Puerto Rico Case Commentaries

Martinez Excuses Default, But § 2254(e)(2) Requires Claim-Specific Diligence: An Unrelated State Hearing Request Won’t Unlock a Federal Evidentiary Hearing

Date: Sep 2, 2026

Martinez Excuses Default, But § 2254(e)(2) Requires Claim-Specific Diligence: An Unrelated State Hearing Request Won’t Unlock a Federal Evidentiary Hearing 1. Introduction Orlando Hernandez v....

Mootness Requires Munsingwear Vacatur When a Restitution-Lien Expiration Dispute Becomes Nonjusticiable on Appeal

Date: Sep 2, 2026

Mootness Requires Munsingwear Vacatur When a Restitution-Lien Expiration Dispute Becomes Nonjusticiable on Appeal 1. Introduction In Ralph Pinson v. United States (11th Cir. Aug. 31, 2026) (per...

Residential High-Speed Flight (and Discarding a Loaded Firearm) Supports U.S.S.G. § 3C1.2 Based on Reliable Video Evidence

Date: Sep 2, 2026

Residential High-Speed Flight (and Discarding a Loaded Firearm) Supports U.S.S.G. § 3C1.2 Based on Reliable Video Evidence Introduction In United States v. Sherron Gary (11th Cir. Aug. 31, 2026)...

Displaced Corporate Managers Cannot Assert Company Privilege; Loan-Fraud “Loss” Does Not Require Personal Gain; Restitution Offset Appeals Become Moot Once Credit Is Applied

Date: Sep 2, 2026

Displaced Corporate Managers Cannot Assert Company Privilege; Loan-Fraud “Loss” Does Not Require Personal Gain; Restitution Offset Appeals Become Moot Once Credit Is Applied 1. Introduction Case:...

Eleventh Circuit Clarifies That Routine Supervision, Non-Impactful Evaluations, and Delayed Resignations Do Not Support Title VII Retaliation or Constructive Discharge

Date: Sep 2, 2026

Eleventh Circuit Clarifies That Routine Supervision, Non-Impactful Evaluations, and Delayed Resignations Do Not Support Title VII Retaliation or Constructive Discharge Introduction In William Gary v....

Public High School Classroom Displays Are Garcetti “Official-Duties” Speech (Government Speech) in the Second Circuit

Date: Sep 2, 2026

Public High School Classroom Displays Are Garcetti “Official-Duties” Speech (Government Speech) in the Second Circuit Case: Dolce v. Connetquot Cent. Sch. Dist. (2d Cir. Aug. 31, 2026) Court: United...

Revenue Rule Does Not Bar Foreign Tax Authority’s Fraud Suit to Recover Refund Payments Where No Tax Was Owed

Date: Sep 2, 2026

Revenue Rule Does Not Bar Foreign Tax Authority’s Fraud Suit to Recover Refund Payments Where No Tax Was Owed 1. Introduction Skatteforvaltningen v. Markowitz (2d Cir. Aug. 31, 2026) is a bellwether...

Widespread Publicity as Constructive Discovery: Utah Fraud Claims May Be Time-Barred on a Rule 12(b)(6) Motion

Date: Sep 2, 2026

Widespread Publicity as Constructive Discovery: Utah Fraud Claims May Be Time-Barred on a Rule 12(b)(6) Motion 1. Introduction In In re: THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS TITHING...

Firearms Are Possessed “In Connection With” Another Felony When They Are Part of a Plan-to-Harm Scheme and Embolden Its Execution

Date: Sep 2, 2026

Firearms Are Possessed “In Connection With” Another Felony When They Are Part of a Plan-to-Harm Scheme and Embolden Its Execution Introduction United States v. Dutton (10th Cir. Aug. 31, 2026) is a...

Interlocutory Appeals Require Explicit Designation of Each Appealable Order Under FRAP 3(c)(1)(B); “Merger” Does Not Save an Omitted Preliminary-Injunction Order

Date: Sep 2, 2026

Interlocutory Appeals Require Explicit Designation of Each Appealable Order Under FRAP 3(c)(1)(B); “Merger” Does Not Save an Omitted Preliminary-Injunction Order Case: Utah Vapor Business Association...

Quasi-Judicial Immunity Is Personal-Only; Rule 32 “Other Copying” Fees Must Conform to I.C. § 74-102(10)

Date: Sep 2, 2026

Quasi-Judicial Immunity Is Personal-Only; Rule 32 “Other Copying” Fees Must Conform to I.C. § 74-102(10) Introduction In BRYAN D. SMITH v. CHRIS POULTER IN HIS CAPACITY AS BONNEVILLE COUNTY CLERK,...

APA Review of ESA Fishery Rules: Substantial Evidence and Notice-and-Comment Limits on Post‑Hoc Data

Date: Sep 2, 2026

APA Review of ESA Fishery Rules: Substantial Evidence and Notice-and-Comment Limits on Post‑Hoc Data Case: LA Shrimp Association v. Lutnick (5th Cir. Aug. 28, 2026) (unpublished) Court: United States...

Cisco Closes the Sosa Door: Alien Tort Statute Claims Limited to the “Blackstone Three”

Date: Sep 2, 2026

Cisco Closes the Sosa Door: Alien Tort Statute Claims Limited to the “Blackstone Three” 1. Introduction In Suhail Al Shimari v. CACI Premier Technology, Inc., No. 25-1043 (4th Cir. Aug. 28, 2026)...

IDEA Initial Evaluations Require All-or-Nothing Parental Consent; No FAPE Duty (and Duplicative ADA Relief) Without Consent

Date: Sep 2, 2026

IDEA Initial Evaluations Require All-or-Nothing Parental Consent; No FAPE Duty (and Duplicative ADA Relief) Without Consent I. Introduction In M. v. Aledo Independent School District (5th Cir. Aug....

Ambiguous Intoxication and Self-Inflicted Head Strikes: Qualified Immunity Absent Clearly Established Duty to Obtain Medical Care

Date: Sep 2, 2026

Ambiguous Intoxication and Self-Inflicted Head Strikes: Qualified Immunity Absent Clearly Established Duty to Obtain Medical Care Introduction Pena v. Starr County, Texas (5th Cir. Aug. 28, 2026)...

HRS § 12-8 as the Exclusive Pre‑Election Vehicle for Candidate-Eligibility Disputes; “Elected To” Term Limits Count Fixed Charter Terms Despite Delayed Swearing-In

Date: Sep 2, 2026

HRS § 12-8 as the Exclusive Pre‑Election Vehicle for Candidate-Eligibility Disputes; “Elected To” Term Limits Count Fixed Charter Terms Despite Delayed Swearing-In 1. Introduction Iwasa v. Nago...

McDonald v. United States (1st Cir. Aug. 28, 2026) — Davis § 924(c) General Verdicts Are Reviewed for Brecht Harmless Error (Not the Categorical Approach) and COAs Do Not Lie for Remedy-Choice Complaints Without a Constitutional Hook

Date: Sep 2, 2026

Davis § 924(c) General Verdicts Are Reviewed for Brecht Harmless Error (Not the Categorical Approach) and COAs Do Not Lie for Remedy-Choice Complaints Without a Constitutional Hook 1. Introduction...

Mass-Shooting Negligence Claims Trigger Assault-and-Battery Sublimits; Settlement Paying the Sublimit Exhausts Coverage and Ends the Insurer’s Defense Duty

Date: Sep 2, 2026

Mass-Shooting Negligence Claims Trigger Assault-and-Battery Sublimits; Settlement Paying the Sublimit Exhausts Coverage and Ends the Insurer’s Defense Duty Introduction Case: James River Insurance...

Emergency-Aid Seizures for Mental-Health Crises Are Judged Objectively (Not by Officer Motive), and Speculative “Muted Bodycam” Theories Cannot Defeat Qualified Immunity at the Pleading Stage

Date: Sep 2, 2026

Emergency-Aid Seizures for Mental-Health Crises Are Judged Objectively (Not by Officer Motive), and Speculative “Muted Bodycam” Theories Cannot Defeat Qualified Immunity at the Pleading Stage Case:...

Conceding ACCA Applicability at Sentencing “Invites” Predicate-Classification Error; Post-Erlinger Plain-Error Relief Requires Showing a Real Chance a Jury Would Find a Single Occasion

Date: Sep 2, 2026

Conceding ACCA Applicability at Sentencing “Invites” Predicate-Classification Error; Post-Erlinger Plain-Error Relief Requires Showing a Real Chance a Jury Would Find a Single Occasion Introduction...