Puerto Rico Case Commentaries

CPLR 3211(a)(7) Dismissal Is Not Merits-Based for Preclusion When a Later Complaint Cures Defects; Excessive Fees Support a Distinct Fiduciary-Duty Claim

Date: Aug 28, 2026

CPLR 3211(a)(7) Dismissal Is Not Merits-Based for Preclusion When a Later Complaint Cures Defects; Excessive Fees Support a Distinct Fiduciary-Duty Claim 1. Introduction Katsoris v Bodnar & Milone,...

CPLR 306-b “Good Cause” Clarified: Reasonable Diligence Can Mandate an Extension, and Courts May Grant It Before a Traverse Hearing

Date: Aug 28, 2026

CPLR 306-b “Good Cause” Clarified: Reasonable Diligence Can Mandate an Extension, and Courts May Grant It Before a Traverse Hearing Case: M&T Bank v Global Sign Cleaning & Maintenance, Inc. (App....

Matter of Bitterman: New York Reciprocal Discipline Gives Significant Weight to the Foreign Sanction and Imposes Matching Public Censure

Date: Aug 28, 2026

Matter of Bitterman: New York Reciprocal Discipline Gives Significant Weight to the Foreign Sanction and Imposes Matching Public Censure 1. Introduction Matter of Bitterman (Appellate Division,...

Reciprocal Discipline Under 22 NYCRR 1240.13: New York Will Publicly Censure to Match a Foreign Public Reprimand When No Statutory Defenses Are Shown

Date: Aug 28, 2026

Reciprocal Discipline Under 22 NYCRR 1240.13: New York Will Publicly Censure to Match a Foreign Public Reprimand When No Statutory Defenses Are Shown 1. Introduction Matter of Cosentino (2026 NY Slip...

Non–Self-Executing Discovery Orders Are Not Conditional Preclusion Orders; Disclosure Motions Must Include 22 NYCRR 202.7 Good-Faith Affirmation and a Specific, Willfulness-Based Record for CPLR 3126 Sanctions

Date: Aug 28, 2026

Non–Self-Executing Discovery Orders Are Not Conditional Preclusion Orders; Disclosure Motions Must Include 22 NYCRR 202.7 Good-Faith Affirmation and a Specific, Willfulness-Based Record for CPLR 3126...

Dismissal for Failure of a Condition Precedent Defeats Acceleration for Limitations Purposes; RPAPL 1304 “Amount in Default” Discrepancies Bar Foreclosure Summary Judgment

Date: Aug 28, 2026

Dismissal for Failure of a Condition Precedent Defeats Acceleration for Limitations Purposes; RPAPL 1304 “Amount in Default” Discrepancies Bar Foreclosure Summary Judgment 1. Introduction In...

Finality in Vermont Judicial Foreclosures: An Unappealed Foreclosure Decree Cannot Be Attacked via an Appeal from the Sale Confirmation Order

Date: Aug 28, 2026

Finality in Vermont Judicial Foreclosures: An Unappealed Foreclosure Decree Cannot Be Attacked via an Appeal from the Sale Confirmation Order Case: Colonial Savings, FA v. Adam Huntley Court: Supreme...

“Until Such Time” Means No HOA Assessments or Voting Rights for Developer-Owned Undeveloped Lots Absent Road and Sewer Extensions—Ambiguous Lot Schedules Require Factfinding

Date: Aug 28, 2026

“Until Such Time” Means No HOA Assessments or Voting Rights for Developer-Owned Undeveloped Lots Absent Road and Sewer Extensions—Ambiguous Lot Schedules Require Factfinding Introduction In Hawk...

Partial Case-Plan Compliance Does Not Bar Termination at Initial Disposition When the Parent Cannot Resume Parenting Within a Reasonable Time

Date: Aug 28, 2026

Partial Case-Plan Compliance Does Not Bar Termination at Initial Disposition When the Parent Cannot Resume Parenting Within a Reasonable Time Introduction Case: In re J.B. Jr., A.B., B.B., E.B.,...

Bourdeau Bros., Inc. v. St. Pierre (2026 VT 38) — Novation Requires Proof the Creditor Agreed to Release a Co-Obligor

Date: Aug 28, 2026

Novation Requires Proof the Creditor Clearly Agreed to Release a Co-Obligor (and Unpreserved Equitable Claims Stay Waived) Case: Bourdeau Bros., Inc. v. Melissa St. Pierre and Jason St. Pierre, 2026...

In re D.P.: “Support” Is Not “Treatment,” and Parental Stagnation (Not Agency Friction) Justifies Post-Disposition Termination

Date: Aug 28, 2026

In re D.P.: “Support” Is Not “Treatment,” and Parental Stagnation (Not Agency Friction) Justifies Post-Disposition Termination 1. Introduction Case: In re D.P., Juvenile (Vt. Sup. Ct. Aug. 21, 2026)...

Actual Notice, Harmless Service Errors, and Late ICPC Requests Do Not Defeat Termination Where Parental Stagnation Persists

Date: Aug 28, 2026

Actual Notice, Harmless Service Errors, and Late ICPC Requests Do Not Defeat Termination Where Parental Stagnation Persists Decision: In re L.V., Juvenile (K.V., Mother* and J.S., Father*), Vermont...

Subdivision Access Litigation: Environmental Division May Decide Fee Ownership/Right-of-Way Over a Discontinued Road, and Unrebutted Rule 56 Fact Statements Control

Date: Aug 28, 2026

Subdivision Access Litigation: Environmental Division May Decide Fee Ownership/Right-of-Way Over a Discontinued Road, and Unrebutted Rule 56 Fact Statements Control Case: In Re Ranney Dairy Farm, LLC...

Nonprecedential Entry Order Reinforcing Appellate Standing, Issue Preservation, and Proof of Habitability Damages in Vermont Eviction Litigation

Date: Aug 28, 2026

Nonprecedential Entry Order Reinforcing Appellate Standing, Issue Preservation, and Proof of Habitability Damages in Vermont Eviction Litigation Introduction In Juliet Stephens v. Shannon Gilmour...

Rule 59(e) Cannot Cure Unraised Consolidation Errors; Courts Need Not Judicially Notice RFA Findings to Reshape PCC in Divorce

Date: Aug 28, 2026

Rule 59(e) Cannot Cure Unraised Consolidation Errors; Courts Need Not Judicially Notice RFA Findings to Reshape PCC in Divorce I. Introduction Shamitra Lefebvre (Mother) appealed a final divorce...

State v. Harry Williams: “Private-Vicinity Proximity” as Prohibited Minor Contact and “Maintain” as Failure to Disengage

Date: Aug 28, 2026

State v. Harry Williams: “Private-Vicinity Proximity” as Prohibited Minor Contact and “Maintain” as Failure to Disengage Court: Supreme Court of Vermont (Entry Order) | Date: 2026-08-21 | Case No.:...

Late-Disclosed Body-Camera Evidence Does Not Warrant a New Trial Absent Concrete Prejudice; Intoxication Videos Not Excluded Under Rules 403/404(b)

Date: Aug 28, 2026

Late-Disclosed Body-Camera Evidence Does Not Warrant a New Trial Absent Concrete Prejudice; Intoxication Videos Not Excluded Under Rules 403/404(b) Introduction In State v. Lucas Avis (Vt. Sup. Ct....

IIED Causation Requires Non-Speculative Proof Where Plaintiff Has Preexisting Mental-Health Symptoms

Date: Aug 28, 2026

IIED Causation Requires Non-Speculative Proof Where Plaintiff Has Preexisting Mental-Health Symptoms 1. Introduction In Todd Ramos v. Thomas Shea (Vt. Aug. 21, 2026) (Entry Order), the Vermont...

Adjunct Faculty Unemployment: The “Regular but Not Successive Terms” Exclusion Applies When Spring–Fall Work Is Agreed and Fall Work Is Reasonably Assured

Date: Aug 28, 2026

Adjunct Faculty Unemployment: The “Regular but Not Successive Terms” Exclusion Applies When Spring–Fall Work Is Agreed and Fall Work Is Reasonably Assured 1. Introduction In Vermont State Colleges v....

La Frontera Center v. United Behavioral Health: Appellate Waiver, Record-Citation Defaults, and Harmless-Error Affirmance in FCA/FATA Scienter Litigation

Date: Aug 28, 2026

Appellate Waiver, Record-Citation Defaults, and Harmless-Error Affirmance in FCA/FATA Scienter Litigation Case: La Frontera Center v. United Behavioral Health (No. 25-2099) Court: United States Court...