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

Marfil v. City of New Braunfels (5th Cir. 2026): No Texas Due-Process Property Interest in Short-Term Leasing; STR Zoning Bans Survive Rational-Basis Review

Date: Jun 22, 2026

No Texas Due-Process Property Interest in Short-Term Leasing; Short-Term Rental Zoning Bans in Residential Districts Survive Rational-Basis Review 1. Introduction Case: Marfil v. City of New...

Third Circuit Narrows APA Review of Park-Service “Exhibit Decisions” and Limits § 407n Mutual-Agreement Rights to Independence Square

Date: Jun 22, 2026

Third Circuit Narrows APA Review of Park-Service “Exhibit Decisions” and Limits § 407n Mutual-Agreement Rights to Independence Square 1. Introduction City of Philadelphia v. Secretary U.S. Department...

FRSA Retaliation Requires Decisionmaker (or Influencer) Knowledge of Protected Activity

Date: Jun 22, 2026

FRSA Retaliation Requires Decisionmaker (or Influencer) Knowledge of Protected Activity 1. Introduction In Jodi Asay v. New Jersey Transit Rail Operations, Inc., the United States Court of Appeals...

Acceptance of a Binding Appraisal Award (and Failure to Timely Challenge It) Ratifies the Loss Amount and Bars Further Coverage and Duplicative Tort Claims

Date: Jun 22, 2026

Acceptance of a Binding Appraisal Award (and Failure to Timely Challenge It) Ratifies the Loss Amount and Bars Further Coverage and Duplicative Tort Claims 1. Introduction In Young v. State Farm Fire...

Revocation Imprisonment Under § 3583(e)(3) Is Capped by Felony Class, Not the Underlying Statutory Maximum—and a Later Revocation Does Not Moot a Prior Revocation Appeal

Date: Jun 22, 2026

Revocation Imprisonment Under § 3583(e)(3) Is Capped by Felony Class, Not the Underlying Statutory Maximum—and a Later Revocation Does Not Moot a Prior Revocation Appeal Introduction In United States...

United States v. Yonathan Melaku — No Plain Tapia Error Where Treatment Rationale Is Intertwined with Public Safety and No Objection Preserves the Issue; “Jurisdiction” Mislabeling Cannot Cure Forfeiture

Date: Jun 22, 2026

No Plain Tapia Error Where Treatment Rationale Is Intertwined with Public Safety and No Objection Preserves the Issue; “Jurisdiction” Mislabeling Cannot Cure Forfeiture Case: United States v....

Issue-by-Issue Exhaustion and Social-Distinction Proof: Limits on “Loan Shark” Particular Social Groups

Date: Jun 22, 2026

Issue-by-Issue Exhaustion and Social-Distinction Proof: Limits on “Loan Shark” Particular Social Groups 1. Introduction In Sushilaben Patel v. Attorney General United States of America (3d Cir. June...

Change-in-Law Alone Does Not Reopen Closed Habeas Judgments Under Rule 60(b)(6) Absent Properly Presented Extraordinary Equities

Date: Jun 22, 2026

Change-in-Law Alone Does Not Reopen Closed Habeas Judgments Under Rule 60(b)(6) Absent Properly Presented Extraordinary Equities Case: Jafarnia Williams v. Superintendent Rockview SCI, No. 23-1306...

Professional-Discipline Plaintiffs Cannot Proceed as “Roe” Absent Specific, Exceptional Proof Overcoming the Presumption of Open Courts

Date: Jun 22, 2026

Professional-Discipline Plaintiffs Cannot Proceed as “Roe” Absent Specific, Exceptional Proof Overcoming the Presumption of Open Courts 1. Introduction In Roe v. Colorado Judicial Department (10th...

Alves-Pains v. Blanche — Reconsideration Requires Specific Error; PSGs Must Be Proved and Objectively Delineated (No “Perceived” Membership)

Date: Jun 22, 2026

Alves-Pains v. Blanche: Reconsideration Requires Specific Error; PSG Membership Must Be Proven, and “Perceived” Family PSGs Fail Particularity 1. Introduction In Alves-Pains v. Blanche (1st Cir. June...

Post-Removal Hair Follicle Tests Are Relevant at Neglect Adjudication When They Encompass the Petition Date

Date: Jun 22, 2026

Post-Removal Hair Follicle Tests Are Relevant at Neglect Adjudication When They Encompass the Petition Date 1. Introduction Case: In the Interest Of: AC and BI, Minor Children, JC v. The State of...

Seventh Circuit: Below-Guidelines Sentences Satisfy § 3553(a)(6), and “Risk-Notification” Supervised-Release Conditions Must Be Specifically Defined

Date: Jun 22, 2026

Seventh Circuit: Below-Guidelines Sentences Satisfy § 3553(a)(6), and “Risk-Notification” Supervised-Release Conditions Must Be Specifically Defined I. Introduction In United States v. Daniel Quiggle...

Upholding a Residence-Based Animal-Contact Ban as a Tailored Special Condition of Supervised Release

Date: Jun 22, 2026

Upholding a Residence-Based Animal-Contact Ban as a Tailored Special Condition of Supervised Release 1. Introduction In United States v. Emily Sahara Lau (11th Cir. 2026-06-17) (unpublished), the...

Equitable Tolling of the 90-Day Motion-to-Reopen Deadline Requires Explained, Continuous Reasonable Diligence—Later “Urgency” After a Removal Notice Is Too Late

Date: Jun 22, 2026

Equitable Tolling of the 90-Day Motion-to-Reopen Deadline Requires Explained, Continuous Reasonable Diligence—Later “Urgency” After a Removal Notice Is Too Late I. Introduction In Oscar Garcia-Islas...

Restitution Under 18 U.S.C. § 2259: Minimal-Indicia Reliability Suffices; Arithmetic Errors Correctable Without Undermining the Award

Date: Jun 22, 2026

Restitution Under 18 U.S.C. § 2259: Minimal-Indicia Reliability Suffices; Arithmetic Errors Correctable Without Undermining the Award Case: United States v. Matherne (5th Cir. June 18, 2026) (per...

Silencers Are Second Amendment “Arms,” but NFA § 5861(d) Challenges Fail Absent Proof a Shall-Issue Regime Is “Put Toward Abusive Ends”

Date: Jun 22, 2026

Silencers Are Second Amendment “Arms,” but NFA § 5861(d) Challenges Fail Absent Proof a Shall-Issue Regime Is “Put Toward Abusive Ends” I. Introduction United States v. Comeaux (5th Cir. June 18,...

Ordinary (Not Maximum) Diligence Governs Post-Limitations Service Under Texas Law; Brief Process-Server Delays Usually Create a Fact Issue

Date: Jun 22, 2026

Ordinary (Not Maximum) Diligence Governs Post-Limitations Service Under Texas Law; Brief Process-Server Delays Usually Create a Fact Issue Introduction Larkins v. S.D.P. Manufacturing (5th Cir. June...

Revocation Imprisonment Under § 3583(e)(3) Is Not Capped by the Underlying Offense’s Statutory Maximum; Successive Revocations Do Not Moot an Earlier Revocation Appeal While Supervised Release Remains Modifiable

Date: Jun 22, 2026

Revocation Imprisonment Under § 3583(e)(3) Is Not Capped by the Underlying Offense’s Statutory Maximum; Successive Revocations Do Not Moot an Earlier Revocation Appeal While Supervised Release...

Revocation Sentencing After Esteras: A Passing Reference to “Respect for the Law” Does Not Require Vacatur Absent Plain, Prejudicial Error

Date: Jun 22, 2026

Revocation Sentencing After Esteras: A Passing Reference to “Respect for the Law” Does Not Require Vacatur Absent Plain, Prejudicial Error 1. Introduction In United States v. Cody Stevenson (4th Cir....

Retroactive OFAC Licensing Validates Trademark Renewal Fees and Preserves Timely Lanham Act Renewals

Date: Jun 22, 2026

Retroactive OFAC Licensing Validates Trademark Renewal Fees and Preserves Timely Lanham Act Renewals Introduction Bacardi and Company Limited v. John Squires (4th Cir. June 16, 2026) is the latest...