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  • Commentaries
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new-precedent-on... Case Commentaries

State v. Jaeger: Clarifying Rule 36 Clerical Corrections of Jail Credit and the Absence of a Right to Counsel in Non‑Critical Sentencing Modifications

State v. Jaeger: Clarifying Rule 36 Clerical Corrections of Jail Credit and the Absence of a Right to Counsel in Non‑Critical Sentencing Modifications

Date: Dec 20, 2025
State v. Jaeger: Clarifying Rule 36 Clerical Corrections of Jail Credit and the Absence of a Right to Counsel in Non‑Critical Sentencing Modifications Introduction In State v. Jaeger, 2025 ND 222,...
Estate of Lepp: Finality, Timeliness, and Rule 54(b) in Unsupervised Probate Appeals

Estate of Lepp: Finality, Timeliness, and Rule 54(b) in Unsupervised Probate Appeals

Date: Dec 20, 2025
Estate of Lepp: Finality, Timeliness, and Rule 54(b) in Unsupervised Probate Appeals I. Introduction The North Dakota Supreme Court’s decision in Estate of Lepp, 2025 ND 216, is a jurisdictional...
Express Authority and Agent‑Amended Trusts under N.D.C.C. § 59‑14‑02(5): Commentary on Matter of William C. Hansen and Verna Hansen Trust, 2025 ND 220

Express Authority and Agent‑Amended Trusts under N.D.C.C. § 59‑14‑02(5): Commentary on Matter of William C. Hansen and Verna Hansen Trust, 2025 ND 220

Date: Dec 20, 2025
Express Authority and Agent‑Amended Trusts under N.D.C.C. § 59‑14‑02(5): Commentary on Matter of William C. Hansen and Verna Hansen Trust, 2025 ND 220 I. Introduction Matter of William C. Hansen and...
State v. Hoff (2025 ND 215): Functional Waiver of Counsel and the Necessity of Timely Faretta-Type Warnings

State v. Hoff (2025 ND 215): Functional Waiver of Counsel and the Necessity of Timely Faretta-Type Warnings

Date: Dec 20, 2025
State v. Hoff (2025 ND 215): Functional Waiver of Counsel and the Necessity of Timely Faretta-Type Warnings I. Introduction In State v. Hoff, 2025 ND 215 (N.D. Dec. 18, 2025), the North Dakota...
Kolstad v. Claussen: Explicit Findings Required on Developmental-Needs and Domestic-Violence Best-Interest Factors in North Dakota Custody Cases

Kolstad v. Claussen: Explicit Findings Required on Developmental-Needs and Domestic-Violence Best-Interest Factors in North Dakota Custody Cases

Date: Dec 20, 2025
Kolstad v. Claussen: Explicit Findings Required on Developmental-Needs and Domestic-Violence Best-Interest Factors in North Dakota Custody Cases I. Introduction In Kolstad v. Claussen, 2025 ND 213,...
Limiting Water Resource District Cost Assessments to Landowners: Commentary on Fairville Township v. Wells County Water Resource District, 2025 ND 209

Limiting Water Resource District Cost Assessments to Landowners: Commentary on Fairville Township v. Wells County Water Resource District, 2025 ND 209

Date: Dec 20, 2025
Limiting Water Resource District Cost Assessments to Landowners: Commentary on Fairville Township v. Wells County Water Resource District, 2025 ND 209 I. Introduction The North Dakota Supreme Court’s...
Abandonment, Incarceration, and Step-Parent Adoption: The Constitutional Application of N.D.C.C. § 14-15-01(1) in Adoption of G.M.H.

Abandonment, Incarceration, and Step-Parent Adoption: The Constitutional Application of N.D.C.C. § 14-15-01(1) in Adoption of G.M.H.

Date: Dec 20, 2025
Abandonment, Incarceration, and Step-Parent Adoption: The Constitutional Application of N.D.C.C. § 14-15-01(1) in Adoption of G.M.H. I. Introduction The North Dakota Supreme Court’s decision in...
United States v. Sanchez‑Zurita: Enforceability of Informal Email-Based Sentencing Promises in Open Pleas

United States v. Sanchez‑Zurita: Enforceability of Informal Email-Based Sentencing Promises in Open Pleas

Date: Dec 20, 2025
United States v. Sanchez‑Zurita: Enforceability of Informal Email-Based Sentencing Promises in Open Pleas I. Introduction In United States v. Sanchez‑Zurita, No. 24‑60602 (5th Cir. Dec. 17, 2025),...
Disarming Debtors, Not Thieves: The Fifth Circuit Limits Lifetime Firearm Bans for Repaid Child‑Support Felonies – Commentary on United States v. Cockerham

Disarming Debtors, Not Thieves: The Fifth Circuit Limits Lifetime Firearm Bans for Repaid Child‑Support Felonies – Commentary on United States v. Cockerham

Date: Dec 20, 2025
Disarming Debtors, Not Thieves: The Fifth Circuit Limits Lifetime Firearm Bans for Repaid Child‑Support Felonies – Commentary on United States v. Cockerham I. Introduction In United States v....
United States v. Almonor: Rejecting a Foreseeability Requirement for Venue in Money Laundering Conspiracies

United States v. Almonor: Rejecting a Foreseeability Requirement for Venue in Money Laundering Conspiracies

Date: Dec 20, 2025
United States v. Almonor: Rejecting a Foreseeability Requirement for Venue in Money Laundering Conspiracies I. Introduction The Fourth Circuit’s unpublished decision in United States v. Pierre Yvelt...
When Private Improvement District Managers Become Public Agencies: Horvath v. DBIA Services and the Expansion of Functional Equivalency Under Washington’s Public Records Act

When Private Improvement District Managers Become Public Agencies: Horvath v. DBIA Services and the Expansion of Functional Equivalency Under Washington’s Public Records Act

Date: Dec 20, 2025
When Private Improvement District Managers Become Public Agencies: Horvath v. DBIA Services and the Expansion of Functional Equivalency Under Washington’s Public Records Act I. Introduction In...
Appellate Waiver through Inadequate Briefing and Incomplete Record: Commentary on Future Contracting & Estimators, LLC v. Allen

Appellate Waiver through Inadequate Briefing and Incomplete Record: Commentary on Future Contracting & Estimators, LLC v. Allen

Date: Dec 20, 2025
Appellate Waiver through Inadequate Briefing and Incomplete Record: Commentary on Future Contracting & Estimators, LLC v. Maelee Allen I. Introduction The Supreme Court of Rhode Island’s decision in...
No Expiration on Credibility: EES Inclusion of Former Officers and Old Misconduct under RSA 105:13-d

No Expiration on Credibility: EES Inclusion of Former Officers and Old Misconduct under RSA 105:13-d

Date: Dec 20, 2025
No Expiration on Credibility: EES Inclusion of Former Officers and Old Misconduct under RSA 105:13-d Introduction This commentary analyzes the New Hampshire Supreme Court’s order in John Doe v. New...
“Rumors, Denials, and Actual Knowledge”: The First Circuit Narrows Title IX Liability and Clarifies State-Created Danger in Hewes v. Gardiner

“Rumors, Denials, and Actual Knowledge”: The First Circuit Narrows Title IX Liability and Clarifies State-Created Danger in Hewes v. Gardiner

Date: Dec 20, 2025
“Rumors, Denials, and Actual Knowledge”: The First Circuit Narrows Title IX Liability and Clarifies State-Created Danger in Hewes v. Gardiner I. Introduction In Hewes v. Gardiner, No. 24-1736 (1st...
Terenzio v. Urena: Substantive Due Process, Voluntary State Care, and the Limits of Government Liability for COVID-19 in Veterans’ Homes

Terenzio v. Urena: Substantive Due Process, Voluntary State Care, and the Limits of Government Liability for COVID-19 in Veterans’ Homes

Date: Dec 20, 2025
Terenzio v. Urena: Substantive Due Process, Voluntary State Care, and the Limits of Government Liability for COVID-19 in Veterans’ Homes I. Introduction In Terenzio v. Urena, No. 24-1244 (1st Cir....
Smart Study v. Shenzhenshixindajixieyouxiangongsi: The Second Circuit Bars Email Service on Chinese Defendants Under the Hague Service Convention

Smart Study v. Shenzhenshixindajixieyouxiangongsi: The Second Circuit Bars Email Service on Chinese Defendants Under the Hague Service Convention

Date: Dec 20, 2025
Smart Study v. Shenzhenshixindajixieyouxiangongsi: The Second Circuit Bars Email Service on Chinese Defendants Under the Hague Service Convention I. Introduction In Smart Study Co., LTD v....
Clarifying Finality and Procedure in Florida Lawyer Discipline: Permanent Disbarment, Disciplinary Revocation Without Leave, and Grievance Committee Voting Under Amended Chapter 3

Clarifying Finality and Procedure in Florida Lawyer Discipline: Permanent Disbarment, Disciplinary Revocation Without Leave, and Grievance Committee Voting Under Amended Chapter 3

Date: Dec 20, 2025
Clarifying Finality and Procedure in Florida Lawyer Discipline: Permanent Disbarment, Disciplinary Revocation Without Leave, and Grievance Committee Voting Under Amended Chapter 3 I. Introduction...
Nonlawyer Control, Not‑for‑Profit Law Firms, and Authorized Business Entities: Commentary on the 2025 Amendments to Florida Rule 4‑8.6

Nonlawyer Control, Not‑for‑Profit Law Firms, and Authorized Business Entities: Commentary on the 2025 Amendments to Florida Rule 4‑8.6

Date: Dec 20, 2025
Nonlawyer Control, Not‑for‑Profit Law Firms, and Authorized Business Entities: Commentary on the 2025 Amendments to Florida Rule 4‑8.6 I. Introduction On December 18, 2025, the Supreme Court of...

      Clarifying the Boundary Between Local Court Rules and Administrative Orders:
      Commentary on In re Amendments to Florida Rules of General Practice and Judicial Administration (Fla. 2025)

Clarifying the Boundary Between Local Court Rules and Administrative Orders: Commentary on In re Amendments to Florida Rules of General Practice and Judicial Administration (Fla. 2025)

Date: Dec 20, 2025
Clarifying the Boundary Between Local Court Rules and Administrative Orders in Florida Trial Courts I. Introduction In In re: Amendments to Florida Rules of General Practice and Judicial...
Finality of Bond Validation Judgments and the Inapplicability of Rule 1.540: Commentary on State Attorneys v. Florida PACE Funding Agency

Finality of Bond Validation Judgments and the Inapplicability of Rule 1.540: Commentary on State Attorneys v. Florida PACE Funding Agency

Date: Dec 20, 2025
Finality of Bond Validation Judgments and the Inapplicability of Rule 1.540 in Chapter 75 Proceedings I. Introduction The consolidated decision in State Attorneys for the Second, Seventh and Ninth...
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