Skechers — Appeals Court treats outsourced shoe production as manufacturing
The Massachusetts Appeals Court held that Skechers was a manufacturing corporation because its detailed control continued through outsourced production.
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Statutory Interpretation
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O’Hare v. Eddo — Free dealership loaner is not a Graves Amendment rental
The Fourth Department held that a free dealership courtesy vehicle is not a rental under the Graves Amendment, leaving New York owner liability intact.
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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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In re J.M. — Prosecutor may challenge an improperly offered juvenile diversion
A divided Utah Supreme Court held that a prosecutor may file a delinquency petition after an ineligible minor received a nonjudicial adjustment from probation.
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RMB v. Celotto — Dramshop settlements do not support statutory contribution
The Utah Supreme Court held that bars that voluntarily settle a Dramshop Act claim cannot seek contribution under a provision limited to persons against whom an award is made.
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Mt. Pleasant Investments v. Charleston County Assessor — ATI Exemption Caps Tax Value at Pre-Sale Baseline, Not Pre-Sale Plus Pre-ATI Improvements
The South Carolina Court of Appeals reversed the Administrative Law Court’s property tax ruling, holding that the “current fair market value” floor for the ATI exemption is the pre-sale value on the assessor’s books—not that value inflated by improvements the prior owner completed before the sale closed. Because the improvements were already incorporated into the ATI fair market value of $8,034,000 used to compute the exemption value, the Assessor’s approach of re-adding them to the current fair market value floor impermissibly double-counted them. The taxable value for tax year 2022 was $6,063,000, not $6,821,000.
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In the Interest of RCR — Wyoming Boys’ School Cannot Hold Alleged Delinquents Before Adjudication
The Wyoming Supreme Court reversed a contempt order against the Wyoming Boys’ School for refusing to admit an alleged delinquent juvenile before adjudication. The court held that Wyoming law expressly prohibits pre-adjudication placement at WBS, which is a reformatory for adjudicated delinquents — not a juvenile detention facility — and that the juvenile court abused its discretion by ordering such placement. All three exceptions to the mootness doctrine applied, allowing the court to reach the merits despite the case having been resolved below.