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Sixth Circuit Clarifies that Payments to Independent Contractors Do Not Constitute “Payroll Costs” under the CARES Act’s Paycheck Protection Program 1. Introduction In Veltor Underground, LLC v....
“Firm Waiver” and Anticipatory Procedural Bar Reinforced: Commentary on Burnett v. Harding, Tenth Circuit (2025) Introduction In Burnett v. Harding, the United States Court of Appeals for the Tenth...
Churchill v. Clark: Clarifying Pro-Se Limits—Waiver by Deficient Briefing and Rule 41(b) Dismissals Introduction Case: Churchill v. Clark, No. 24-7065, United States Court of Appeals for the Tenth...
Tenth Circuit Affirms Broad Sentencing-Court Discretion on Acceptance-of-Responsibility and Extreme-Conduct Departures – United States v. Born Introduction On 11 July 2025 the United States Court of...
“From Pattern to Episode” – The Seventh Circuit’s Landmark Re-definition of Title IX Liability in Isabelle Arana v. Board of Regents of the University of Wisconsin 1. Introduction On 11 July 2025 the...
“From Galarza to Rahimzadeh” – Seventh Circuit Confirms that Commercial Auto Policies May Condition UIM Coverage on Occupancy 1. Introduction The Seventh Circuit’s decision in Jason Rahimzadeh v. Ace...
United States v. Karagianis: The Seventh Circuit Clarifies that Omission of a § 3582(c)(2) Appeal-Waiver During a Rule 11 Colloquy Is Not Plain Error Absent a Showing of Prejudice 1. Introduction...
First Circuit Invalidates Maine’s “5% Foreign-Ownership” Election-Spending Ban Central Maine Power Co. v. Maine Commission on Governmental Ethics & Election Practices, No. 24-1265 (1st Cir. 2025) 1....
Clarifying Objections to Magistrate Reports and Pleading Requirements under N.Y. GBL § 399-p: A Commentary on Oparaji v. Home Retention Corp., 24-1444-cv (2d Cir. July 10, 2025) I. Introduction...
Predicate Exception Re-Defined: Second Circuit Affirms State Gun-Specific Public Nuisance Statute under PLCAA Commentary on National Shooting Sports Foundation, Inc. v. James, 90 F.4th ___ (2d Cir....
Second Circuit Clarifies the “Offense-Guideline Exception” to the Official-Victim Enhancement – Commentary on United States v. Cooke (2025) I. Introduction In United States v. Cooke, No. 24-1967 (2d...
United States v. Thompson: Clarifying the Individualized-Assessment Requirement and Affirming Broad Electronic-Search Conditions on Supervised Release 1. Introduction In United States v. Thompson,...
Johnson v. Spalding County: The Eleventh Circuit Tightens the Double-Hearsay Gate at Summary Judgment and Re-affirms that a “Convincing Mosaic” Is Not a Separate Test Introduction Happy Johnson, the...
Breedlove v. Christian: No Per-Se Bad-Faith Presumption for Police Body-Cam Spoliation & Early Qualified-Immunity Dismissals Reaffirmed Introduction On 13 March 2021 the Clayton County Police...
Eleventh Circuit Clarifies that Alabama Wrongful-Foreclosure Claims Do Not Require Mortgagees to Produce the Original Note (“Show-Me-the-Note”) Haywood Jackson Mizell v. Wells Fargo Bank, N.A. 1....
Unwritten Qualification Thresholds as Evidence of Pretext: A Comprehensive Commentary on Scott v. Macon-Bibb County, Georgia (11th Cir. 2025) Introduction In Scott v. Macon-Bibb County, Georgia, No....
United States v. Pettway: Re-entrenching § 922(g)(1) After Rahimi and Clarifying “Intrinsic” Evidence & Sentencing Cross-References Introduction In United States v. James Pettway, No. 24-10422 (11th...
United States v. Michel: Clarifying the Scope of District-Court Discretion After Guideline Amendment 821 in § 3582(c)(2) Proceedings 1. Introduction United States v. Jonas Michel, No. 24-11699 (11th...
United States v. Thirkield – Re-confirming ACCA Predicate Status of Georgia Marijuana Convictions & The Continuing Constitutionality of 18 U.S.C. § 922(g)(1) Introduction The Eleventh Circuit’s...
“The Nose Still Knows” – Eleventh Circuit Re-Affirms that the Odor of Marijuana Alone Creates Probable Cause for a Vehicle Search Even After State-Level Legalization Commentary on United States v....