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

Generalized Mental-Health Allegations Do Not Warrant a Postconviction Competency Hearing Absent Facts Showing Probable Incompetence

Date: Jun 2, 2026

Generalized Mental-Health Allegations Do Not Warrant a Postconviction Competency Hearing Absent Facts Showing Probable Incompetence Case: State v. Kellogg, 321 Neb. 502 (Neb. May 29, 2026) | Court:...

State v. Rohena: Independent-Source Admission of In-Court Identifications After a Suppressed Out-of-Court Identification (Especially Where the Witness Is Familiar with the Defendant)

Date: Jun 2, 2026

State v. Rohena: Independent-Source Admission of In-Court Identifications After a Suppressed Out-of-Court Identification (Especially Where the Witness Is Familiar with the Defendant) Supreme Court of...

Iowa Savings Statute Applies After Voluntary Dismissal Triggered by Post-Miller Certificate-of-Merit Defect Absent Negligence

Date: Jun 2, 2026

Iowa Savings Statute Applies After Voluntary Dismissal Triggered by Post-Miller Certificate-of-Merit Defect Absent Negligence 1. Introduction Case: Michael Trask v. Amar F. Ahmed, M.D.; Sandro...

Habitual Offender Enhancement Under Iowa Code § 902.8 Depends on Two Prior Convictions—Hollins Sequencing Limited to Same‑Day Convictions

Date: Jun 2, 2026

Habitual Offender Enhancement Under Iowa Code § 902.8 Depends on Two Prior Convictions—Hollins Sequencing Limited to Same‑Day Convictions 1. Introduction State of Iowa v. Richard Allen Sharples...

Iowa: Certificate of Merit Not Required for Informed-Consent Claims Under § 147.140

Date: Jun 2, 2026

Iowa: Certificate of Merit Not Required for Informed-Consent Claims Under Iowa Code § 147.140 Case: Margaret Lofgren, both individually and as administrator of the Estate of Louden P. Lofgren v....

Ruffin v. BP: No Per Se Quantitative-Dose Requirement for General Causation, But Experts Must Tie the Plaintiff’s Exposure to a конкрет Carcinogenic Agent and the Specific Cancer

Date: Jun 2, 2026

No Per Se Quantitative-Dose Requirement for General Causation in Fifth Circuit Toxic-Tort Cases—But Experts Must Link the Plaintiff’s Exposure to a Specific Causal Agent and the Specific Cancer Case:...

Express Reopening Conditions Govern Administrative Closures: Only a Transfer “Out Of” the Facility Triggers Reopening

Date: Jun 2, 2026

Express Reopening Conditions Govern Administrative Closures: Only a Transfer “Out Of” the Facility Triggers Reopening I. Introduction In Vreeland v. Jacobson (10th Cir. May 27, 2026), a Colorado...

Delegated Arbitrability Binds Courts: Arbitrator May Permit Litigation of Non-Signatory Tort Claims Absent an Arbitration Agreement

Date: Jun 2, 2026

Delegated Arbitrability Binds Courts: Arbitrator May Permit Litigation of Non-Signatory Tort Claims Absent an Arbitration Agreement Case: SJH 11 LLC v. Dowbuilt, Inc. (No. 25-8037) — United States...

Nonappealability of Mediation-Deferral Orders that Deny Immunity Motions Without Prejudice and Suspend Litigation Burdens (28 U.S.C. § 1291)

Date: Jun 2, 2026

Nonappealability of Mediation-Deferral Orders that Deny Immunity Motions Without Prejudice and Suspend Litigation Burdens (28 U.S.C. § 1291) I. Introduction Lopez v. Ramirez (5th Cir. May 27, 2026)...

USSG § 2K2.1(a)(3) Large-Capacity Magazine Enhancement Applies Without Knowledge; Lack of Knowledge Is Only Mitigation for § 3553(a)

Date: Jun 2, 2026

USSG § 2K2.1(a)(3) Large-Capacity Magazine Enhancement Applies Without Knowledge; Lack of Knowledge Is Only Mitigation for § 3553(a) I. Introduction Case: United States v. Travis Lee Morgan (Fourth...

Waiver of State Jury-Trial Claims in Agency Enforcement and Deference to Preclusive Agency Factfinding in Excessive-Fines Review

Date: Jun 2, 2026

Waiver of State Jury-Trial Claims in Agency Enforcement and Deference to Preclusive Agency Factfinding in Excessive-Fines Review I. Introduction SmartEnergy Holdings, LLC v. Frederick Hoover (4th...

Bowman Wrongful-Discharge Claims Must Rest on an Explicit Virginia Statute (Not a Regulation), and VWPA Protection Requires Reporting a Legal Violation (Not Merely “Inappropriate” Conduct)

Date: Jun 2, 2026

Bowman Wrongful-Discharge Claims Must Rest on an Explicit Virginia Statute (Not a Regulation), and VWPA Protection Requires Reporting a Legal Violation (Not Merely “Inappropriate” Conduct) I....

Fourth Circuit: No Federal Jurisdiction for Post-Judgment Veil-Piercing to Collect WARN Act/ERISA Money Judgments from Nonparties

Date: Jun 2, 2026

Fourth Circuit: No Federal Jurisdiction for Post-Judgment Veil-Piercing to Collect WARN Act/ERISA Money Judgments from Nonparties 1. Introduction Tony Messer and other former employees of Bristol...

Third Circuit Reaffirms Enforcement of Broad Plea-Agreement Appellate Waivers Absent a “Miscarriage of Justice”

Date: Jun 2, 2026

Third Circuit Reaffirms Enforcement of Broad Plea-Agreement Appellate Waivers Absent a “Miscarriage of Justice” Introduction In United States v. Leroy Roebuck, Jr. (3d Cir. May 27, 2026), the Court...

Third Circuit: Unpreserved Public-Trial Violations from COVID-Era Closures and Spectator Exclusions May Not Merit Reversal Under Plain-Error Prong Four

Date: Jun 2, 2026

Third Circuit: Unpreserved Public-Trial Violations from COVID-Era Closures and Spectator Exclusions May Not Merit Reversal Under Plain-Error Prong Four Case: United States v. Kareem Harry (with...

Session-Replay Privacy Suits Require Concrete, Traditionally Analogous Harm—Statutory Labels and Anonymized Tracking Alone Do Not Create Article III Standing

Date: Jun 2, 2026

Session-Replay Privacy Suits Require Concrete, Traditionally Analogous Harm—Statutory Labels and Anonymized Tracking Alone Do Not Create Article III Standing Case: Malinda Smidga v. Spirit Airlines,...

Living at the Drug-Distribution Location “Easily Proves” Maintaining a Premises Under U.S.S.G. § 2D1.1(b)(12) Without Ownership, and Unobjected PSR Facts Control

Date: Jun 2, 2026

Living at the Drug-Distribution Location “Easily Proves” Maintaining a Premises Under U.S.S.G. § 2D1.1(b)(12) Without Ownership, and Unobjected PSR Facts Control I. Introduction In United States v....

Duress in Illegal-Reentry Cases: Telephone Threats and Speculative Surveillance Are Insufficient to Show an “Immediate Threat”

Date: Jun 2, 2026

Duress in Illegal-Reentry Cases: Telephone Threats and Speculative Surveillance Are Insufficient to Show an “Immediate Threat” 1. Introduction In United States v. Bustillos-Perea (10th Cir. May 29,...

Telephone Threats and Speculative Surveillance Are Insufficient “Immediacy” for a Duress Defense to Unlawful Reentry

Date: Jun 2, 2026

Telephone Threats and Speculative Surveillance Are Insufficient “Immediacy” for a Duress Defense to Unlawful Reentry 1. Introduction In United States v. Bustillos-Perea (10th Cir. May 29, 2026)...

Uncharged Tax-Year Loss Counts as Relevant Conduct When a Defendant Continues the Same Evasion Scheme, and “Sophisticated Means” Applies Even if the Scheme Was Purchased

Date: Jun 2, 2026

Uncharged Tax-Year Loss Counts as Relevant Conduct When a Defendant Continues the Same Evasion Scheme, and “Sophisticated Means” Applies Even if the Scheme Was Purchased Introduction In United States...