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

Idaho Adopts the “Reasonable Expectations” Test for LLC Member Oppression and Rejects Dissolution on Unpleaded “Illegal Conduct” Grounds

Date: May 28, 2026

Idaho Adopts the “Reasonable Expectations” Test for LLC Member Oppression and Rejects Dissolution on Unpleaded “Illegal Conduct” Grounds Introduction BEARDSLEE v. RATLIFF FAMILY LLC, NO. 1 (Idaho...

Rule 68 “More Favorable” Comparison Excludes Counterclaim Offsets and Looks Only to the Claim the Offeror Defends

Date: May 28, 2026

Rule 68 “More Favorable” Comparison Excludes Counterclaim Offsets and Looks Only to the Claim the Offeror Defends 1. Introduction In Susan Cornelius, as Personal Representative of the Estate of...

Individualized Findings Required for U.S.S.G. § 2B1.1(b)(10)(C) “Sophisticated Means”; Leadership May Establish “Caused” Conduct

Date: May 28, 2026

Individualized Findings Required for U.S.S.G. § 2B1.1(b)(10)(C) “Sophisticated Means”; Leadership May Establish “Caused” Conduct Case: United States v. Betsy Alexandra Medina (consolidated with...

Individualized “Sophisticated Means” Findings Required; Leadership Role Can Satisfy the Intent Requirement Under U.S.S.G. § 2B1.1(b)(10)(C)

Date: May 28, 2026

Individualized “Sophisticated Means” Findings Required; Leadership Role Can Satisfy the Intent Requirement Under U.S.S.G. § 2B1.1(b)(10)(C) I. Introduction This unpublished consolidated Eleventh...

ALJs Must Address SSR 19-4p and Listing 11.02(B) When Evaluating Migraines at Step Three

Date: May 28, 2026

ALJs Must Address SSR 19-4p and Listing 11.02(B) When Evaluating Migraines at Step Three Case: Pakita Wright v. Commissioner of Social Security Court: United States Court of Appeals for the Eleventh...

Parens Patriae Cannot Supply Standing in Ohio Mandamus Actions: Attorney General Must Show Direct Beneficial Interest or Statutory Authority

Date: May 28, 2026

Parens Patriae Cannot Supply Standing in Ohio Mandamus Actions: Attorney General Must Show Direct Beneficial Interest or Statutory Authority Introduction In State ex rel. Yost, Atty. Gen., v....

U.S.S.G. § 2K2.1(b)(6)(B) “In Connection With” Satisfied When the Firearm Is an Element of a Distinct Concealed-Carry Felony; Unpronounced Supervised-Release Conditions Must Be Vacated

Date: May 28, 2026

U.S.S.G. § 2K2.1(b)(6)(B) “In Connection With” Satisfied When the Firearm Is an Element of a Distinct Concealed-Carry Felony; Unpronounced Supervised-Release Conditions Must Be Vacated Case: United...

Sufiyan v. Blanche: The BIA Must Make “But-For” Merits Findings When the Material Support Bar Is Dispositive and a DHS Waiver Requires “Otherwise Eligible” Status

Date: May 28, 2026

Sufiyan v. Blanche: The BIA Must Make “But-For” Merits Findings When the Material Support Bar Is Dispositive and a DHS Waiver Requires “Otherwise Eligible” Status I. Introduction In Sufiyan v....

Visual-Simulation Requirement Extends to Solar-Project Substations as Part of the “Facility” Under Ohio Power Siting Board Rules

Date: May 28, 2026

Visual-Simulation Requirement Extends to Solar-Project Substations as Part of the “Facility” Under Ohio Power Siting Board Rules In re Application of Oak Run Solar Project, L.L.C., Slip Opinion No....

BP3 Capital, LLC v. 5120 Realty Corp. (2d Dept 2026): Lender Must Reasonably Verify Corporate Agent Authority; Apparent Authority Cannot Be Self-Created; Liberal Amendment of Pleadings

Date: May 28, 2026

BP3 Capital, LLC v. 5120 Realty Corp.: Apparent Authority in Corporate Mortgage Closings Requires Principal-Based Conduct and a Reasonable Lender Inquiry (and CPLR 3025(b) Amendments Should Be...

Matter of Julien v. Arthur — Sanctions for Unverified GenAI Hallucinations in Appellate Briefs (Including Pro Se Litigants)

Date: May 28, 2026

Unverified Generative-AI Case Citations Are “Frivolous Conduct” Under 22 NYCRR 130-1.1—Even for Pro Se Appellants Case: Matter of Julien v Arthur, 2026 NY Slip Op 03308 (App Div 2d Dept May 27, 2026)...

Denial of Summary Judgment Does Not Bar Trial Finding of “Willful and Avowed Obstruction” Supporting a Noncooperation Disclaimer Under Insurance Law § 3420

Date: May 28, 2026

Denial of Summary Judgment Does Not Bar Trial Finding of “Willful and Avowed Obstruction” Supporting a Noncooperation Disclaimer Under Insurance Law § 3420 1. Introduction Foddrell v Utica First Ins....

Environmental Deed Restrictions May “Run with the Land” by Surrounding Circumstances; Tax-Deed/Reemption Does Not Merge Away Recorded Restrictions

Date: May 28, 2026

Environmental Deed Restrictions May “Run with the Land” by Surrounding Circumstances; Tax-Deed/Redemption Does Not Merge Away Recorded Restrictions 1. Introduction Case: U & Me Homes, LLC v County of...

Relation-Back Allows Adding an Omitted Titled Owner in Foreclosure When United in Interest and on Notice

Date: May 28, 2026

Relation-Back Allows Adding an Omitted Titled Owner in Foreclosure When United in Interest and on Notice Introduction In BAC Home Loan Servicing, LP v MacPherson (2026 NY Slip Op 03285), the...

Fraud/Duress Allegations Can Defeat a Release at the Pleading Stage in Confession-of-Judgment/MCA Litigation

Date: May 28, 2026

Fraud/Duress Allegations Can Defeat a Release at the Pleading Stage in Confession-of-Judgment/MCA Litigation Case: Dual Diagnosis Treatment Ctr., Inc. v. Yellowstone Capital W., LLC, 2026 NY Slip Op...

Rent-Overcharge Class Actions: “Colorable Indicia of Fraud” Defeats Four-Year Time Bar and Supports Commonality, with Class Period Limited to Four Years Pre-Filing

Date: May 28, 2026

Rent-Overcharge Class Actions: “Colorable Indicia of Fraud” Defeats Four-Year Time Bar and Supports Commonality, with Class Period Limited to Four Years Pre-Filing 1. Introduction In Abdelrazek v...

State v. Rademacher (2026 ND 107): Presumptive Probation Requires Record-Based, Statute-Textual Aggravator Findings—Driving Alone Is Not “Trust/Responsibility,” and “Age and Vulnerability” Is Conjunctive

Date: May 28, 2026

State v. Rademacher (2026 ND 107): Presumptive Probation Requires Record-Based, Statute-Textual Aggravator Findings—Driving Alone Is Not “Trust/Responsibility,” and “Age and Vulnerability” Is...

Unverified AI-Generated Citations as “Knowing” False Statements Under ORPC 3.3 (Reciprocal Discipline Under RGDP 7.7)

Date: May 28, 2026

Unverified AI-Generated Citations as “Knowing” False Statements Under ORPC 3.3 (Reciprocal Discipline Under RGDP 7.7) I. Introduction STATE OF OKLAHOMA ex rel. OBA v. REEVES, 2026 OK 37, is an...

Second Circuit Requires Enhanced Anders Scrutiny When Electronic-Device Search Conditions Present Potentially Non-Frivolous Appellate Issues

Date: May 27, 2026

Second Circuit Requires Enhanced Anders Scrutiny When Electronic-Device Search Conditions Present Potentially Non-Frivolous Appellate Issues Introduction In United States v. Samuels (2d Cir. May 26,...

ERISA Actuarial Equivalence Requires Reasonable Assumptions; QPSA Charges Must Reasonably Reflect Increased Cost

Date: May 27, 2026

ERISA Actuarial Equivalence Requires Reasonable Assumptions; QPSA Charges Must Reasonably Reflect Increased Cost I. Introduction In William Drummond v. Southern Company Services, Inc., the Eleventh...