establishing-personal-jurisdiction-requires-targeted-activities Case Commentaries

Rule 41 Stipulated Dismissal Ends a Desegregation Case Immediately—No “Public-Interest” Override; Mandamus Lies to Stop Post-Dismissal Proceedings

Date: Jul 18, 2026

Rule 41 Stipulated Dismissal Ends a Desegregation Case Immediately—No “Public-Interest” Override; Mandamus Lies to Stop Post-Dismissal Proceedings 1. Introduction Sch Bd Concordia Prsh v. United...

Brown v. Burmaster: Causation Is Indispensable to Municipal Liability; Irreconcilable Special Verdicts Require a New Trial

Date: Jul 18, 2026

Brown v. Burmaster: Causation Is Indispensable to Municipal Liability; Irreconcilable Special Verdicts Require a New Trial I. Introduction Brown v. Burmaster (5th Cir. July 14, 2026) arises from a...

Competency to Stand Trial Suffices for Faretta Waiver; Indiana v. Edwards Is Discretionary, Not Mandatory

Date: Jul 18, 2026

Competency to Stand Trial Suffices for Faretta Waiver; Indiana v. Edwards Is Discretionary, Not Mandatory 1. Introduction In United States v. Stephen Snyder (4th Cir. July 14, 2026), the Fourth...

Rule 60(b)(6) Finality in Diversity Cases: Later State-Law Decisions Are Not “Extraordinary” Absent the Same Transaction or Occurrence

Date: Jul 18, 2026

Rule 60(b)(6) Finality in Diversity Cases: Later State-Law Decisions Are Not “Extraordinary” Absent the Same Transaction or Occurrence 1. Introduction In Golden Corral Corporation v. Illinois Union...

FTCA “Risk-Creation” Negligence Survives the Intentional Tort Exception When a Separate Duty to the Victim Exists (Sheridan Applied to USPS Assault Context)

Date: Jul 18, 2026

FTCA “Risk-Creation” Negligence Survives the Intentional Tort Exception When a Separate Duty to the Victim Exists (Sheridan Applied to USPS Assault Context) I. Introduction In Dawn Lusk v. Chris...

Hulett v. Foster (10th Cir. 2026): Discretionary Denial of Late-Appeal Relief Under FRAP 4(a)(5) and 4(a)(6)

Date: Jul 18, 2026

Discretionary Denial of Late-Appeal Relief: Sporadic E-Filing Undercuts “Excusable Neglect,” and FRAP 4(a)(6) Reopening Remains Permissive 1. Introduction Case: Hulett v. Foster, No. 26-3035 (10th...

Monell Deliberate Indifference Requires Notice of a Pattern of Nonconsensual Guard–Inmate Sexual Abuse (Not Merely Policy/Criminal Misconduct)

Date: Jul 18, 2026

Monell Deliberate Indifference Requires Notice of a Pattern of Nonconsensual Guard–Inmate Sexual Abuse (Not Merely Policy/Criminal Misconduct) Introduction Harden v. Hedgecock (10th Cir. July 14,...

Georgia Trial Courts May Strike a Defendant’s Answer for Willful Motions-in-Limine Violations Under OCGA § 15-1-3

Date: Jul 18, 2026

Georgia Trial Courts May Strike a Defendant’s Answer for Willful Motions-in-Limine Violations Under OCGA § 15-1-3 1. Introduction This Court of Appeals of Georgia decision (Fifth Division) arises...

OCGA § 44-7-14 Exclusivity for Tenant-Possessed Areas: Mischarging OCGA § 51-3-1 Requires Vacatur and Full Retrial

Date: Jul 18, 2026

OCGA § 44-7-14 Exclusivity for Tenant-Possessed Areas: Mischarging OCGA § 51-3-1 Requires Vacatur and Full Retrial 1. Introduction Venetian Hills Apartments, LLC v. Hughes is a wrongful-death...

State v. Quelon Page: Trial Justice Must Clearly Articulate “Thirteenth Juror” Weight-of-the-Evidence Reasoning When Denying a New Trial

Date: Jul 18, 2026

State v. Quelon Page: Trial Justice Must Clearly Articulate “Thirteenth Juror” Weight-of-the-Evidence Reasoning When Denying a New Trial 1. Introduction In State v. Quelon Page (R.I. July 16, 2026),...

Rhode Island Rejects “Language Conduit” Treatment for Unidentified Interpreters: Out-of-Court Interpreted Statements Are Hearsay Absent Reliability and Agency

Date: Jul 18, 2026

Rhode Island Rejects “Language Conduit” Treatment for Unidentified Interpreters: Out-of-Court Interpreted Statements Are Hearsay Absent Reliability and Agency I. Introduction In Galbin Fernandez, in...

“In the View of the Board” Does Not Dilute the Applicant’s Evidentiary Burden for a Special Exception

Date: Jul 18, 2026

“In the View of the Board” Does Not Dilute the Applicant’s Evidentiary Burden for a Special Exception Case: Appeal of Murray, 2026 N.H. 26 (N.H. July 15, 2026) Court: Supreme Court of New Hampshire...

Expert “Medical Torture” Diagnoses Are Inadmissible in Torture Trials When They Are Unhelpful, Unreliable, and Function as a Legal Conclusion

Date: Jul 18, 2026

Expert “Medical Torture” Diagnoses Are Inadmissible in Torture Trials When They Are Unhelpful, Unreliable, and Function as a Legal Conclusion I. Introduction In People of Michigan v. Gwendolyn...

People v Fenderson: Police May Not Undermine Miranda by Implying Counsel Depends on Money; “What’s going on?” Is Not Edwards Reinitiation

Date: Jul 18, 2026

People v Fenderson (Mich 2026): Police May Not Undermine Miranda by Implying Counsel Depends on Money; “So what’s going on?” Is Not Edwards Reinitiation Supreme Court of Michigan — July 14, 2026...

Oklahoma Rule 5.2(A) Waiver as an Independent and Adequate State Ground Barring Federal Habeas Review (Absent Cause/Prejudice or Actual Innocence)

Date: Jul 18, 2026

Oklahoma Rule 5.2(A) Waiver as an Independent and Adequate State Ground Barring Federal Habeas Review (Absent Cause/Prejudice or Actual Innocence) Introduction Cray v. Cultrera is a nonprecedential...

Fake-Identity Bank Account Holders Are Not “Customers” Under Shaw: Bank Fraud Proof and Deferred-Restitution Jurisdiction

Date: Jul 18, 2026

Fake-Identity Bank Account Holders Are Not “Customers” Under Shaw: Bank Fraud Proof and Deferred-Restitution Jurisdiction Case: United States v. Omoruyi (1st Cir. July 15, 2026) | Charges: 18 U.S.C....

Fake-Identity “Customers” and Deferred Restitution: Bank Fraud Property Interests Under § 1344(1) and MVRA Jurisdiction

Date: Jul 18, 2026

Fake-Identity “Customers” and Deferred Restitution: Bank Fraud Property Interests Under § 1344(1) and MVRA Jurisdiction I. Introduction In United States v. Omoruyi (1st Cir. July 15, 2026), the First...

FSIA Commercial-Activity Exception: Sovereign-Coerced Merger “Brokering” Is Not Commercial Activity

Date: Jul 18, 2026

FSIA Commercial-Activity Exception: Sovereign-Coerced Merger “Brokering” Is Not Commercial Activity 1. Introduction Creditincome Limited v. The Swiss Confederation (2d Cir. July 16, 2026) addresses...

Prospective Application of Florida’s Post–SB 450 Nonunanimous Death-Recommendation Scheme Is Procedural and Not Ex Post Facto

Date: Jul 18, 2026

Prospective Application of Florida’s Post–SB 450 Nonunanimous Death-Recommendation Scheme Is Procedural and Not Ex Post Facto I. Introduction In Patrick R. McDowell v. State of Florida (Fla. July 16,...

Wyoming TPR Rule: No “Reasonable Efforts” Prerequisite Under § 14-2-309(a)(v), and Unchallenged Independent Grounds Sustain Termination

Date: Jul 18, 2026

Wyoming TPR Rule: No “Reasonable Efforts” Prerequisite Under § 14-2-309(a)(v), and Unchallenged Independent Grounds Sustain Termination 1. Introduction In In the Matter of the Termination of Parental...