Puerto Rico Case Commentaries

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...

Midstream Miranda in the Sixth Circuit: “Genuine Choice” Controls, Officer Intent Is Irrelevant, and No Duty Exists to Disclaim the Earlier Unwarned Confession

Date: Jul 30, 2026

Midstream Miranda in the Sixth Circuit: “Genuine Choice” Controls, Officer Intent Is Irrelevant, and No Duty Exists to Disclaim the Earlier Unwarned Confession Case: United States v. Jarvis Clayborn...

Strategic Open-Plea Advice Is Not Ineffective Assistance Absent Unreasonableness; Unpreserved Rule 43 Claims Are Not Reviewed

Date: Jul 29, 2026

Strategic Open-Plea Advice Is Not Ineffective Assistance Absent Unreasonableness; Unpreserved Rule 43 Claims Are Not Reviewed 1. Introduction In Paola v. State, 2026 ND 151, Tayven Lynn Paola sought...

Childers v. Childers (2026 ND 150): Stipulated Post-Hearing Income Submissions Permit Supplemental Evidence, but Income Imputation Requires a Purpose Finding and Effective-Date Explanation

Date: Jul 29, 2026

Stipulated Post-Hearing Income Submissions Permit Supplemental Evidence, but Income Imputation Requires a Purpose Finding and Effective-Date Explanation 1. Introduction Childers v. Childers, 2026 ND...

Res Judicata Does Not Bar Later “Offset” Claims After a Default Judgment; CPLR 205(a) May Save Refiled Former Counterclaims

Date: Jul 29, 2026

Res Judicata Does Not Bar Later “Offset” Claims After a Default Judgment; CPLR 205(a) May Save Refiled Former Counterclaims Case: Vince's Pizza Plus, Inc. v. Dion DeFedericis, 2026 NY Slip Op 04598...

RPTL 497(2) Makes NYSERDA Filing Non-Precondition to Effectiveness of RPTL 487 Solar-Exemption Opt-Out Laws (and Applies Retroactively)

Date: Jul 29, 2026

RPTL 497(2) Makes NYSERDA Filing Non-Precondition to Effectiveness of RPTL 487 Solar-Exemption Opt-Out Laws (and Applies Retroactively) 1. Introduction Matter of Solar Advocate Dev., LLC v Assessor...

Hayseeds “Necessity” Requires Insured Cooperation and Meaningful Demand; Bankruptcy-Related Noncooperation Defeats Fee-Shifting

Date: Jul 29, 2026

Hayseeds “Necessity” Requires Insured Cooperation and Meaningful Demand; Bankruptcy-Related Noncooperation Defeats Fee-Shifting Introduction In Bristol Springs Custom Homes, LLC v. Argos Group US,...

Hayseeds “Necessity” Requires More Than Post-Suit Settlement Timing; West Virginia UTPA Subsections (b), (c), (d), (f), (g), and (m) Remain Unavailable to Insureds

Date: Jul 29, 2026

Hayseeds “Necessity” Requires More Than Post-Suit Settlement Timing; West Virginia UTPA Subsections (b), (c), (d), (f), (g), and (m) Remain Unavailable to Insureds Introduction In Bristol Springs...

Equitable Tolling Requires Concrete Diligence in EEOC Filings; Ethnic “Food/Language” Remarks Alone May Not Meet § 1981 Hostile-Environment Threshold

Date: Jul 29, 2026

Equitable Tolling Requires Concrete Diligence in EEOC Filings; Ethnic “Food/Language” Remarks Alone May Not Meet § 1981 Hostile-Environment Threshold 1. Introduction In Raymond Rodriguez v. Loyal...

Excess Insurers Cannot Demur Solely for Non-Exhaustion: Declaratory Relief and Bad-Faith Claims May Proceed Upon Adequate Allegations of Covered Loss and Likely Attachment

Date: Jul 29, 2026

Excess Insurers Cannot Demur Solely for Non-Exhaustion: Declaratory Relief and Bad-Faith Claims May Proceed Upon Adequate Allegations of Covered Loss and Likely Attachment Case: Fox Paine & Co, LLC...

DVSJA “Significant Contributing Factor” Requires Evidence Linking Abuse to the Criminal Act—Childhood Trauma Alone Is Insufficient

Date: Jul 29, 2026

DVSJA “Significant Contributing Factor” Requires Evidence Linking Abuse to the Criminal Act—Childhood Trauma Alone Is Insufficient 1. Introduction People v Sean S. (Appellate Division, Fourth...

State v. Keaton: An Unqualified “No Objection” Waives Confrontation and Right-to-Counsel Claims and Limits Supervisory Relief

Date: Jul 29, 2026

An Unqualified “No Objection” Waives Confrontation and Right-to-Counsel Claims and Limits Supervisory Relief 1. Introduction In State v. Keaton (Conn. July 28, 2026), the Supreme Court of Connecticut...

People v. Kadenhead: Common-Hallway Arrests Do Not Trigger Payton, and “Last-Seen” Video Evidence Can Supply Probable Cause Despite Timestamp Error

Date: Jul 29, 2026

People v. Kadenhead: Common-Hallway Arrests Do Not Trigger Payton, and “Last-Seen” Video Evidence Can Supply Probable Cause Despite Timestamp Error Court: Appellate Division, Fourth Department...

People v. Riley: Circumstantial Evidence and “Natural and Probable Consequences” Permit an Intent-to-Kill Inference for Accessorial Second-Degree Murder; Strategic Avoidance of Inconsistent Defenses Is Not Ineffective Assistance

Date: Jul 29, 2026

People v. Riley: Circumstantial Evidence and “Natural and Probable Consequences” Permit an Intent-to-Kill Inference for Accessorial Second-Degree Murder; Strategic Avoidance of Inconsistent Defenses...

BOLO Plus “Arrest Paperwork” and Victim Identification Can Supply Reasonable Suspicion and Probable Cause; Inventory-Search/Impoundment and Miranda Rulings Deferentially Upheld

Date: Jul 29, 2026

BOLO Plus “Arrest Paperwork” and Victim Identification Can Supply Reasonable Suspicion and Probable Cause; Inventory-Search/Impoundment and Miranda Rulings Deferentially Upheld 1. Introduction In...

Ingram v Cuba Mem. Hosp., Inc.: Defendants Must Establish Each Summary-Judgment Element (Including Causation) and Cannot Win Article 28 Dismissal Where Their Own Proof Raises Fact Issues

Date: Jul 29, 2026

Ingram v Cuba Mem. Hosp., Inc.: Defendants Must Establish Each Summary-Judgment Element (Including Causation) and Cannot Win Article 28 Dismissal Where Their Own Proof Raises Fact Issues 1....

Passenger’s Justification in a Vehicle Shootout: Failure to Disprove Safe Retreat Warrants Weight-of-Evidence Reversal of Second-Degree Manslaughter (People v Major)

Date: Jul 29, 2026

Passenger’s Justification in a Vehicle Shootout: Failure to Disprove Safe Retreat Warrants Weight-of-Evidence Reversal of Second-Degree Manslaughter (People v Major) 1. Introduction In People v Major...

Invalid Appeal Waiver Does Not Bar Suppression Review; De Bour Escalation Upheld Based on Dispatch/Order-of-Protection Information and Traffic-Violation Probable Cause

Date: Jul 29, 2026

Invalid Appeal Waiver Does Not Bar Suppression Review; De Bour Escalation Upheld Based on Dispatch/Order-of-Protection Information and Traffic-Violation Probable Cause 1. Introduction In People v...

Irrelevant Evidence Before the Grand Jury Does Not Automatically Defect the Indictment Absent Pervasive, Willful Prosecutorial Misconduct

Date: Jul 29, 2026

Irrelevant Evidence Before the Grand Jury Does Not Automatically Defect the Indictment Absent Pervasive, Willful Prosecutorial Misconduct Case: People v. Stencel, 2026 NY Slip Op 04574 (App Div, 4th...

§ 922(g)(1) As-Applied Challenges: Government Must Prove a Founding-Era Tradition for Disarming Property-Crime Felons and May Not Substitute “Dangerousness” Factfinding for the Predicate

Date: Jul 29, 2026

§ 922(g)(1) As-Applied Challenges: Government Must Prove a Founding-Era Tradition for Disarming Property-Crime Felons and May Not Substitute “Dangerousness” Factfinding for the Predicate I....