Puerto Rico Case Commentaries

U.S.S.G. § 1B1.2(d) Cannot Apply Without a Beyond-a-Reasonable-Doubt Finding That the Defendant Conspired to Each Object Offense

Date: Jul 24, 2026

U.S.S.G. § 1B1.2(d) Cannot Apply Without a Beyond-a-Reasonable-Doubt Finding That the Defendant Conspired to Each Object Offense Case: United States v. Katrail Bridges (7th Cir. July 21, 2026)...

Matter of Douglas Marshall — Text Messages Are Not a “Signed” Contingent-Fee Agreement Absent Client Adoption

Date: Jul 24, 2026

Matter of Douglas Marshall: Text Messages Do Not Satisfy Montana’s “Signed Writing” Requirement for Contingent-Fee Agreements Without Client Adoption 1. Introduction Matter of Douglas Marshall is a...

Claim Preclusion Bars Post-Judgment Tort Claims Against an Estate and Its Personal Representative Acting Only in a Fiduciary Capacity

Date: Jul 24, 2026

Claim Preclusion Bars Post-Judgment Tort Claims Against an Estate and Its Personal Representative Acting Only in a Fiduciary Capacity 1. Introduction Kahle v. Estate of Tosch (Mont. 2026 MT 159N) is...

State v. Reed: No Ineffective Assistance Absent Prejudice Where Evidence Does Not Support a Lesser-Included Instruction; Bail-Jumping “Lawful Excuse” Survives Vagueness Challenge Under Trombley

Date: Jul 24, 2026

State v. Reed: No Ineffective Assistance Absent Prejudice Where Evidence Does Not Support a Lesser-Included Instruction; Bail-Jumping “Lawful Excuse” Survives Vagueness Challenge Under Trombley 1....

ICWA Diligent Inquiry and IAC in Termination: Tattoos and Speculative Parole Dates Do Not Undermine Termination Under § 41-3-609(4)(c), MCA

Date: Jul 24, 2026

ICWA Diligent Inquiry and IAC in Termination: Tattoos and Speculative Parole Dates Do Not Undermine Termination Under § 41-3-609(4)(c), MCA Introduction Matter of D.J.L. and R.J.M., Youths in Need of...

Affirmance Despite an Incomplete Batson Step-Three Inquiry Where the Record Shows No Discriminatory Intent

Date: Jul 24, 2026

Affirmance Despite an Incomplete Batson Step-Three Inquiry Where the Record Shows No Discriminatory Intent Introduction In MOTLEY (COURTNEY) v. STATE (CRIMINAL), No. 88757 (Nev. July 23, 2026), the...

Repeated Violations and Concealment of Court-Order Breaches Can Establish “Risk of Flight” Justifying Monetary Bail Under 13 V.S.A. § 7554

Date: Jul 24, 2026

Repeated Violations and Concealment of Court-Order Breaches Can Establish “Risk of Flight” Justifying Monetary Bail Under 13 V.S.A. § 7554 1. Introduction In State of Vermont v. Dennis McLaughlin...

Striking an Adjudication of Guilt Under a Deferred Sentence Is Not “Reversal or Vacatur” for Automatic Reinstatement from Interim Suspension (A.O. 9, Rule 21(F))

Date: Jul 24, 2026

Striking an Adjudication of Guilt Under a Deferred Sentence Is Not “Reversal or Vacatur” for Automatic Reinstatement from Interim Suspension (A.O. 9, Rule 21(F)) Case: In re Eva Vekos, Esq. (Office...

Florida Death-Warrant Litigation: Rule 3.852 Records Require a Nexus to a Colorable Claim; Speculative Lethal-Injection, Elderly, and “Execution-Pace” Challenges Are Not Cognizable

Date: Jul 23, 2026

Florida Death-Warrant Litigation: Rule 3.852 Records Require a Nexus to a Colorable Claim; Speculative Lethal-Injection, Elderly, and “Execution-Pace” Challenges Are Not Cognizable I. Introduction In...

DSM Text Revisions Count as the “Most Recently Published Edition”; PTSD Presumption Rebuttal Is Not Limited to IPEs and Outdated-DSM IPEs Are Weighable Evidence

Date: Jul 23, 2026

DSM Text Revisions Count as the “Most Recently Published Edition”; PTSD Presumption Rebuttal Is Not Limited to IPEs and Outdated-DSM IPEs Are Weighable Evidence 1. Introduction In Nicholas Rowe v....

Victim Allegations—Even If Inconsistent—Can Supply Probable Cause; Conditional Assurances Do Not Vitiate Consent to Home Entry

Date: Jul 23, 2026

Victim Allegations—Even If Inconsistent—Can Supply Probable Cause; Conditional Assurances Do Not Vitiate Consent to Home Entry Introduction Charles Friend v. City of Decatur, Illinois (7th Cir. July...

Montana’s 2026 Rule: Documented Random, Proximate Judge Reassignment and Strict Timing/Fee Controls for District Judge Substitution (§ 3-1-804, MCA)

Date: Jul 23, 2026

Montana’s 2026 Rule: Documented Random, Proximate Judge Reassignment and Strict Timing/Fee Controls for District Judge Substitution (§ 3-1-804, MCA) 1. Introduction In re Revised Rules on...

Counterman Does Not Invalidate Montana’s Threatening-an-Officer Statute Where It Requires Purposeful/Knowing Threats, and 911-Driven Domestic-Disturbance Exigency Can Justify Warrantless Entry Despite a Demand to Leave

Date: Jul 23, 2026

Counterman Does Not Invalidate Montana’s Threatening-an-Officer Statute Where It Requires Purposeful/Knowing Threats, and 911-Driven Domestic-Disturbance Exigency Can Justify Warrantless Entry...

Reversal of a Conditional Federal Habeas Writ Extinguishes Substitution Rights and Permits Reinstatement of a Vacated Montana Conviction—But Only After the Defendant Is Heard

Date: Jul 23, 2026

Reversal of a Conditional Federal Habeas Writ Extinguishes Substitution Rights and Permits Reinstatement of a Vacated Montana Conviction—But Only After the Defendant Is Heard Case: State v. K....

Diligent ICWA Inquiry Is Satisfied by Prompt Notice and Conclusive Tribal Responses; Speculative Parole Date Does Not Establish Ineffective Assistance or Defeat Termination Under § 41-3-609(4)(c), MCA

Date: Jul 23, 2026

Diligent ICWA Inquiry Is Satisfied by Prompt Notice and Conclusive Tribal Responses; Speculative Parole Date Does Not Establish Ineffective Assistance or Defeat Termination Under § 41-3-609(4)(c),...

Discovery Is Not GRE 404(b) Notice: Failure to Provide Requested Notice Renders Other-Acts Evidence Inadmissible and Can Require Reversal

Date: Jul 23, 2026

Discovery Is Not GRE 404(b) Notice: Failure to Provide Requested Notice Renders Other-Acts Evidence Inadmissible and Can Require Reversal Case: People of Guam v. Philips James Sablan, Cite: 2026 Guam...

Bus Aide Assignment and Student-Supervision Methods Are Discretionary Under Delaware’s Tort Claims Act; Special-Needs Regulations Do Not Create a Ministerial Hiring/Placement Duty

Date: Jul 23, 2026

Bus Aide Assignment and Student-Supervision Methods Are Discretionary Under Delaware’s Tort Claims Act; Special-Needs Regulations Do Not Create a Ministerial Hiring/Placement Duty 1. Introduction In...

“A Deadly Weapon” Means One Weapon: Separate § 1448 Convictions for Each Firearm (and Ammunition) Possessed by a Person Prohibited

Date: Jul 23, 2026

“A Deadly Weapon” Means One Weapon: Separate § 1448 Convictions for Each Firearm (and Ammunition) Possessed by a Person Prohibited Case: Abbott v. State (Del. Supr. July 21, 2026) | Court: Supreme...

Reliable Foundation Required for Expert Future Lost-Wage Projections; Narrow Admission of Stale Dishonesty Convictions Under D.R.E. 609(b) When Credibility Is Central

Date: Jul 23, 2026

Reliable Foundation Required for Expert Future Lost-Wage Projections; Narrow Admission of Stale Dishonesty Convictions Under D.R.E. 609(b) When Credibility Is Central Case: Willie L. Bowman v....

Unpublished Sixth Circuit: Stroke Misdiagnosis, “More Than Negligence,” and Reasonable Deference to Jail Medical Staff Defeat Fourteenth Amendment Deliberate-Indifference Claims

Date: Jul 22, 2026

Unpublished Sixth Circuit: Stroke Misdiagnosis, “More Than Negligence,” and Reasonable Deference to Jail Medical Staff Defeat Fourteenth Amendment Deliberate-Indifference Claims 1. Introduction In...