Puerto Rico Case Commentaries

Conditional Pleas Do Not Create Appellate Finality: West Virginia Criminal Appeals Require Sentence as the Final Judgment

Date: May 5, 2026

Conditional Pleas Do Not Create Appellate Finality: West Virginia Criminal Appeals Require Sentence as the Final Judgment I. Introduction In State of West Virginia v. Richard A. Hensley Jr. (Apr. 30,...

Preston v. SB&C, Ltd.: Charity-Care Notice Duty Extends to Collection Agencies Collecting Hospital Debt Under RCW 70.170.060(8)(a)

Date: May 5, 2026

Preston v. SB&C, Ltd.: Charity-Care Notice Duty Extends to Collection Agencies Collecting Hospital Debt Under RCW 70.170.060(8)(a) Court: Supreme Court of Washington (En Banc) Date: April 30, 2026...

HELOCs Are Nonnegotiable; DTA “Holder” Proof Requires a Negotiable-Note Holder for Nonjudicial Foreclosure (Marquez Vargas v. RRA CP Opportunity Tr. 1)

Date: May 5, 2026

HELOCs Are Nonnegotiable; DTA “Holder” Proof Requires a Negotiable-Note Holder for Nonjudicial Foreclosure Marquez Vargas v. RRA CP Opportunity Trust 1 (Wash. Apr. 30, 2026) Court: Supreme Court of...

Polinder v. Brand Insulations: Construction Statute of Repose Bars Construction-Activity Claims but Not Independent Seller/Supplier Claims

Date: May 5, 2026

Construction Statute of Repose Bars Claims “Arising From” Integral Construction Work, but Not Claims Based on Independent Product Seller/Supplier Duties 1. Introduction Case: Polinder v. Aecom Energy...

Clean Air Act Citizen Suits Require Ongoing or Repeated SIP Violations—Purely Prospective Noncompliance Is Not Actionable Under § 7604(a)(1)

Date: May 5, 2026

Clean Air Act Citizen Suits Require Ongoing or Repeated SIP Violations—Purely Prospective Noncompliance Is Not Actionable Under § 7604(a)(1) I. Introduction Gordon-Darby Holdings, Inc. v. Quinn is a...

Contractual Silence on Contingency-Fee Bonus Credit Is Not Ambiguity; Wage Claimant Must Prove an Agreed Bonus Rate

Date: May 5, 2026

Contractual Silence on Contingency-Fee Bonus Credit Is Not Ambiguity; Wage Claimant Must Prove an Agreed Bonus Rate Introduction In Dino Moncecchi v. Mckellar, Tiedeken & Scoggin, LLC, 2026 WY 50...

State v. Kelly — Harmless-Error Review for Denied Use-of-Force Instructions in Aggravated-Burglary Felony Murder; “Physical Evidence Is Not Biased” Closing Argument Not Improper Vouching

Date: May 5, 2026

State v. Kelly — Harmless-Error Review for Denied Use-of-Force Instructions in Aggravated-Burglary Felony Murder; “Physical Evidence Is Not Biased” Closing Argument Not Improper Vouching 1....

Amendment 80 Fixes Jurisdiction: Circuit Courts Retain Original Jurisdiction Over Facial Constitutional Challenges; Legislature Cannot Confer Exclusive Original Jurisdiction on the Court of Appeals

Date: May 5, 2026

Amendment 80 Fixes Jurisdiction: Circuit Courts Retain Original Jurisdiction Over Facial Constitutional Challenges; Legislature Cannot Confer Exclusive Original Jurisdiction on the Court of Appeals...

“Methamphetamine” in the Controlled Substances Act Means the Generic Drug—No Isomer-by-Isomer Proof Required

Date: May 5, 2026

“Methamphetamine” in the Controlled Substances Act Means the Generic Drug—No Isomer-by-Isomer Proof Required 1. Introduction United States v. Glenn Wooden (7th Cir. Apr. 30, 2026) addresses a...

United States v. Blair: Cellebrite Phone Extractions May Be Authenticated and Admitted Through Lay Agent Testimony (No Expert Required)

Date: May 5, 2026

United States v. Blair: Cellebrite Phone Extractions May Be Authenticated and Admitted Through Lay Agent Testimony (No Expert Required) Court: U.S. Court of Appeals for the Eleventh Circuit Date:...

Abandonment on Appeal Affirms Domestic-Relations Abstention, But Abstention Dismissals Must Be Without Prejudice (11th Cir.)

Date: May 5, 2026

Abandonment on Appeal Affirms Domestic-Relations Abstention, But Abstention Dismissals Must Be Without Prejudice (11th Cir.) Case: Oleksandra Plyatsko v. Alice Benton, et al. (No. 25-11784,...

No Dixon-Like Procedural Bar in Penal Code Section 1172.6 Imputed-Malice Resentencing Petitions

Date: May 5, 2026

No Dixon-Like Procedural Bar in Penal Code Section 1172.6 Imputed-Malice Resentencing Petitions Introduction In People v. Lopez, the Supreme Court of California clarified the scope of resentencing...

State v. Flores Commentary

Date: May 5, 2026

State v. Flores: Nebraska Reaffirms That Standard Aiding-and-Abetting Instructions Suffice and Juvenile De Facto Life Sentences May Stand When the Court Has Sentencing Discretion Introduction In...

State v. Abrams: Washington Vacatur Requires Release from All Confinement and Evidence of Rehabilitation

Date: May 5, 2026

State v. Abrams: Washington Vacatur Requires Release from All Confinement and Evidence of Rehabilitation Introduction In State v. Abrams, the Washington Supreme Court interpreted RCW 9.94A.640,...

Legislature May Not Strip Louisiana Courts of Jurisdiction to Order Necessary Indigent-Defense Expert Funding

Date: May 5, 2026

Legislature May Not Strip Louisiana Courts of Jurisdiction to Order Necessary Indigent-Defense Expert Funding Case Overview Case: State of Louisiana v. Maya Jones Court: Supreme Court of Louisiana...

Fourth Circuit Confirms Three-Part McDonough Test: Juror Dishonesty and Inferred Bias Do Not Automatically Require a New Trial

Date: May 5, 2026

Fourth Circuit Confirms Three-Part McDonough Test: Juror Dishonesty and Inferred Bias Do Not Automatically Require a New Trial Introduction In United States v. Andre Williamson, the Fourth Circuit...

Foster-Care Negligence Suits Directly Concern Program Administration, Allowing Discovery of Related Child Welfare Records

Date: May 5, 2026

Foster-Care Negligence Suits Directly Concern Program Administration, Allowing Discovery of Related Child Welfare Records Introduction In J.M.I. v. State, the Washington Supreme Court addressed...

Protective-Order Violations and Repeated Surveillance Can Establish Specific Intent for Felony Stalking in Wyoming

Date: May 5, 2026

Protective-Order Violations and Repeated Surveillance Can Establish Specific Intent for Felony Stalking in Wyoming Introduction In Brent Douglas Gayman v. The State of Wyoming, 2026 WY 49, the...

Consecutive Federal Sentences May Be Reasonable When Needed to Preserve Independent Punishment for Unrelated State and Federal Crimes

Date: May 5, 2026

Consecutive Federal Sentences May Be Reasonable When Needed to Preserve Independent Punishment for Unrelated State and Federal Crimes Introduction In United States v. Isaias Pablo-Fabin, the Eleventh...

Local Ties as Legitimate Hiring Criteria for Temporary Details and the Limits of Temporal Proximity in Retaliation Claims

Date: May 5, 2026

Local Ties as Legitimate Hiring Criteria for Temporary Details and the Limits of Temporal Proximity in Retaliation Claims Introduction In Renel Sample v. OPM, the Third Circuit affirmed summary...