Puerto Rico Case Commentaries

Goldwater v. Phoenix: No Rigid “Probability of Harm” Element Under Carlson; Appellate De Novo Rebalancing and In Camera Review for Negotiation-Stage Public Records

Date: Jul 20, 2026

Goldwater v. Phoenix: No Rigid “Probability of Harm” Element Under Carlson; Appellate De Novo Rebalancing and In Camera Review for Negotiation-Stage Public Records 1) Introduction In GOLDWATER v....

Unequal Subclass Allocations Require Separate Representation: Structural Adequacy as a Prerequisite to Class-Settlement Approval

Date: Jul 20, 2026

Unequal Subclass Allocations Require Separate Representation: Structural Adequacy as a Prerequisite to Class-Settlement Approval I. Introduction In In re: Clearview AI, Inc. Consumer Privacy...

Homeowner’s Contents Become “Business Property” When Used to Operate a Rental/Event Venue, Triggering the $25,000 Sublimit

Date: Jul 20, 2026

Homeowner’s Contents Become “Business Property” When Used to Operate a Rental/Event Venue, Triggering the $25,000 Sublimit Introduction In Wesley Gibson v. Chubb National Insurance Company (7th Cir....

People of Guam v. VonSchimpf: Circumstantial Proof of Intent for Attempted CSC IV and No Double Jeopardy for Consecutive Sentences with Abuse of an Incompetent

Date: Jul 20, 2026

Circumstantial Proof of Intent Suffices for Attempted CSC IV, and Consecutive Sentences with Abuse of an Incompetent Do Not Violate Guam’s Double Jeopardy Statutes I. Introduction In People of Guam...

Household-Control and Grooming Evidence as Admissible Rule 404(b) Proof of Motive/Plan in Child Sexual-Abuse Prosecutions

Date: Jul 20, 2026

Household-Control and Grooming Evidence as Admissible Rule 404(b) Proof of Motive/Plan in Child Sexual-Abuse Prosecutions Case: Steven Randall Marler v. The State of Wyoming Citation: 2026 WY 83...

Rule 4(b)(4) Without a Motion: Seventh Circuit Requires District-Court Good-Cause/Excusable-Neglect Finding Before Dismissing a Criminal Appeal Filed Within the 30-Day Extension Window

Date: Jul 20, 2026

Rule 4(b)(4) Without a Motion: Seventh Circuit Requires District-Court Good-Cause/Excusable-Neglect Finding Before Dismissing a Criminal Appeal Filed Within the 30-Day Extension Window 1....

State v. Barker (Kan. 2026): Invited Error Requires an Affirmative Omission/Refusal of Jury Instructions; Nonrequested Lesser-Included Instructions Are Reviewed for Clear Error

Date: Jul 20, 2026

State v. Barker (Kan. 2026): Invited Error Requires an Affirmative Omission/Refusal of Jury Instructions; Nonrequested Lesser-Included Instructions Are Reviewed for Clear Error Introduction In State...

State v. Ross: Kansas Preliminary Hearings Exclude Affirmative Defenses; K.S.A. 21-5109(d) Limits Only Multiple Convictions

Date: Jul 20, 2026

State v. Ross: Kansas Preliminary Hearings Exclude Affirmative Defenses; K.S.A. 21-5109(d) Limits Only Multiple Convictions 1. Introduction In State v. Ross (Kan. July 17, 2026), the State appealed a...

Upward Variances Affirmed When District Courts Tie the Degree of Deviation to § 3553(a) and Reliably Supported Uncharged Conduct (Seventh Circuit)

Date: Jul 20, 2026

Upward Variances Affirmed When District Courts Tie the Degree of Deviation to § 3553(a) and Reliably Supported Uncharged Conduct (Seventh Circuit) 1. Introduction United States v. Travis L. Withers...

Participation Without Reservation Waives Non‑Signatory Arbitrability Objections in Labor Arbitration

Date: Jul 20, 2026

Participation Without Reservation Waives Non‑Signatory Arbitrability Objections in Labor Arbitration Introduction Elmar Hotel Management, LLC v. Unite Here Local 1 (7th Cir. July 17, 2026) concerns...

Fraud Sentencing in the Seventh Circuit: Intended-Loss Reliance on a Reliable PSR and § 2B1.1(b)(9)(A) Applied to a “Non-Existent” Government Agency

Date: Jul 19, 2026

Fraud Sentencing in the Seventh Circuit: Intended-Loss Reliance on a Reliable PSR and § 2B1.1(b)(9)(A) Applied to a “Non-Existent” Government Agency 1. Introduction United States v. Minister Zakar...

U.S.S.G. § 2B1.1(b)(9)(A) Enhancement Applies to Purported “Diplomats” of a Nonexistent Government Entity; PSR-Based Intended-Loss Findings Stand Absent “Real Doubt”

Date: Jul 19, 2026

U.S.S.G. § 2B1.1(b)(9)(A) Enhancement Applies to Purported “Diplomats” of a Nonexistent Government Entity; PSR-Based Intended-Loss Findings Stand Absent “Real Doubt” 1. Introduction In United States...

Extortion-for-Money Defeats Asylum Nexus; Child’s SIJS Does Not Reopen Parent’s Case Absent Independent Relief

Date: Jul 19, 2026

Extortion-for-Money Defeats Asylum Nexus; Child’s SIJS Does Not Reopen Parent’s Case Absent Independent Relief Case: Gladis Chavez-Pineda v. Todd W. Blanche (7th Cir. July 17, 2026) (nonprecedential)...

Agee v. Hickenbottom: Class-of-One Equal Protection Amendments Are Not Futile Unless Probable Cause Is Certain on the Pleadings

Date: Jul 19, 2026

Agee v. Hickenbottom: Class-of-One Equal Protection Amendments Are Not Futile Unless Probable Cause Is Certain on the Pleadings I. Introduction In Jacqueline Agee v. Paige Hickenbottom (7th Cir. July...

Extortion-as-Profit Motive Defeats Asylum Nexus: Seventh Circuit Affirms Denial Where “Single-Mother” PSG Evidence Does Not Show a Central Reason

Date: Jul 19, 2026

Extortion-as-Profit Motive Defeats Asylum Nexus: Seventh Circuit Affirms Denial Where “Single-Mother” PSG Evidence Does Not Show a Central Reason 1. Introduction In Gladis Chavez-Pineda v. Todd W....

Reliable PSR Controls Intended-Loss Findings and “Government-Agency” Fraud Enhancement Applies Even to a Non-Existent “Consulate” (Seventh Circuit)

Date: Jul 19, 2026

Reliable PSR Controls Intended-Loss Findings and “Government-Agency” Fraud Enhancement Applies Even to a Non-Existent “Consulate” (Seventh Circuit) 1. Introduction In United States v. Aziz Hassan Bey...

Pretrial Detainee Suicide Claims: Objective Unreasonableness Requires Evidence that a Reasonable Mental-Health Professional Would Have Acted Differently

Date: Jul 19, 2026

Pretrial Detainee Suicide Claims: Objective Unreasonableness Requires Evidence that a Reasonable Mental-Health Professional Would Have Acted Differently Introduction In Estate of Anthony Mouradian v....

Agee v. Hickenbottom: Leave to Amend Must Be Granted Unless Probable Cause (and Futility) Is Certain on the Face of the Proposed Class-of-One Equal Protection Pleading

Date: Jul 18, 2026

Agee v. Hickenbottom: Leave to Amend Must Be Granted Unless Probable Cause (and Futility) Is Certain on the Face of the Proposed Class-of-One Equal Protection Pleading I. Introduction Case:...

Armstrong Deference Confirmed for ESOP Sale Decisions Absent Conflict; Market Deal Price Anchors Fair-Market-Value and Damages

Date: Jul 18, 2026

Armstrong Deference Confirmed for ESOP Sale Decisions Absent Conflict; Market Deal Price Anchors Fair-Market-Value and Damages 1. Introduction Bruce Rush v. GreatBanc Trust Company (7th Cir. July 17,...

§2D1.1(b)(1) “Procurement-and-Proximity” Rule: Obtaining a Firearm for a Buyer En Route to a Drug Deal Supports the Dangerous-Weapon Enhancement

Date: Jul 18, 2026

§2D1.1(b)(1) “Procurement-and-Proximity” Rule: Obtaining a Firearm for a Buyer En Route to a Drug Deal Supports the Dangerous-Weapon Enhancement 1. Introduction In United States v. Augusto...