establishing-personal-jurisdiction-through-digital-communications-in-alienation-of-affections:-mississippi-supreme-court Case Commentaries

Stone v. Powell Forecloses § 2255 Fourth Amendment Relitigation Absent a Debatable Brady/IAC Showing; “Blanket Suppression” Demands Foster-Level Flagrant Disregard

Date: May 22, 2026

Stone v. Powell Forecloses § 2255 Fourth Amendment Relitigation Absent a Debatable Brady/IAC Showing; “Blanket Suppression” Demands Foster-Level Flagrant Disregard I. Introduction In United States v....

Anders Review in Supervised-Release Revocations: Reentry-Center Conditions Are Lawful; Concurrent Multi-Count Sentencing Error May Be Harmless

Date: May 22, 2026

Anders Review in Supervised-Release Revocations: Reentry-Center Conditions Are Lawful; Concurrent Multi-Count Sentencing Error May Be Harmless 1. Introduction In United States v. Roscoe Chambers (7th...

Permanent Disbarment Under Amended Rule XIX: Egregious Bank-Fraud Misconduct Plus No Reasonable Expectation of Rehabilitation

Date: May 22, 2026

Permanent Disbarment Under Amended Rule XIX: Egregious Bank-Fraud Misconduct Plus No Reasonable Expectation of Rehabilitation Case: In re: Gregory Joseph St. Angelo, No. 2026-B-0360 (La. May 19,...

EFTA “Notice of Error” Must Be Pleaded with Statutory Specificity; “Best Case” Dismissal and Prefiling Injunction Affirmed

Date: May 22, 2026

EFTA “Notice of Error” Must Be Pleaded with Statutory Specificity; “Best Case” Dismissal and Prefiling Injunction Affirmed 1. Introduction In Reyna v. Block (5th Cir. May 18, 2026) (per curiam)...

Roberson v. DeAnda: Probable Cause for “Interference” When a Bystander Refuses to Step Aside and Disrupts an Investigation; Resistance Independently Supplies Probable Cause; Undeveloped Property Claims Are Forfeited at Summary Judgment

Date: May 22, 2026

Roberson v. DeAnda: Probable Cause for “Interference” When a Bystander Refuses to Step Aside and Disrupts an Investigation; Resistance Independently Supplies Probable Cause; Undeveloped Property...

Non-Signatory Debt-Collection Law Firms Cannot Compel Arbitration as “Servicers” Absent Clear Contract Language

Date: May 22, 2026

Non-Signatory Debt-Collection Law Firms Cannot Compel Arbitration as “Servicers” Absent Clear Contract Language I. Introduction Donte Jackson v. Protas, Spivok & Collins LLC (Fourth Circuit, May 18,...

Erroneously Refunded Underpayment Interest Constitutes “Unpaid Tax” Eligible for § 6015(f) Innocent-Spouse Relief

Date: May 22, 2026

Erroneously Refunded Underpayment Interest Constitutes “Unpaid Tax” Eligible for § 6015(f) Innocent-Spouse Relief 1. Introduction In Catherine LaRosa v. Commissioner of Internal Revenue (4th Cir. May...

Compensatory Education May Include Multi‑Year Residential Placement to Remedy FAPE Denial Without Usurping the IEP Team (S. M. v. Chichester School District)

Date: May 22, 2026

Compensatory Education May Include Multi‑Year Residential Placement to Remedy FAPE Denial Without Usurping the IEP Team (S. M. v. Chichester School District) 1. Introduction S. M. v. Chichester...

Financial-Management Vendors in Self-Directed Medicaid Programs Are Not Joint Employers Absent “Significant Control”

Date: May 22, 2026

Financial-Management Vendors in Self-Directed Medicaid Programs Are Not Joint Employers Absent “Significant Control” I. Introduction Ralph Talarico v. Public Partnerships LLC (3d Cir. May 19, 2026)...

Complaint Exhibits Can Defeat an FCRA § 1681s-2(b) Claim and Rule 9(b) Strictly Bars Vague Fraud/Conspiracy Pleading

Date: May 22, 2026

Complaint Exhibits Can Defeat an FCRA § 1681s-2(b) Claim and Rule 9(b) Strictly Bars Vague Fraud/Conspiracy Pleading I. Introduction In Gutti Rao v. Sleep Number Bed, Inc (3d Cir. May 18, 2026)...

Shaffer Footnote 36 Extends to New York Convention Award Enforcement: Property-Based (Quasi in Rem) Jurisdiction Without Minimum Contacts

Date: May 22, 2026

Shaffer Footnote 36 Extends to New York Convention Award Enforcement: Property-Based (Quasi in Rem) Jurisdiction Without Minimum Contacts I. Introduction Sociedad Concesionaria Metropolitana de Salud...

Rule 701 Boundary: Narcotics “Modus Operandi” Opinions Untethered to Case Facts Are Expert Testimony (Harmless Here)

Date: May 22, 2026

Rule 701 Boundary: Narcotics “Modus Operandi” Opinions Untethered to Case Facts Are Expert Testimony (Harmless Here) Case: United States v. Jabar Evans Court: Court of Appeals for the Third Circuit...

Turcios-Ortiz v. Blanche: Serious Nonpolitical Crime Bar Is Fact-Reviewed for Substantial Evidence and Admits No Duress Exception

Date: May 22, 2026

Serious Nonpolitical Crime Bar: Substantial-Evidence Review, Probable-Cause “Serious Reasons to Believe,” and No Duress Exception (Tenth Circuit) 1. Introduction Case: Turcios-Ortiz v. Blanche, No....

Arguable Probable Cause to Arrest for Kansas “Interference” Defeats Clearly-Established Prong in Citizen-Journalist Retaliatory Arrest Claims at the Pleading Stage

Date: May 22, 2026

Arguable Probable Cause to Arrest for Kansas “Interference” Defeats Clearly-Established Prong in Citizen-Journalist Retaliatory Arrest Claims at the Pleading Stage Case: Eravi v. City Commission of...

Drug-Trafficking Nexus to a Residence: Reliable Informant Tips Plus Agent Experience Can Supply Probable Cause; Immaterial Misstatements Defeat a Franks Claim

Date: May 22, 2026

Drug-Trafficking Nexus to a Residence: Reliable Informant Tips Plus Agent Experience Can Supply Probable Cause; Immaterial Misstatements Defeat a Franks Claim Case: United States v. Cangro, No....

Rule 16(a)(1)(G) Rebuttal-Expert Disclosure Is Triggered Only by the Defense’s Timely Disclosed Expert Opinions (Not Undisclosed New Trial Opinions)

Date: May 22, 2026

Rule 16(a)(1)(G) Rebuttal-Expert Disclosure Is Triggered Only by the Defense’s Timely Disclosed Expert Opinions (Not Undisclosed New Trial Opinions) Case: United States v. Crow (No. 24-1377) | Court:...

Extraordinary Writs from Interlocutory Criminal Orders Require a Gaughan Findings Order; the State Must Show “Flagrant” Prejudice to Prosecute

Date: May 22, 2026

Extraordinary Writs from Interlocutory Criminal Orders Require a Gaughan Findings Order; the State Must Show “Flagrant” Prejudice to Prosecute Case: State of West Virginia ex rel. State of West...

State v. Pinkerton—Holistic Probable Cause for Cell-Phone Records and Voluntary Buccal-Swab Consent Assessed by Totality of Circumstances

Date: May 22, 2026

State v. Pinkerton—Holistic Probable Cause for Cell-Phone Records and Voluntary Buccal-Swab Consent Assessed by Totality of Circumstances 1. Introduction State v. Isaiah Pinkerton (R.I. May 19, 2026)...

Rule 32.1 Notice Must Track the Condition Alleged When Conduct Is Treated as a Higher-Grade “New Crime” Violation—But Plain-Error Relief Requires Prejudice

Date: May 22, 2026

Rule 32.1 Notice Must Track the Condition Alleged When Conduct Is Treated as a Higher-Grade “New Crime” Violation—But Plain-Error Relief Requires Prejudice Case: United States v. Ortiz-Rodríguez (1st...

Massachusetts Carjacking Is Not Categorically a Career-Offender “Crime of Violence” Under U.S.S.G. § 4B1.2(a)(1)

Date: May 22, 2026

Massachusetts Carjacking Is Not Categorically a Career-Offender “Crime of Violence” Under U.S.S.G. § 4B1.2(a)(1) I. Introduction In United States v. Pimental (1st Cir. May 20, 2026), the First...