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

Reyos v. State (2026 UT 18) Commentary

Date: Jul 17, 2026

Reyos v. State (2026 UT 18): Appellate “Engagement” Requirement and Preservation Bar in Untimely PCRA Appeal-Reinstatement Efforts 1. Introduction In Reyos v. State, the Utah Supreme Court addressed...

Private Bail Recovery Agents Are Not State Actors for § 1983 Absent State Compulsion or Joint Law-Enforcement Participation (11th Cir.)

Date: Jul 17, 2026

Private Bail Recovery Agents Are Not State Actors for § 1983 Absent State Compulsion or Joint Law-Enforcement Participation (11th Cir.) 1. Introduction In Lillie Middlebrooks v. Bond, James Bond,...

People v. Wilson (3d Dept 2026): Fleeing a Crashed, Unoccupied Vehicle Constitutes Abandonment Defeating Fourth Amendment Standing; Conditional Pro Se Requests Are Not “Unequivocal”

Date: Jul 17, 2026

People v. Wilson (3d Dept 2026): Fleeing a Crashed, Unoccupied Vehicle Constitutes Abandonment Defeating Fourth Amendment Standing; Conditional Pro Se Requests Are Not “Unequivocal” 1. Introduction...

Benowski v. Track Dr., LLC — Clear Final Release Bars Contractor’s Retainage Claim; Bald Forgery Allegations and Unilateral Mistake Do Not Create Triable Issues

Date: Jul 17, 2026

Clear Final Release Bars Contractor’s Retainage Claim; Bald Forgery Allegations and Unilateral Mistake Do Not Create Triable Issues Introduction In Benowski v Track Dr., LLC (2026 NY Slip Op 04466...

Brady Materiality of Suppressed Police Civil Litigation and CCRB Histories When a Confession Case Turns on Detective Credibility

Date: Jul 17, 2026

Brady Materiality of Suppressed Police Civil Litigation and CCRB Histories When a Confession Case Turns on Detective Credibility Case: People v White, 2026 NY Slip Op 04475 (App Div, 1st Dept July...

People v. Buchanan: Distinct Second-Degree Weapon Possession Counts May Support Consecutive Sentences, Yet Appellate Courts May Reduce to Concurrent in the Interest of Justice

Date: Jul 17, 2026

People v. Buchanan: Distinct Second-Degree Weapon Possession Counts May Support Consecutive Sentences, Yet Appellate Courts May Reduce to Concurrent in the Interest of Justice Case: People v....

People v. Mosley: CPL 440.30(1-a) Permits Renewed DNA Testing When Materially Advanced Methods Could Yield Materially Different Results

Date: Jul 17, 2026

People v. Mosley: CPL 440.30(1-a) Permits Renewed DNA Testing When Materially Advanced Methods Could Yield Materially Different Results 1. Introduction People v Mosley (2026 NY Slip Op 04454 [3d Dept...

People v. Williams: Limited Molineux “Background” Evidence to Explain Police Pursuit; Omitted Gomberg Inquiry Reversible Only Upon Actual, Operative Conflict

Date: Jul 17, 2026

People v. Williams: Limited Molineux “Background” Evidence to Explain Police Pursuit; Omitted Gomberg Inquiry Reversible Only Upon Actual, Operative Conflict 1. Introduction In People v Williams...

Attempted First-Degree Arson: Bringing and Lighting a Molotov on a Wooden Porch, with Nearby Burn Marks and Gasoline Spill, Meets the “Dangerously Near” Standard

Date: Jul 17, 2026

Attempted First-Degree Arson: Bringing and Lighting a Molotov on a Wooden Porch, with Nearby Burn Marks and Gasoline Spill, Meets the “Dangerously Near” Standard 1. Introduction In People v. Fajardo...

Misnaming the Contractually Required Additional Insured Is a Material Breach; Conditional Indemnification May Be Granted Despite Potential Indemnitee Negligence

Date: Jul 17, 2026

Misnaming the Contractually Required Additional Insured Is a Material Breach; Conditional Indemnification May Be Granted Despite Potential Indemnitee Negligence 1. Introduction Newland v County Waste...

Police “Business Records” and the Unidentified Declarant: Foundation Required Under CPLR 4518 for Hearsay Statements in Investigation Reports

Date: Jul 17, 2026

Police “Business Records” and the Unidentified Declarant: Foundation Required Under CPLR 4518 for Hearsay Statements in Investigation Reports 1. Introduction People v Mawhiney (2026 NY Slip Op 04460...

Private, Uncirculated Social-Media Messages Lack “Terroristic Threat” Intent; Direct Threats to a Media Outlet May Qualify

Date: Jul 17, 2026

Private, Uncirculated Social-Media Messages Lack “Terroristic Threat” Intent; Direct Threats to a Media Outlet May Qualify 1. Introduction In People v. Rainey (2026 NY Slip Op 04451 [3d Dept July 16,...

Mandatory Sexually Violent Offender Designation for Enumerated SORA Offenses and Required Weighing of Mitigation in Upward-Departure Decisions (People v. Occhipinti)

Date: Jul 17, 2026

Mandatory Sexually Violent Offender Designation for Enumerated SORA Offenses and Required Weighing of Mitigation in Upward-Departure Decisions (People v. Occhipinti) 1. Introduction In People v...

Carman v. State — Treatment Discharge as a VOP Proven by “Some Competent Evidence” Despite Hearsay Limits

Date: Jul 16, 2026

Treatment Discharge as a VOP Proven by “Some Competent Evidence” Despite Hearsay Limits 1. Introduction Carman v. State (Del. July 14, 2026) is a Delaware Supreme Court order affirming a Superior...

Amendment 821 Is Substantive on Direct Appeal: Retroactive Status-Point Relief Must Proceed via 18 U.S.C. § 3582(c)(2)

Date: Jul 16, 2026

Amendment 821 Is Substantive on Direct Appeal: Retroactive Status-Point Relief Must Proceed via 18 U.S.C. § 3582(c)(2) Case: United States v. Daniel King (11th Cir. July 15, 2026) (Not for...

Incomplete Appellate Transcript in Vermont Bench-Trial Appeals Presumes Trial Findings and Waives Fact-Based Challenges

Date: Jul 16, 2026

Incomplete Appellate Transcript in Vermont Bench-Trial Appeals Presumes Trial Findings and Waives Fact-Based Challenges Case: Jessica Floyd v. Michelle LeBlanc (Vt. Sup. Ct., July 10, 2026) — Entry...

Aggravated Stalking with a Deadly Weapon Is Not a “Felony Involving an Act of Violence” for § 7553a Hold-Without-Bail

Date: Jul 16, 2026

Aggravated Stalking with a Deadly Weapon Is Not a “Felony Involving an Act of Violence” for § 7553a Hold-Without-Bail Introduction In State v. Mark Sterling (Vt. July 10, 2026), the Vermont Supreme...

Rule 75 Prison-Discipline Review: Strict Issue Preservation to the Superintendent and Deferential “Some Evidence” Sufficiency

Date: Jul 16, 2026

Rule 75 Prison-Discipline Review: Strict Issue Preservation to the Superintendent and Deferential “Some Evidence” Sufficiency Introduction In Jason Eaton v. Nicholas Deml and Amy Jacobs (Vt. Sup. Ct....

Extension of Vermont Anti-Stalking Orders Turns on Protective Necessity—Not New Stalking—and Pro Se Filings Risk Rule 11 Sanctions for Fake Authority

Date: Jul 16, 2026

Extension of Vermont Anti-Stalking Orders Turns on Protective Necessity—Not New Stalking—and Pro Se Filings Risk Rule 11 Sanctions for Fake Authority 1. Introduction In Cheryl O'Donnell v. Hope...

Termination at Initial Disposition: Recent Sobriety and Housing Gains Do Not Defeat TPR Absent a Child-Timed Path to Resuming Parenting

Date: Jul 16, 2026

Termination at Initial Disposition: Recent Sobriety and Housing Gains Do Not Defeat TPR Absent a Child-Timed Path to Resuming Parenting Introduction Case: In re L.H., Juvenile (K.M., Mother*) (Vt....