Puerto Rico Case Commentaries

Advisory Fishery Councils Do Not Cause Appointments Clause Injury When the Secretary Independently Promulgates Binding Rules

Date: May 5, 2026

Advisory Fishery Councils Do Not Cause Appointments Clause Injury When the Secretary Independently Promulgates Binding Rules Introduction In New England Fishermen's Stewardship Association v....

Ambiguous Lack-of-Remorse Remarks Do Not Establish Plain Error in Above-Guidelines Sentencing

Date: May 5, 2026

Ambiguous Lack-of-Remorse Remarks Do Not Establish Plain Error in Above-Guidelines Sentencing Introduction In United States v. Rodriguez, the Fifth Circuit affirmed an above-guidelines sentence...

Reverse FCA Liability Requires an Immediate Duty to Pay: No Claim for Unapplied-For Visa Fees or Taxes on Unpaid Wages

Date: May 5, 2026

Reverse FCA Liability Requires an Immediate Duty to Pay: No Claim for Unapplied-For Visa Fees or Taxes on Unpaid Wages Introduction In Palmer v. Tata Consulting Services, the Fifth Circuit affirmed...

Prior Supervised-Release Status Is Not Intrinsic Evidence Without a Direct Nexus to the Charged Crime

Date: May 5, 2026

Prior Supervised-Release Status Is Not Intrinsic Evidence Without a Direct Nexus to the Charged Crime Introduction In State of West Virginia v. Jeffrey John Paglia, the Supreme Court of Appeals of...

Conditional Nolle Prosequi Agreements Are Governed by Ordinary Contract Principles

Date: May 5, 2026

Conditional Nolle Prosequi Agreements Are Governed by Ordinary Contract Principles Introduction In State of Arkansas v. Luis Ramirez, 2026 Ark. 92, the Supreme Court of Arkansas addressed a novel...

No Abuse of Discretion Where Juvenile Recidivism Supports Denial of a Youth-Based Sentencing Variance

Date: May 5, 2026

No Abuse of Discretion Where Juvenile Recidivism Supports Denial of a Youth-Based Sentencing Variance Introduction In United States v. Derrion Turner, the Sixth Circuit affirmed a 246-month federal...

Terminated Conditional Permanent Residents Cannot Use Prior Five-Year Status to Obtain Cancellation of Removal

Date: May 5, 2026

Terminated Conditional Permanent Residents Cannot Use Prior Five-Year Status to Obtain Cancellation of Removal Introduction In Ghazi v. Blanche, the Fifth Circuit reviewed a petition by Said Ghazi, a...

Gang Extortion Claims Fail Absent Proof That Protected Status Motivated the Threats

Date: May 5, 2026

Gang Extortion Claims Fail Absent Proof That Protected Status Motivated the Threats Introduction In Iris Rodriguez Martinez v. Attorney General United States of America, the United States Court of...

First Circuit: Upward Variance Cannot Rest on 31 Rounds of Ammunition or Unsupported “Firearms of War” Facts

Date: May 5, 2026

First Circuit: Upward Variance Cannot Rest on 31 Rounds of Ammunition or Unsupported “Firearms of War” Facts Introduction In United States v. Rosa-Borges, the First Circuit revisited two sentences...

Postconviction DNA “Results” Include Underlying Data Needed for Statistical Analysis

Date: May 5, 2026

Postconviction DNA “Results” Include Underlying Data Needed for Statistical Analysis Introduction In James Aren Duckett v. State of Florida, the Supreme Court of Florida addressed whether a...

No Merits Ruling Without Jurisdiction: Insubstantial Federal Claims Must Be Dismissed Without Prejudice

Date: May 5, 2026

No Merits Ruling Without Jurisdiction: Insubstantial Federal Claims Must Be Dismissed Without Prejudice Introduction In James Giehl v. Ocwen Financial Corporation, the Eleventh Circuit reviewed a...

In re Kowalczyk: California Bail May Be Denied Only Under Article I, Section 12 and Must Generally Be Reasonably Attainable

Date: May 4, 2026

In re Kowalczyk: California Bail May Be Denied Only Under Article I, Section 12 and Must Generally Be Reasonably Attainable Introduction In In re Kowalczyk, the Supreme Court of California resolved...

Felony Stalking Can Supply the “Any Felony” Intent Element for Nebraska Burglary

Date: May 4, 2026

Felony Stalking Can Supply the “Any Felony” Intent Element for Nebraska Burglary Introduction In State v. Dicken, the Nebraska Supreme Court affirmed Michael M. Dicken’s plea-based conviction and...

Martinez Reports May Not Defeat Well-Pleaded Prisoner Claims at § 1915A Screening

Date: May 4, 2026

Martinez Reports May Not Defeat Well-Pleaded Prisoner Claims at § 1915A Screening Introduction In Martin v. Schnurr, the Tenth Circuit reversed the dismissal of a Kansas prisoner’s civil-rights...

Mechanistic Discipline Under Detailed Policies Does Not Establish NLRA Supervisory Status

Date: May 4, 2026

Mechanistic Discipline Under Detailed Employer Policies Does Not Establish NLRA Supervisory Status Introduction In Universal Protection Services, LLC v. National Labor Relations Board, the Eleventh...

Preventive Detention Under 13 V.S.A. § 7553a Requires Clear, Particularized Proof That No Release Conditions Can Prevent Violence

Date: May 4, 2026

Preventive Detention Under 13 V.S.A. § 7553a Requires Clear, Particularized Proof That No Release Conditions Can Prevent Violence Introduction In State v. Cameron Waite, the Vermont Supreme Court...

Reaffirming Reinhart: Nolle Prosequi Requires a Valid and Reasonable Basis, Not Ajaj Deference

Date: May 4, 2026

Reaffirming Reinhart: Nolle Prosequi Requires a Valid and Reasonable Basis, Not Ajaj Deference Introduction In Commonwealth, Aplt. v. Harrison, the Supreme Court of Pennsylvania addressed the...

Post-Starbucks § 10(j) Injunctions Require Independent Proof of Irreparable Harm

Date: May 4, 2026

Post-Starbucks § 10(j) Injunctions Require Independent Proof of Irreparable Harm Introduction In Elizabeth Kerwin v. Trinity Health Grand Haven Hosp., the Sixth Circuit addressed, for the first time...

Warhol Does Not Require Targeting: Brief Documentary Use of Public Factual Footage Can Be Transformative Fair Use

Date: May 4, 2026

Warhol Does Not Require Targeting: Brief Documentary Use of Public Factual Footage Can Be Transformative Fair Use Introduction In Whyte Monkee Productions v. Netflix, the Tenth Circuit affirmed...

Corroborated Accomplice Testimony and Lewis-Compliant Jury Instructions Sustain Felony-Murder Conviction

Date: May 4, 2026

Corroborated Accomplice Testimony and Lewis-Compliant Jury Instructions Sustain Felony-Murder Conviction Introduction In State v. Maldonado, the Supreme Court of New Mexico affirmed Christopher...