federal Case Commentaries

Louisiana v. Callais: Voting Rights Act Compliance Justifies Race-Based Districting Only Under a Narrowed, Politics-Controlled Section 2 Framework

Date: May 2, 2026

Louisiana v. Callais: Voting Rights Act Compliance Justifies Race-Based Districting Only Under a Narrowed, Politics-Controlled Section 2 Framework Introduction Louisiana v. Callais addresses a...

Sixth Circuit Holds 8 U.S.C. § 1252(b)(1)’s 30-Day Immigration Petition Deadline Is Subject to Equitable Tolling

Date: May 2, 2026

Sixth Circuit Holds 8 U.S.C. § 1252(b)(1)’s 30-Day Immigration Petition Deadline Is Subject to Equitable Tolling Introduction In Jorge Oxlaj-Perez v. Todd Blanche, the Sixth Circuit addressed a...

Deported Former State Prisoners Must Name a Current Custodian to Invoke Federal Habeas Jurisdiction

Date: May 2, 2026

Deported Former State Prisoners Must Name a Current Custodian to Invoke Federal Habeas Jurisdiction Introduction In St. John v. Campbell, the United States Court of Appeals for the First Circuit...

Responsive Prison Medical Care and Strict Summary-Judgment Rules Defeat Eighth Amendment Deliberate-Indifference Claims

Date: May 2, 2026

Responsive Prison Medical Care and Strict Summary-Judgment Rules Defeat Eighth Amendment Deliberate-Indifference Claims Introduction In Paul Smith v. Pamela Hart, the Seventh Circuit affirmed summary...

Later Interpreter Disqualification Does Not Require Reopening Without Specific Mistranslation or Prejudice

Date: May 2, 2026

Later Interpreter Disqualification Does Not Require Reopening Without Specific Mistranslation or Prejudice Introduction In Efra Samba Deh v. Todd Blanche, the Sixth Circuit addressed whether...

Chapter 13 Means-Test Compliance Does Not Immunize a Plan from Good-Faith Review

Date: May 2, 2026

Chapter 13 Means-Test Compliance Does Not Immunize a Plan from Good-Faith Review Introduction In Bobby Goddard v. Michael Burnett, the Fourth Circuit addressed whether a Chapter 13 debtor who...

Invited Error Bars First-Time Challenge to Large-Capacity-Magazine Enhancement Absent Manifest Injustice

Date: May 1, 2026

Invited Error Bars First-Time Challenge to Large-Capacity-Magazine Enhancement Absent Manifest Injustice Introduction In United States v. Ricky House, the Sixth Circuit affirmed a 96-month sentence...

Rehaif Claims Are Not “Novel” Cause for Procedural Default When Their Legal Basis Was Previously Available

Date: May 1, 2026

Rehaif Claims Are Not “Novel” Cause for Procedural Default When Their Legal Basis Was Previously Available Introduction In United States v. Aaron Lyons, the Third Circuit addressed whether a federal...

Undisputed PSR Facts and Corroborated Co-Conspirator Statements May Support Drug-Quantity Estimates at Sentencing

Date: May 1, 2026

Undisputed PSR Facts and Corroborated Co-Conspirator Statements May Support Drug-Quantity Estimates at Sentencing Introduction In United States v. Freeman, the Tenth Circuit affirmed Jerry Lana...

United States v. Crabbe: Cooperation Talk Without Promises Does Not Invalidate a Miranda Waiver, and a Lesser-Included Possession Instruction Requires Supporting Evidence

Date: May 1, 2026

Cooperation Talk Without Promises Does Not Invalidate a Miranda Waiver, and a Lesser-Included Possession Instruction Requires Supporting Evidence Introduction In United States v. Otis Furman Crabbe,...

Invoking § 1442 Opens § 1447(d) Review, but Unsupported Federal-Officer Removal and Unpreserved Arguments Fail

Date: May 1, 2026

Invoking § 1442 Opens § 1447(d) Review, but Unsupported Federal-Officer Removal and Unpreserved Arguments Fail Introduction Winn v. Wakat concerns two consolidated appeals arising from August Wakat’s...

Attorney Discipline Upheld Where Recusal, Notice, and Privilege Objections Show No Prejudice or Objective Bias

Date: May 1, 2026

Attorney Discipline Upheld Where Recusal, Notice, and Privilege Objections Show No Prejudice or Objective Bias Introduction In In re Van Irion, the Sixth Circuit affirmed disciplinary sanctions...

Money-Motivated Gang Extortion, Without Protected-Ground Motive, Does Not Establish Asylum Nexus

Date: May 1, 2026

Money-Motivated Gang Extortion, Without Protected-Ground Motive, Does Not Establish Asylum Nexus Introduction In Julio Francisco Sebastian v. Todd Blanche, the Sixth Circuit denied a petition for...

Independent Traffic Violations and Concurrent Dog Sniffs Sustain Fourth Amendment Stops

Date: May 1, 2026

Independent Traffic Violations and Concurrent Dog Sniffs Sustain Fourth Amendment Stops Introduction In United States v. Salcido-Gonzalez, the Tenth Circuit affirmed the conviction of Rene...

Default Is Not Damages Proof: Lanham Act Plaintiffs Must Support Enhanced Statutory Damages After Default

Date: May 1, 2026

Default Is Not Damages Proof: Lanham Act Plaintiffs Must Support Enhanced Statutory Damages After Default Introduction In Shenzhen Huajie Technology Co., Ltd. v. Shenzhen Leyibei Technology Co.,...

Specific Causation Evidence Is Required for Health-Risk-Based Disability Accommodations

Date: May 1, 2026

Specific Causation Evidence Is Required for Health-Risk-Based Disability Accommodations Introduction In Friedman v. Central Maine Power Company, the First Circuit affirmed summary judgment for...

Grey v. Vengroff Williams: No Summary-Judgment Escape Without Evidence of a Convincing Mosaic of ADA or ADEA Discrimination

Date: May 1, 2026

Grey v. Vengroff Williams: No Summary-Judgment Escape Without Evidence of a Convincing Mosaic of ADA or ADEA Discrimination Introduction In Deborah Grey v. Vengroff Williams, Inc., the Eleventh...

Sixth Circuit Adopts IIRIRA Substantial-Evidence Review for Cancellation-of-Removal Hardship Determinations

Date: May 1, 2026

Sixth Circuit Adopts IIRIRA Substantial-Evidence Review for Cancellation-of-Removal Hardship Determinations Introduction In Jose Baltazar Us v. Todd Blanche, the Sixth Circuit denied Jose Baltazar...

A K-9 Warning Does Not Defeat the Clearly Established Right Against Gratuitous Dog-Bite Force

Date: May 1, 2026

A K-9 Warning Does Not Defeat the Clearly Established Right Against Gratuitous Dog-Bite Force on a Non-Threatening, Unarmed, Passively Resisting Suspect Introduction In Richard Harrold v. Lewis...

Virginia Firearm Use During Robbery Is a Guidelines Crime of Violence; Drug-Trafficking Conspiracy Remains a Controlled Substance Offense in the First Circuit

Date: May 1, 2026

Virginia Firearm Use During Robbery Is a Guidelines Crime of Violence; Drug-Trafficking Conspiracy Remains a Controlled Substance Offense in the First Circuit Introduction In United States v. Mao,...