Puerto Rico Case Commentaries

Orders of Protection Must Defer to Existing Parenting Plans While Permitting Only Logistics-Limited Contact

Date: Jul 31, 2026

Orders of Protection Must Defer to Existing Parenting Plans While Permitting Only Logistics-Limited Contact 1. Introduction Gemar v. Gemar (Mont. 2026 MT 173N) concerns whether a district court...

Platted Express Easements Cannot Be “Supplanted” by a Non‑Signatory Easement Agreement; Obstruction Remedies Must Be Precisely Tied to Proven Encroachments

Date: Jul 31, 2026

Platted Express Easements Cannot Be “Supplanted” by a Non‑Signatory Easement Agreement; Obstruction Remedies Must Be Precisely Tied to Proven Encroachments Introduction Vicevich v. Kultgen (2026 MT...

State v. Veltkamp — SANE Reports Are Not “Medical Diagnosis” Hearsay; Jury-Room Access Is Error but May Be Harmless When Cumulative

Date: Jul 31, 2026

State v. Veltkamp (2026 MT 169): SANE Reports Are Not “Medical Diagnosis” Hearsay; Jury-Room Access Is Error but May Be Harmless When Cumulative 1. Introduction In State v. Veltkamp, the Montana...

State Tortfeasor Cannot Use Interpleader to Impose the Tort Claims Act Cap; Constitutional Challenges to § 2-9-108, MCA, Are Unripe Absent a Filed Tort Action and Excess Damages Determination

Date: Jul 31, 2026

State Tortfeasor Cannot Use Interpleader to Impose the Tort Claims Act Cap; Constitutional Challenges to § 2-9-108, MCA, Are Unripe Absent a Filed Tort Action and Excess Damages Determination 1....

Montana Lawyer Discipline: Felony Drug Convictions Trigger Rule 8.4 Charges, While Interim Suspension Requires a Separate Rule 23(B) Showing

Date: Jul 31, 2026

Montana Lawyer Discipline: Felony Drug Convictions Trigger Rule 8.4 Charges, While Interim Suspension Requires a Separate Rule 23(B) Showing 1. Introduction Matter of Kenneth B. Cotter arises from...

Service of Notice of Appeal Is Nonjurisdictional; Late Expert Declarations Cannot Be Wholly Excluded When Substantially Justified/Harmless and Supporting Properly Disclosed Malpractice Opinions

Date: Jul 31, 2026

Service of Notice of Appeal Is Nonjurisdictional; Late Expert Declarations Cannot Be Wholly Excluded When Substantially Justified/Harmless and Supporting Properly Disclosed Malpractice Opinions...

Utah Adoption Act: Termination to Facilitate Adoption Requires a “Strictly Necessary” Best-Interest Analysis Grounded in Case-Specific Stability Needs

Date: Jul 31, 2026

Utah Adoption Act: Termination to Facilitate Adoption Requires a “Strictly Necessary” Best-Interest Analysis Grounded in Case-Specific Stability Needs Introduction In re Adoption of B.C., 2026 UT 23,...

Sua Sponte Discussion Does Not Preserve an Unraised Appellate Issue Unless It Serves Judicial Economy and Fairness

Date: Jul 31, 2026

Sua Sponte Discussion Does Not Preserve an Unraised Appellate Issue Unless It Serves Judicial Economy and Fairness Introduction In Abu-Ulba v. Ananda Scientific, Inc., 2026 UT 24, the Utah Supreme...

Limiting Instructions Need Not Accompany Each Exhibit’s Publication; Drug-Related Text Messages Admissible Under Rule 404(b) to Prove Intent and Rebut “No Longer Dealing” Defense

Date: Jul 31, 2026

Limiting Instructions Need Not Accompany Each Exhibit’s Publication; Drug-Related Text Messages Admissible Under Rule 404(b) to Prove Intent and Rebut “No Longer Dealing” Defense I. Introduction In...

Rencher v. State of Mississippi Commentary

Date: Jul 30, 2026

Rencher v. State of Mississippi: Meta/AT&T Records Are Self-Authenticating Under MRE 902(11), and “Google Earth” Coordinate Plotting May Be Proven by Lay Testimony Introduction In Rencher v. State of...

Eacholes v. State of Mississippi: Verified Warrant Reliance and “Substantial Basis” Review of Probable Cause Despite No Preliminary Hearing Record

Date: Jul 30, 2026

Verified Warrant Reliance and “Substantial Basis” Review: Lack of a Preliminary-Hearing Record Does Not Undermine a Facially Valid Arrest Warrant 1. Introduction In Eacholes v. State of Mississippi...

Sanders v. State of Mississippi — Waiver of Late-Disclosed Expert/Discovery Claims Absent a Continuance Request; Timeline Uncertainty Does Not Defeat Child Sex-Offense Proof

Date: Jul 30, 2026

Waiver of Late-Disclosed Expert/Discovery Claims Without a Continuance Request; Timeline Uncertainty Does Not Defeat Child Sex-Offense Proof Case: Sanders v. State of Mississippi (No....

Certified MDH HIV Surveillance Records Are Nontestimonial; § 97-27-14(1) Requires No Proof of Viral Load or Transmission Likelihood

Date: Jul 30, 2026

Certified MDH HIV Surveillance Records Are Nontestimonial; § 97-27-14(1) Requires No Proof of Viral Load or Transmission Likelihood Case: Sims v. State of Mississippi, Supreme Court of Mississippi...

Post-Appeal Release and Mootness: Disputed Settlement Facts Require District-Court Determination Before Merits Review

Date: Jul 30, 2026

Post-Appeal Release and Mootness: Disputed Settlement Facts Require District-Court Determination Before Merits Review 1. Introduction Tammy Russell v. U.S. Dep't of Treasury (6th Cir. July 29, 2026)...

Anti-Waiver Statutes Do Not Preempt Forum Choice-of-Law: Kentucky’s § 188 “Most Significant Relationship” Test Governs Sales-Representative Termination Disputes

Date: Jul 30, 2026

Anti-Waiver Statutes Do Not Preempt Forum Choice-of-Law: Kentucky’s § 188 “Most Significant Relationship” Test Governs Sales-Representative Termination Disputes Case: Bonfiglioli USA, Inc. v. Midwest...

Renewing Rule 29 Motions to Preserve Sufficiency Claims and Treating Digital-Forensics Disputes as Weight (Not Admissibility)

Date: Jul 30, 2026

Renewing Rule 29 Motions to Preserve Sufficiency Claims and Treating Digital-Forensics Disputes as Weight (Not Admissibility) Introduction In United States v. Scott Nelson (6th Cir. July 29, 2026)...

United States v. Khari Qunarll Smith (6th Cir. 2026) Commentary

Date: Jul 30, 2026

Judicial “Testimony” Under Rule 605 Is Subject to Rule 52(a) Harmless-Error Review Requiring an Effect on Substantial Rights United States v. Khari Qunarll Smith (with co-appellants Saruba Asante...

Sixth Circuit Establishes Harmless-Error Framework for Rule 605 Judicial “Testimony” and Clarifies Sentencing/Drug-Premises Applications

Date: Jul 30, 2026

Sixth Circuit Establishes a “Substantial Rights” Harmless-Error Standard for Rule 605 Judicial “Testimony” (and Remands Where a Mandatory Guideline Reduction Was Omitted) 1. Introduction United...

Amended Judgments After § 2255: Direct Appeal Permitted, But ACCA Error Can Be Harmless and “Ransom” Includes Family-Hostage Demands

Date: Jul 30, 2026

Amended Judgments After § 2255: Direct Appeal Permitted, But ACCA Error Can Be Harmless and “Ransom” Includes Family-Hostage Demands 1. Introduction United States v. Michael Benanti (6th Cir. July...

Rule 605 Judicial-“Testimony” Error Is Subject to Rule 52(a) Harmless-Error Review (Substantial-Rights Standard)

Date: Jul 30, 2026

Rule 605 Judicial-“Testimony” Error Is Subject to Rule 52(a) Harmless-Error Review (Substantial-Rights Standard) 1. Introduction United States v. Chanel Lashae Logan (consolidated appeals involving...