conversion-liability-under-restatement-(second)-of-torts- Case Commentaries

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...

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...

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...

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...