State v. Marx — Court rejects Brady and ineffective-assistance challenges
The Utah Court of Appeals affirmed child-sex-abuse and witness-tampering convictions, finding no material Brady violation or prejudicial attorney error.
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Appellate Procedure
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State v. Vance — Retaining stolen property is a continuing offense
The Utah Court of Appeals held that retaining stolen property can continue until possession ends, making the prosecution of a stolen skid steer timely.
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People v. Sablan — Court overturns conviction for undisclosed other-acts evidence
The Supreme Court of Guam overruled its prior decision, holding that discovery did not satisfy GRE 404(b) notice, and reversed Philips James Sablan’s conviction.
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11H, LLC v. Adegunle — Second Department confirms CPLR 3220 permits attorney-fee shifting
The Second Department held that CPLR 3220’s post-offer “expenses” include attorney fees and affirmed an $11,473 award after the plaintiff recovered less than the defendant’s contract-damages offer.
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Com. v. Stark, M. — Superior Court orders a new murder trial over prior-bad-acts evidence
Superior Court orders a new murder trial over prior-bad-acts evidence J-S44005-25 2026 PA Super 156 COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MICHAEL ALLEN STARK : : Appellant : No. 1648 EDA 2025 Appeal from the Judgment of Sentence Entered September 9, 2024 In the Court of Common Pleas of Bucks County Criminal Division at No(s): CP-09-CR-0003952-2023 BEFORE: LAZARUS, P.J., DUBOW, J., and SULLIVAN, J.
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Academy House Condo Assoc. v. B.S. Goldthorpe & B.E. Yelk — Court issues a substantive appellate ruling
Court issues a substantive appellate ruling IN THE COMMONWEALTH COURT OF PENNSYLVANIA Academy House Condominium : Association, : Appellant : : No. 250 C.D. 2025 v. : : Submitted: June 16, 2026 Brian S.
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Commonwealth v. Steadly, Q., Aplt. — Court issues a substantive appellate ruling
Court issues a substantive appellate ruling [J-62-2025] IN THE SUPREME COURT OF PENNSYLVANIA EASTERN DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Lukasik, G. v. Scotchlas, S.; Appeal of: Campbell, R. — As there was no other basis upon which the Superior Court could have determined that the trial court abused its…
As there was no other basis upon which the Superior Court could have determined that the trial court abused its… [J-10-2026] IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Adams, A., Aplt. v. AG — We vacate the Commonwealth Court’s order and remand for further proceedings consistent with this opinion.20…
We vacate the Commonwealth Court’s order and remand for further proceedings consistent with this opinion.20… [J-46-2026] IN THE SUPREME COURT OF PENNSYLVANIA WESTERN DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Commonwealth v. Sutton, S., Aplt. — Court issues a substantive appellate ruling
Court issues a substantive appellate ruling [J-81A-2025 and J-81B-2025] IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Commonwealth v. Shivers, P., Aplt. — Court issues a substantive appellate ruling
Court issues a substantive appellate ruling [J-64-2025] IN THE SUPREME COURT OF PENNSYLVANIA EASTERN DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Commonwealth v. Osman, M., Aplt. — The Superior Court erred in concluding otherwise, and we reverse that portion of its decision.
The Superior Court erred in concluding otherwise, and we reverse that portion of its decision. [J-85-2025] IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Punxsutawney Hunting Club v. PGC — Court issues a substantive appellate ruling
Court issues a substantive appellate ruling [J-20-2025] IN THE SUPREME COURT OF PENNSYLVANIA WESTERN DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Samsung v. RI Settlement; Apl. of: RI Settlement — Conclusion For the reasons provided, we hold that neither an insurer’s duty to defend nor its duty to indemnify…
Conclusion For the reasons provided, we hold that neither an insurer’s duty to defend nor its duty to indemnify… [J-65-2025] IN THE SUPREME COURT OF PENNSYLVANIA EASTERN DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ. SAMSUNG FIRE AND MARINE : No. 61 EAP 2024 INSURANCE CO., LTD (U.S.
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Commonwealth v. Hitchner, W., Aplt. — Court issues a substantive appellate ruling
Court issues a substantive appellate ruling [J-88-2025] IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.
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Matter of Cushlin Ltd. — Isle of Man Hotel Company Loses $14.5M NY Franchise Tax Fight
The Appellate Division confirmed over $14.5 million in NY corporate franchise tax deficiencies against an offshore Isle of Man hotel company that failed to file returns for seven years and then provided belated, unverifiable substantiation.
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Bozek v. Atlantic Wind — Internet Discovery of Wind Turbine Construction Did Not Toll MPC’s 30-Day Land Use Appeal Deadline
The Commonwealth Court affirmed the quashing of a land use appeal challenging a Fayette County wind power facility development plan, holding that the MPC’s 30-day appeal period ran from the date of the written approval decision — not from the objector’s internet discovery that construction had begun — and that the due process exception to the time limit must be affirmatively pleaded in the appeal.
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Jonah B. — Alaska Supreme Court affirms CINA dismissal after adoption deadline
The Alaska Supreme Court held that reversal of a parental-rights termination did not toll the one-year deadline to challenge a separate adoption decree, leaving the reopened CINA case moot.
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Rhodes v. Dilena — Hospital Loses Summary Judgment Win After Raising New Expert Theory in Reply Without Plaintiff’s Chance to Respond
Second Department affirms grant of reargument in OB malpractice case: trial court properly vacated its prior grant of summary judgment after recognizing it had overlooked defendants’ introduction — for the first time in reply — of a new ‘in-house obstetrician’ theory that plaintiff had no chance to rebut.
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Keller & Cruz v. Wyoming DFS — Section 14-2-309(a)(v) Requires No Reunification Efforts Finding, and DFS Procedural Gaps Do Not Defeat Termination Unless They Impair a Parent’s Fundamental Rights
The Wyoming Supreme Court affirmed the termination of both parents’ parental rights to three children under Wyo. Stat. Ann. § 14-2-309(a)(v), holding that the statute—requiring only that the child has been in foster care for 15 of the past 22 months and that the parent is unfit—does not impose a reasonable-reunification-efforts requirement; that DFS’s documentation gaps did not reach the structural failure level required by MB; and that clear and convincing evidence of parental unfitness supported the district court’s termination order.
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Smith v. Wyoming — Premature Willfulness Finding in Probation Revocation Adjudicatory Phase Is Error, But Not Plain Error Without Material Prejudice
The Wyoming Supreme Court affirmed a probation revocation, holding that the district court erred by determining willfulness during the adjudicatory phase rather than the dispositional phase—a clear violation of Wyoming’s two-part revocation framework—but that the error did not constitute plain error because Smith suffered no material prejudice: he presented his willfulness arguments before the court’s finding and again at disposition, and an independently established, uncontested violation independently supported revocation.
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State v. Simpson — Rule of Lenity Bars Two Concealed-Weapon Convictions for a Single Incident; Probation Period Also Vacated
The North Carolina Court of Appeals vacated a consolidated judgment entering two counts of carrying a concealed firearm under N.C. Gen. Stat. § 14-269(a1) arising from discovery of two guns in a single traffic stop. Applying the rule of lenity under the Conley line of cases, the court held that § 14-269(a1)’s “any pistol or gun” language is ambiguous as to unit of prosecution, permitting only one conviction per incident. The court also vacated a twenty-four-month probationary term imposed without the specific written findings required to exceed the statutory eighteen-month cap.
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N.C. State Bar v. Cummings — DHC’s Five-Year Suspension Vacated in Part; Hearsay and Willfulness Failures Undermine Three of Four Misconduct Findings
The North Carolina Court of Appeals unanimously affirmed a DHC finding that attorney Mark Cummings lied to Bar investigators about compensating a paralegal, but vacated three other misconduct findings—on failure to file 1099s (no willfulness finding by the DHC), a courtroom recording device (no evidence of an actual misrepresentation), and a residency misrepresentation (prior out-of-court statement inadmissible under Rules 804(b)(5) and 803(24) because the declarant testified live at the hearing). The case was remanded for the DHC to reconsider appropriate discipline based only on the violations that survived review.
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Campbell v. State — Totality of Circumstances, Not Paragraph-by-Paragraph Scrutiny, Controls Probable Cause Review
The Wyoming Supreme Court unanimously affirmed the denial of Christopher Campbell’s motion to suppress evidence seized from his Evanston residence, holding that Deputy Barker’s search-warrant affidavit established probable cause under the totality-of-circumstances test. The court rejected Campbell’s paragraph-by-paragraph critique of the affidavit as methodologically improper: Wyoming law requires courts to evaluate the affidavit as a whole, not in piecemeal fashion. Viewed in its totality, a convergence of circumstantial links—a matching U-Haul seen at the residence, receipts tying an associate to both the truck and the address, Arizona connections shared by the stolen vehicle and the occupants, and matching tire tracks—established the required nexus between the evidence sought and the place to be searched.