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

No Dixon-Like Procedural Bar in Penal Code Section 1172.6 Imputed-Malice Resentencing Petitions

Date: May 5, 2026

No Dixon-Like Procedural Bar in Penal Code Section 1172.6 Imputed-Malice Resentencing Petitions Introduction In People v. Lopez, the Supreme Court of California clarified the scope of resentencing...

State v. Flores Commentary

Date: May 5, 2026

State v. Flores: Nebraska Reaffirms That Standard Aiding-and-Abetting Instructions Suffice and Juvenile De Facto Life Sentences May Stand When the Court Has Sentencing Discretion Introduction In...

State v. Abrams: Washington Vacatur Requires Release from All Confinement and Evidence of Rehabilitation

Date: May 5, 2026

State v. Abrams: Washington Vacatur Requires Release from All Confinement and Evidence of Rehabilitation Introduction In State v. Abrams, the Washington Supreme Court interpreted RCW 9.94A.640,...

Legislature May Not Strip Louisiana Courts of Jurisdiction to Order Necessary Indigent-Defense Expert Funding

Date: May 5, 2026

Legislature May Not Strip Louisiana Courts of Jurisdiction to Order Necessary Indigent-Defense Expert Funding Case Overview Case: State of Louisiana v. Maya Jones Court: Supreme Court of Louisiana...

Fourth Circuit Confirms Three-Part McDonough Test: Juror Dishonesty and Inferred Bias Do Not Automatically Require a New Trial

Date: May 5, 2026

Fourth Circuit Confirms Three-Part McDonough Test: Juror Dishonesty and Inferred Bias Do Not Automatically Require a New Trial Introduction In United States v. Andre Williamson, the Fourth Circuit...

Foster-Care Negligence Suits Directly Concern Program Administration, Allowing Discovery of Related Child Welfare Records

Date: May 5, 2026

Foster-Care Negligence Suits Directly Concern Program Administration, Allowing Discovery of Related Child Welfare Records Introduction In J.M.I. v. State, the Washington Supreme Court addressed...

Protective-Order Violations and Repeated Surveillance Can Establish Specific Intent for Felony Stalking in Wyoming

Date: May 5, 2026

Protective-Order Violations and Repeated Surveillance Can Establish Specific Intent for Felony Stalking in Wyoming Introduction In Brent Douglas Gayman v. The State of Wyoming, 2026 WY 49, the...

Consecutive Federal Sentences May Be Reasonable When Needed to Preserve Independent Punishment for Unrelated State and Federal Crimes

Date: May 5, 2026

Consecutive Federal Sentences May Be Reasonable When Needed to Preserve Independent Punishment for Unrelated State and Federal Crimes Introduction In United States v. Isaias Pablo-Fabin, the Eleventh...

Local Ties as Legitimate Hiring Criteria for Temporary Details and the Limits of Temporal Proximity in Retaliation Claims

Date: May 5, 2026

Local Ties as Legitimate Hiring Criteria for Temporary Details and the Limits of Temporal Proximity in Retaliation Claims Introduction In Renel Sample v. OPM, the Third Circuit affirmed summary...

Advisory Fishery Councils Do Not Cause Appointments Clause Injury When the Secretary Independently Promulgates Binding Rules

Date: May 5, 2026

Advisory Fishery Councils Do Not Cause Appointments Clause Injury When the Secretary Independently Promulgates Binding Rules Introduction In New England Fishermen's Stewardship Association v....

Ambiguous Lack-of-Remorse Remarks Do Not Establish Plain Error in Above-Guidelines Sentencing

Date: May 5, 2026

Ambiguous Lack-of-Remorse Remarks Do Not Establish Plain Error in Above-Guidelines Sentencing Introduction In United States v. Rodriguez, the Fifth Circuit affirmed an above-guidelines sentence...

Reverse FCA Liability Requires an Immediate Duty to Pay: No Claim for Unapplied-For Visa Fees or Taxes on Unpaid Wages

Date: May 5, 2026

Reverse FCA Liability Requires an Immediate Duty to Pay: No Claim for Unapplied-For Visa Fees or Taxes on Unpaid Wages Introduction In Palmer v. Tata Consulting Services, the Fifth Circuit affirmed...

Prior Supervised-Release Status Is Not Intrinsic Evidence Without a Direct Nexus to the Charged Crime

Date: May 5, 2026

Prior Supervised-Release Status Is Not Intrinsic Evidence Without a Direct Nexus to the Charged Crime Introduction In State of West Virginia v. Jeffrey John Paglia, the Supreme Court of Appeals of...

Conditional Nolle Prosequi Agreements Are Governed by Ordinary Contract Principles

Date: May 5, 2026

Conditional Nolle Prosequi Agreements Are Governed by Ordinary Contract Principles Introduction In State of Arkansas v. Luis Ramirez, 2026 Ark. 92, the Supreme Court of Arkansas addressed a novel...

No Abuse of Discretion Where Juvenile Recidivism Supports Denial of a Youth-Based Sentencing Variance

Date: May 5, 2026

No Abuse of Discretion Where Juvenile Recidivism Supports Denial of a Youth-Based Sentencing Variance Introduction In United States v. Derrion Turner, the Sixth Circuit affirmed a 246-month federal...

Terminated Conditional Permanent Residents Cannot Use Prior Five-Year Status to Obtain Cancellation of Removal

Date: May 5, 2026

Terminated Conditional Permanent Residents Cannot Use Prior Five-Year Status to Obtain Cancellation of Removal Introduction In Ghazi v. Blanche, the Fifth Circuit reviewed a petition by Said Ghazi, a...

Gang Extortion Claims Fail Absent Proof That Protected Status Motivated the Threats

Date: May 5, 2026

Gang Extortion Claims Fail Absent Proof That Protected Status Motivated the Threats Introduction In Iris Rodriguez Martinez v. Attorney General United States of America, the United States Court of...

First Circuit: Upward Variance Cannot Rest on 31 Rounds of Ammunition or Unsupported “Firearms of War” Facts

Date: May 5, 2026

First Circuit: Upward Variance Cannot Rest on 31 Rounds of Ammunition or Unsupported “Firearms of War” Facts Introduction In United States v. Rosa-Borges, the First Circuit revisited two sentences...

Postconviction DNA “Results” Include Underlying Data Needed for Statistical Analysis

Date: May 5, 2026

Postconviction DNA “Results” Include Underlying Data Needed for Statistical Analysis Introduction In James Aren Duckett v. State of Florida, the Supreme Court of Florida addressed whether a...

No Merits Ruling Without Jurisdiction: Insubstantial Federal Claims Must Be Dismissed Without Prejudice

Date: May 5, 2026

No Merits Ruling Without Jurisdiction: Insubstantial Federal Claims Must Be Dismissed Without Prejudice Introduction In James Giehl v. Ocwen Financial Corporation, the Eleventh Circuit reviewed a...