 1....

Montana’s 2026 Evidence Modernization Proposal: Deepfake Authentication Gatekeeping and a Forfeiture-by-Wrongdoing Hearsay Exception

Date: May 21, 2026

Montana’s 2026 Evidence Modernization Proposal: Deepfake Authentication Gatekeeping and a Forfeiture-by-Wrongdoing Hearsay Exception 1. Introduction In re the Montana Rules of Evidence (Supreme Court...

State v. Guthrie: Sufficiency Review Turns on Statutory Elements—“Preteen” Testimony Can Establish Under-14 Age Absent a Preserved Date-Variance/Instructional Claim

Date: May 21, 2026

State v. Guthrie: Sufficiency Review Turns on Statutory Elements—“Preteen” Testimony Can Establish Under-14 Age Absent a Preserved Date-Variance/Instructional Claim 1. Introduction In State v....

Appeal Waivers Narrow “Eligible Defendant” Status Under Post-Conviction Rule 2 to Claims of an “Illegal” Sentence

Date: May 21, 2026

Appeal Waivers Narrow “Eligible Defendant” Status Under Post-Conviction Rule 2 to Claims of an “Illegal” Sentence I. Introduction Ortiz v. State of Indiana (Ind. May 19, 2026) addresses when a...

Parker v. The Bank of New York Mellon — Complaint Naming Only Deceased Defendants Is Void Ab Initio and Cannot Be Cured by Amendment

Date: May 21, 2026

Complaint Naming Only Deceased Defendants Is Void Ab Initio and Cannot Be Cured by Amendment or Substitution (Even in Post-Foreclosure Ejectment) Introduction In Parker v. The Bank of New York Mellon...

U.S. Bank Trust Nat’l Ass’n v. Bonilla — Wantonness Requires a Jury Where State of Mind Is Disputed; New Postjudgment Legal Theories Need Not Be Entertained

Date: May 21, 2026

Wantonness Requires a Jury Where State of Mind Is Disputed; New Postjudgment Legal Theories Need Not Be Entertained 1. Introduction U.S. Bank Trust National Association, as trustee of the Igloo...

Commercial Landlords May Use Peaceable Lockout Re-Entry for Rent Default (and Plaintiffs Must Identify a Specific Contract and “Wrongful Means” to Prove Interference)

Date: May 21, 2026

Commercial Landlords May Use Peaceable Lockout Re-Entry for Rent Default (and Plaintiffs Must Identify a Specific Contract and “Wrongful Means” to Prove Interference) 1. Introduction Nolan v. Edison...

Finley v. Turner: Income Averaging Rejected for Support Calculations and Sole Legal Custody Disfavored Where Joint Custody Is Contemplated

Date: May 21, 2026

Finley v. Turner: Income Averaging Rejected for Support Calculations and Sole Legal Custody Disfavored Where Joint Custody Is Contemplated Case: Finley v. Turner, 2026 NY Slip Op 03147 (2d Dep’t May...

Settlor May Reduce a Beneficiary’s Share to Zero; Recorded Deed and Trustee Conduct Can Bar Later Challenges to Trust Revocation

Date: May 21, 2026

Settlor May Reduce a Beneficiary’s Share to Zero; Recorded Deed and Trustee Conduct Can Bar Later Challenges to Trust Revocation Introduction Matter of Malitz Family Trust v. Angarola (2026 NY Slip...

Geographic Limits in UK Derivative-Action Standing Are Procedural in New York; Forum Non Conveniens Dismissal Must Be Conditioned on UK Refiling Protections

Date: May 21, 2026

Geographic Limits in UK Derivative-Action Standing Are Procedural in New York; Forum Non Conveniens Dismissal Must Be Conditioned on UK Refiling Protections Commentary on City of Philadelphia Bd. of...

People v. L.F.: Hearing Required Where CPL 440.10 Motion Plausibly Alleges Trafficking-Victim Causation and Padilla-Based Mandatory-Removal Misadvice

Date: May 21, 2026

People v. L.F.: Hearing Required Where CPL 440.10 Motion Plausibly Alleges Trafficking-Victim Causation and Padilla-Based Mandatory-Removal Misadvice Court: Appellate Division, Second Department (New...

RPAPL 1304 Requires Separate 90-Day Notices to Each Borrower; Jointly Addressed Single-Envelope Notice Warrants Dismissal and Supports Renewal After Yapkowitz

Date: May 21, 2026

RPAPL 1304 Requires Separate 90-Day Notices to Each Borrower; Jointly Addressed Single-Envelope Notice Warrants Dismissal and Supports Renewal After Yapkowitz 1. Introduction Case: HSBC Bank USA,...

Matter of Cantin (2026 NY Slip Op 03162): Misappropriation and Escrow-Accounting Failures Warrant a Two-Year Suspension Despite Substantial Personal Mitigation

Date: May 21, 2026

Matter of Cantin (2026 NY Slip Op 03162): Misappropriation and Escrow-Accounting Failures Warrant a Two-Year Suspension Despite Substantial Personal Mitigation 1. Introduction Matter of Cantin is an...

Matter of Warner: Aggravated DWI Conviction Triggers Presumptive Public Discipline Absent a Successful Show-Cause Defense

Date: May 21, 2026

Matter of Warner: Aggravated DWI Conviction Triggers Presumptive Public Discipline Absent a Successful Show-Cause Defense 1. Introduction Matter of Warner (App Div, 2d Dept, May 20, 2026) is an...

U.S. Bank N.A. v. White: Time-Barred Addition of a Recorded Owner in Foreclosure Is “Patently Devoid of Merit” and Unexcused Delay Defeats CPLR 3025(b) Leave

Date: May 21, 2026

Time-Barred Addition of a Recorded Owner in Foreclosure Is “Patently Devoid of Merit” and Unexcused Delay Defeats CPLR 3025(b) Leave Case: U.S. Bank N.A. v White, 2026 NY Slip Op 03198 (2d Dept May...

Ex parte Spencer: HFOA Sentencing Discretion Cannot Be Nullified by Pharmacy-Robbery Parole-Ineligibility Language

Date: May 20, 2026

Ex parte Spencer: HFOA Sentencing Discretion Cannot Be Nullified by Pharmacy-Robbery Parole-Ineligibility Language Court: Supreme Court of Alabama Date: May 15, 2026 Case: Ex parte Altonio Spencer...

Unsworn Estate-Removal Petitions Do Not Divest Probate Jurisdiction: Intervening Circuit Orders Are Void and Not Retroactively Cured

Date: May 20, 2026

Unsworn Estate-Removal Petitions Do Not Divest Probate Jurisdiction: Intervening Circuit Orders Are Void and Not Retroactively Cured 1. Introduction Case: Thomas v. Thomas (SC-2025-0804), Supreme...