Puerto Rico Case Commentaries

No Per Se Piercing of Medical/Therapy Privileges for RSA 135:17-a, V Involuntary-Admission Evaluations; “Standard of Care” Alone Is Not a Compelling Justification

Date: May 19, 2026

No Per Se Piercing of Medical/Therapy Privileges for RSA 135:17-a, V Involuntary-Admission Evaluations; “Standard of Care” Alone Is Not a Compelling Justification 1. Introduction State of New...

Contextual Credibility Standard for “Assertion of Innocence” in Rule 11(d)(2)(B) Guilty-Plea Withdrawal Motions

Date: May 19, 2026

Contextual Credibility Standard for “Assertion of Innocence” in Rule 11(d)(2)(B) Guilty-Plea Withdrawal Motions 1. Introduction In United States v. Ortega-Moreno (10th Cir. May 18, 2026) (unpublished...

United States v. Back: Speculative Prejudice Cannot Defeat a Timely Indictment; Intermediary Assurances Can “Further” a Drug Conspiracy

Date: May 19, 2026

United States v. Back: Speculative Prejudice Cannot Defeat a Timely Indictment; Intermediary Assurances Can “Further” a Drug Conspiracy Court: U.S. Court of Appeals for the Tenth Circuit (May 18,...

Revocation Sentencing Must Be Based on the Revocation Record: Extra-Record Trial Evidence Cannot Supply a Grade A Finding

Date: May 19, 2026

Revocation Sentencing Must Be Based on the Revocation Record: Extra-Record Trial Evidence Cannot Supply a Grade A Finding I. Introduction In United States v. Fernandez-Santos (1st Cir. May 15, 2026),...

Overlapping Evidence May Support a Willful-Blindness Instruction in Money-Laundering Conspiracies, and Guidelines Errors Are Harmless Where the Court Would Impose the Same Sentence

Date: May 19, 2026

Overlapping Evidence May Support a Willful-Blindness Instruction in Money-Laundering Conspiracies, and Guidelines Errors Are Harmless Where the Court Would Impose the Same Sentence Case: United...

Arizona’s Post-2021 Administrative Review Rule: Superior Courts Find Facts Independently, Yet Still Apply Substantial-Evidence Review; Appellate Courts Defer to Superior-Court Factfinding

Date: May 19, 2026

Arizona’s Post-2021 Administrative Review Rule: Superior Courts Find Facts Independently, Yet Still Apply Substantial-Evidence Review; Appellate Courts Defer to Superior-Court Factfinding 1....

Prosecutorial Error Is Objective: No Mental-State Element and Escalante Prong-Three “Profound Distortion” Governs Cumulative-Error Review

Date: May 19, 2026

Prosecutorial Error Is Objective: No Mental-State Element and Escalante Prong-Three “Profound Distortion” Governs Cumulative-Error Review Introduction State of Arizona v. Dimitri Polanco Romero...

Second Circuit Endorses Munsingwear Vacatur on Joint Motion When Mootness Is Not Fairly Attributable to Appellants

Date: May 19, 2026

Second Circuit Endorses Munsingwear Vacatur on Joint Motion When Mootness Is Not Fairly Attributable to Appellants I. Introduction Am. Ass'n of Univ. Professors v. U.S. Dep't of Just. (2d Cir. May...

Federal Reserve Act Confers Discretion (Not Entitlement) Over Master Accounts for Nonmember Depository Institutions

Date: May 19, 2026

Federal Reserve Act Confers Discretion (Not Entitlement) Over Master Accounts for Nonmember Depository Institutions I. Introduction In Banco San Juan Internacional, Inc. v. Fed. Rsrv. Bank of N.Y.,...

Second Circuit Rejects New York’s “Opt-In” Default Gun Ban on Public-Access Private Property While Upholding an Urban Public-Park Carry Ban on Facial Review

Date: May 19, 2026

Second Circuit Rejects New York’s “Opt-In” Default Gun Ban on Public-Access Private Property While Upholding an Urban Public-Park Carry Ban on Facial Review 1. Introduction Christian v. James (Nos....

United States v. Dralle: Plain Error to Rely on a Co-Defendant’s Prior Violence as “Context” at Sentencing Absent Joint Undertaking, Foreseeability, or a § 3553(a) Nexus

Date: May 19, 2026

United States v. Dralle: Plain Error to Rely on a Co-Defendant’s Prior Violence as “Context” at Sentencing Absent Joint Undertaking, Foreseeability, or a § 3553(a) Nexus Introduction In United States...

Appeal Waivers Bar Resentencing on Limited Remand Despite Intervening Guidelines Law; Ripeness of Supervised-Release Conditions Is Issue-Specific

Date: May 19, 2026

Appeal Waivers Bar Resentencing on Limited Remand Despite Intervening Guidelines Law; Ripeness of Supervised-Release Conditions Is Issue-Specific Case: United States v. Jimenez (2d Cir. Feb. 25,...

FAPA Retroactivity Upheld: No Federal Due Process, Contracts Clause, or Takings Clause Violation in Mortgage Quiet-Title Litigation

Date: May 19, 2026

FAPA Retroactivity Upheld: No Federal Due Process, Contracts Clause, or Takings Clause Violation in Mortgage Quiet-Title Litigation Article 13 LLC v. LaSalle Nat'l Bank Ass'n (2d Cir. May 13, 2026)...

Shevling v. Major (2026 S.D. 27): Enforcing Plain-Language Military Retirement Percentages (No Implied Coverture Reduction) and Applying Statutory Interest Absent Contract

Date: May 19, 2026

Shevling v. Major (2026 S.D. 27): Enforcing Plain-Language Military Retirement Percentages (No Implied Coverture Reduction) and Applying Statutory Interest Absent Contract 1. Introduction Parties:...

State v. Pickner (2026 S.D. 29) Commentary

Date: May 19, 2026

State v. Pickner: No Post-Judgment Conversion of a Conviction into a Suspended Imposition of Sentence Under SDCL 23A-31-1 or SDCL 23A-27-19; Res Judicata Does Not Bar the State When Appellate Review...

State v. Cadotte (2026 S.D. 28): Criminal Discovery Requires “Permit to Inspect,” Not Exhibit-By-Exhibit Identification; Cumulative Hearsay Is Nonprejudicial

Date: May 19, 2026

State v. Cadotte (2026 S.D. 28): Criminal Discovery Requires “Permit to Inspect,” Not Exhibit-By-Exhibit Identification; Cumulative Hearsay Is Nonprejudicial Court: Supreme Court of South Dakota...

Successive Death-Warrant Postconviction Claims Must Be Timely, Non-Speculative, and Meet Strict Merits Standards (Knight v. State)

Date: May 19, 2026

Successive Death-Warrant Postconviction Claims Must Be Timely, Non-Speculative, and Meet Strict Merits Standards (Knight v. State) I. Introduction In Richard Knight v. State of Florida (Fla. May 15,...

Apprendi/Alleyne Sentencing-Procedure Claims Are Not Cognizable as “Illegal Sentence” Errors Under Florida Rule 3.800(a)

Date: May 19, 2026

Apprendi/Alleyne Sentencing-Procedure Claims Are Not Cognizable as “Illegal Sentence” Errors Under Florida Rule 3.800(a) Introduction In Marcus Roland Maye v. State of Florida (Fla. May 14, 2026)...

Personal and Particularized Irreparable Harm Required to Preliminarily Enjoin a Statute (Even in Facial Constitutional Challenges)

Date: May 19, 2026

Personal and Particularized Irreparable Harm Required to Preliminarily Enjoin a Statute (Even in Facial Constitutional Challenges) Case: Megan Degenfelder, et al. v. Wyoming Education Association, et...

Summary Affirmance for Noncompliant Appellate Briefing and Inadequate Record—Including Pro Se Appeals from Arbitration Orders

Date: May 19, 2026

Summary Affirmance for Noncompliant Appellate Briefing and Inadequate Record—Including Pro Se Appeals from Arbitration Orders 1. Introduction Victorine O'Donoghue v. Jim Vito Construction, Inc., and...