Legal Research

NC Reports Record 2,349 Data Breaches, 9.3M Exposed; AG Warns on Axios Hack

North Carolina businesses and government agencies reported 2,349 data breaches in 2025 — the most ever recorded in the state — exposing the personal information of nearly 9.3 million North Carolinians. On March 31, hackers published malicious versions of an update to Axios, a popular open-source JavaScript library, installing malware on any system that downloaded the compromised update. Attorney General Jeff Jackson is urging all North Carolina businesses to immediately check whether Axios is part of their software systems and to take remediation steps if affected. Businesses that discover personal information of North Carolinians was accessed are legally required to notify those affected and report the breach to the NC DOJ Consumer Protection Division.

Quick Reference Guides for Georgia Real Estate Rules

The Georgia Real Estate Commission has published GREC Notes, a collection of quick reference guides covering key rules, issues, and processes for real estate licensees. The page provides nine downloadable PDF guides including topics such as advertising rules, broker continuing education requirements, trust account management, reciprocity for licensees, and procedures for opening a real estate firm. These guides supplement the GA Real Estate License Law and State of Georgia Laws.

GREC Seeks Appraisal Investigator and Information Specialist

The Georgia Real Estate Commission and Georgia Appraisers Board is advertising two open positions: Appraisal Investigator and Information Specialist. Job seekers must submit the State Application for Employment along with position-specific requirements detailed in attached PDFs for each role.

3-Hour Online CE Courses and In-Class Options

The Georgia Real Estate Commission publishes an informational webpage listing available 3-hour online continuing education courses and in-class options for licensed real estate professionals in Georgia. The page provides direct links to external course registration pages operated by third-party providers. No new compliance obligations, deadlines, or regulatory changes are described.

State of the Commission Update

The Georgia Real Estate Commission published a routine status update page directing visitors to a PDF document titled 'State of GREC' for details on current commission activities and priorities. The page contains no substantive regulatory content beyond navigation links and social sharing options. No new rules, guidance, or compliance obligations are presented.

Anubis Bot Verification Blocks Access to Case 2026IEHC215

BAILII has deployed Anubis, a Proof-of-Work anti-bot verification system, on its legal database website. Users attempting to access case 2026IEHC215 encounter a challenge page requiring JavaScript execution before proceeding. The system uses Hashcash-style proof-of-work to increase computational costs for mass web scraping by AI companies, while intending minimal impact on legitimate individual users.

Cosmetology Licensing Portal - Florida Professional License Applications

The Florida Department of Business and Professional Regulation published a cosmetology licensing portal providing links to 27 different license application categories including cosmetologist examination, endorsement, re-examination, and military veteran fee waivers. The page covers individual licenses for cosmetologists, nail specialists, facial specialists, and full specialists, as well as salon licenses including mobile and flea market operations. Fee waiver programs for military personnel, veterans, military spouses, and low-income applicants are also listed.

License Application Center

The Florida Real Estate Commission Application Center provides centralized access to licensing information for five real estate license categories: Sales Associates/Broker-Sales Associates, Brokers, Real Estate Companies, Real Estate Schools, and Real Estate School Instructors. Fee waiver programs are also listed, including Florida Military Veteran Fee Waiver, Florida National Guard Fee Waiver, Military Personnel/Veterans/Military Spouses Licensing Fee Waiver, and Low Income Waiver of Licensing Fee. The page serves as a navigation portal for the Florida Department of Business & Professional Regulation's licensing services.

Florida DBPR License Portal - Architecture & Interior Design

The Florida Department of Business and Professional Regulation (DBPR) has published an online licensing portal providing comprehensive information for Architecture and Interior Design licensure. The portal offers multiple pathways including initial licensure by examination, NCARB certification endorsement, state endorsement, direct endorsement, reinstatement of null and void licenses due to hardship, and activation of inactive licenses. The page also includes information on fee waiver programs for military veterans, National Guard members, active duty military personnel, and low-income applicants. Separate sections cover architectural business organization qualification, continuing education provider approvals, and course certifications.

Alcoholic Beverages and Tobacco Licensing Portal

The Florida Department of Business & Professional Regulation (DBPR) maintains a web portal providing access to Alcoholic Beverages & Tobacco licensing services. The portal lists 11 license categories including Alcohol Brand Registrant, Bottle Club, Common Carriers, Limited Permits, Manufacturers/Distributors, Miscellaneous Permits, Pool Buying, Retail Beverage, Retail Tobacco Products Dealer Permit, Salesperson of Wine & Spirits, and Tobacco Wholesalers/Distributors/Exporters. Additional services include applications for lien interests, changes to existing licenses, manufacturer malt Florida imprinting exemptions, and standalone bar smoking forms. Users can apply for licenses, verify licensee status, check application status, and access printable applications through this centralized portal.

Florida Construction Contractor Licensing Services Portal

The Florida Department of Business and Professional Regulation (DBPR) hosts an online portal for construction contractor licensing through the Construction Contractors section of its Application Center. The portal distinguishes between two licensing types: Certified Licenses, which are statewide and allow contractors to work anywhere in Florida, and Registered Licenses, which are limited to specific local jurisdictions and only permit work in the cities or counties where the holder has a certificate of competency. Users can access licensing requirements, check application status, apply for licenses, or use the online application system.

United States v. Pence - Murder-for-Hire Conviction Upheld, Suppression Motion Denied

The Second Circuit affirmed Christopher Pence's conviction for using a facility of interstate commerce in connection with murder-for-hire under 18 U.S.C. § 1958(a). Pence sought to suppress statements he made to FBI agents before receiving Miranda warnings, arguing he was in custody when he was questioned in an FBI vehicle outside his Utah home. The court agreed with the district court that a reasonable person in Pence's circumstances would not have believed he was in custody, finding the interview was non-custodial because agents informed him he was not under arrest and was not obligated to answer questions, and because he voluntarily agreed to speak with agents and was unhandcuffed during the questioning.

Kwok v. Trustee - Alter Ego Finding Upheld in Chapter 11 Bankruptcy Appeal

The Second Circuit affirmed that a Chapter 11 trustee has standing to assert alter ego claims on behalf of bankruptcy estate creditors and that HK International Funds Investments (USA) Limited, LLC was the debtor's alter ego, with HK's assets belonging to the bankruptcy estate. The court found that HK had no revenue, bank accounts, officers, directors, employees, or independent business purpose—it existed solely to hold the Lady May mega-yacht worth tens of millions and the Lady May II worth approximately $1 million. The debtor, Ho Wan Kwok, exercised control over both vessels while listing only a Pomeranian and a few thousand dollars in his bankruptcy petition.

Schneiderman v. American Chemical Society - Diversity Jurisdiction

The Second Circuit affirmed dismissal of a diversity jurisdiction case brought by Arnold Schneiderman against the American Chemical Society (ACS), a federally chartered corporation, holding that 28 U.S.C. § 1332(c)(1) does not independently establish citizenship based on principal place of business alone. The court concluded that the statute's principal-place-of-business provision requires a corporation to first have a State of incorporation, and since federally chartered corporations like ACS are incorporated under federal law rather than any State, diversity jurisdiction was not established. The district court's dismissal was upheld along with its denial of reconsideration and motion to reopen for further discovery.

United States v. Barrett - Firearms Conviction and Sentencing Affirmed in Part, Vacated in Part on Remand

The Second Circuit withdrew Part III.A.2.c from its prior Barrett III opinion and vacated in part the judgment insofar as it vacated the district court's sentence on both Counts Six and Seven, remanding for resentencing consistent with the Supreme Court's Barrett IV ruling that Congress has not authorized convictions under both 18 U.S.C. §§ 924(c)(1)(A)(i) and (j) for one act. The district court must now exercise its discretion to vacate one of the two convictions (Count Six or Count Seven) and resentence Barrett accordingly, while the court's conclusion that the aggregate 50-year sentence was substantively reasonable remains undisturbed. Barrett's request for reassignment to a different judge on remand was denied.

USA v. Manuel Zumba Mejia - Illegal Reentry Collateral Challenge

The Second Circuit reversed the SDNY's October 29, 2024 order granting Manuel Zumba Mejia's motion to dismiss his illegal reentry charge under 8 U.S.C. §§ 1326(a) and (b)(2). The appellate court held that § 1326(d)'s requirements are mandatory and that no court may excuse a defendant's failure to satisfy them, expressly abrogating the Second Circuit's prior rule in United States v. Sosa, 387 F.3d 131 (2d. Cir. 2004) which had permitted courts to bypass exhaustion requirements when a defendant's waiver of administrative review was not knowing and intelligent. The case has been remanded for further proceedings consistent with the opinion. Defendants in the Second Circuit who previously relied on Sosa-type arguments to collaterally challenge removal orders must now satisfy all three § 1326(d) requirements before a court may consider such a challenge.

United States v. Goklu - Bitcoin Money Laundering Conviction Affirmed

The Second Circuit affirmed Mustafa Goklu's conviction for money laundering and operating an unlicensed money transmitting business based on bitcoin-for-cash exchanges with an undercover DEA officer. Between August 2018 and January 2019, Goklu conducted six exchanges totaling approximately $130,000 in bitcoin for cash. The court rejected challenges regarding jury impartialness, sufficiency of evidence, and jury instructions, holding that exchanging bitcoin for cash constitutes "money transmitting" under 18 U.S.C. § 1960.

Cruz v. Banks - Special Education IEP Placement Class Size Requirements

The Second Circuit affirmed that New York City's placement of a student with severe multiple disabilities in a 12:1:4 classroom under his June 2021 IEP did not violate the IDEA. The court held that 8 N.Y.C.R.R. § 200.6(h)(4) provides alternative placements rather than cumulative stacking requirements, allowing CSE committees to select among listed alternatives based on student needs. The SRO's finding that the 12:1:4 placement was appropriate was upheld, with the court noting O.F.'s need for increased adult support and his prior lack of progress in a 6:1:1 setting.

Campbell v. Broome County - Affirms § 1983 Dismissal in Part, Vacates on Firearms Seizure

The Second Circuit largely affirmed the District Court's sua sponte dismissal of pro se plaintiff David John Campbell's 42 U.S.C. § 1983 action, which alleged Fourth and Fourteenth Amendment violations arising from firearm permit and seizure disputes with Broome County, City of Binghamton officials, and a New York State Police trooper. The appellate court agreed the amended complaint was factually frivolous and failed to allege personal involvement of certain defendants or a municipal policy causing constitutional injury. The court vacated and remanded solely as to defendant Officer Nicholas Mushalla, finding he was not a defendant in a related action and that Campbell adequately pleaded a claim for unreasonable seizure of firearms and other items from his home.

Proposed Rules Public Comment Period April 10 - May 11, 2026

The Arkansas Real Estate Commission has opened a public comment period for proposed rules from April 10 through May 11, 2026. Comments may be submitted by email or mail to AREC's Little Rock office at 612 S. Summit, Little Rock, AR 72201. A public hearing will be held on May 12, 2026 at 9:00 a.m. at the same address, and those wishing to speak must attend in person. Copies of the proposed rules and public notice are available via links on the AREC website.

State Ethics Commission Spring 2026 Newsletter

The Pennsylvania State Ethics Commission published its Spring 2026 newsletter on March 24, 2026, providing updated media contact information for Executive Director Mary W. Fox. The newsletter includes links to the Commission's YouTube and LinkedIn social media channels.

State Ethics Commission Public Meeting Agenda April 16, 2026

The Pennsylvania State Ethics Commission will hold a public meeting on April 16, 2026, at 9:00 a.m. in Room 307 of the Finance Building in Harrisburg. The agenda includes approval of prior meeting minutes, 14 Civil Penalty Orders (one consent and 13 defaults), and 3 Administrative Penalty Orders (one consent and two defaults) related to lobbying violations, along with an operational report, regulations update, budget letters, and recognition of Senior Special Investigator Dan Bender.

State Ethics Commission Public Meeting - Regulations Update

The Pennsylvania State Ethics Commission will hold a public meeting on March 26, 2026 at 9:00 a.m. via teleconference from the Finance Building, Room 307, Harrisburg, PA. The agenda includes an administrative matters section and a regulations update involving review and approval of a revised rulemaking package. No specific compliance deadlines, obligations, or penalties are detailed in this meeting notice.

Commission Meeting April 17, 2026

The New Mexico State Ethics Commission will hold its next commission meeting on April 17, 2026, at 9:00 AM via virtual platform. Members of the public are welcomed and encouraged to attend, and the Commission will accept written public comment submitted to Ethics.Commission@sec.nm.gov with the subject line 'Public Comment: April 17, 2026' until 9:00 AM on the day of the meeting.

2026 Connecticut Campaign Finance Guide for Non-CEP Candidates

The Connecticut State Elections Enforcement Commission published its 2026 guidebook for statewide office and General Assembly candidates who are not participating in the Citizens' Election Program (CEP). The guide covers candidate registration, candidate committee formation, treasurer responsibilities, electronic online reporting (eCRIS), permissible contribution sources and limits, in-kind contributions, loans, impermissible sources, and various reportable and non-reportable receipts including organization expenditures, volunteer services, and independent expenditures. This is a comprehensive reference document for non-CEP candidates to understand Connecticut campaign finance laws.

Declaratory Ruling 2026-01: In-House Lobbyist Contributions by U.S. Subsidiaries of Foreign Corporations Under Public Act 24-28

The Connecticut State Elections Enforcement Commission issued Declaratory Ruling 2026-01 on October 30, 2025, addressing whether in-house lobbyists who are U.S. citizens employed by U.S. subsidiaries of foreign corporations qualify as "agents of a foreign principal" under Public Act 24-28. The Commission concluded that such lobbyists are not foreign agents solely by virtue of foreign ownership of the parent corporation. The ruling applies federal FARA standards, finding that agency requires more than foreign ownership — it requires evidence of direction or control by the foreign parent over the individual's lobbying or political activities.

April 2026 Quarterly Filing Deadlines

The Connecticut State Elections Enforcement Commission has published its April 2026 newsletter detailing quarterly filing deadlines for political committees. The April quarterly report filing period opened April 1, 2026 and closes Friday, April 10, 2026. All state central committees, town committees, political committees, and open candidate committees must file regardless of financial activity. The newsletter also announces availability of the 2026 CEP Guidebook for statewide and General Assembly candidates, pre-application review deadlines for CEP General Assembly campaigns, and 2026 CEP grant application calendars.

Housing Ombudsman Publishes 2026-27 Business Plan with Fee Increase

The Housing Ombudsman has published its Business Plan for 2026-27, raising the annual chargeable fee from £8.03 to £9.64 in a phased approach following sector feedback on the late timing of consultations. The plan maintains continuity with 2025-26 KPIs and reflects the stabilise phase of the caseload reduction strategy, aiming to stop complaint growth and ageing while delivering faster dispute resolution. The Ombudsman has committed to working with MHCLG to ensure future consultations occur in Quarter 3 of the preceding financial year.

International Protection Bill 2026 Passes Irish Oireachtas

The International Protection Bill 2026 has passed through both Houses of the Irish Oireachtas, representing the most significant reform of Irish asylum laws in the history of the State, in line with the EU Migration and Asylum Pact. The Bill introduces mandatory processing timelines ranging from two months under the inadmissibility procedure to six months under the ordinary procedure, and requires applicants to undergo screening including security checks, identity verification, and biometric registration on the Eurodac system. Asylum applicants, immigration authorities, and related service providers in Ireland will be directly affected by the new procedures once the Act is commenced.

ZUWIT Trademark Invalidity Decision O/0321/26

The UK Intellectual Property Office issued Decision O/0321/26 on 15 April 2026, declaring the ZUWIT trade mark in Class 12 (vehicles and transport) invalid following a challenge proceeding. Hearing Officer Ms L Bailey issued the determination, which affects the mark proprietor and parties with competing registrations in Class 12.

TEC Trademark Opposition Upheld Under Sections 5(1)-(4)

The UK Intellectual Property Office (UKIPO) upheld a trademark opposition against the TEC mark (covering Classes 01, 07, 08, 16) in Decision O/0319/26 dated 15 April 2026. Hearing Officer Ms L Fayter found in favour of the opponent based on earlier trademark rights under Sections 5(1), 5(2), 5(3), and 5(4), including distinctiveness, family of marks, and visual/aural/conceptual considerations. Procedural consolidation was also addressed.

Tado Trade Mark Opposition Decision O/0317/26

The UK Intellectual Property Office issued decision O/0317/26 on 14 April 2026 concerning the opposition to registration of the trade mark 'tado' across Classes 9, 35, 37, 39, and 42. The decision addresses grounds under Sections 5(1), 5(2), and 5(3), including imperfect recollection, dilution cases involving reputation, and revocation/proof of use matters including partial revocation for fair description of goods and services. The ruling is binding on the parties to the opposition.

Phoenix Figurative Series Two Opposition Decision

The UK Intellectual Property Office issued a trademark opposition decision under case O/0322/26 on 15 April 2026. The decision addresses procedural issues including pleadings, strike out, and estoppel in the opposition proceedings concerning the Phoenix (Figurative – Series of Two) mark across Classes 09 and 42.

Cristiano Ronaldo Origins Trade Mark Decision O/0318/26

UKIPO issued Decision O/0318/26 on 15 April 2026 regarding the Cristiano Ronaldo Origins trade mark application (Class 03). The decision examined grounds under Sections 5(1), 5(2), and 5(3) including composite word and device marks, treatment of descriptive/allusive elements, and dilution cases (reputation, link, and unfair disadvantage). The outcome determination is recorded in the decision document.

Digital Chopin Trademark Opposition Decision O/0315/26

UKIPO issued Decision O/0315/26 on 14 April 2026 regarding the 'Digital Chopin' trademark opposition. Hearing Officer Ms C Boucher ruled on grounds including Sections 5(1), 5(2), and 5(3) concerning imperfect recollection, dilution cases with reputation and link, and proof of use requirements. The decision addressed variant forms of marks and partial revocation for goods and services in Classes 09, 41, and 42.

JANUS Trade Mark Opposition Decision O/0316/26

The UK Intellectual Property Office issued decision O/0316/26 dated 14 April 2026 concerning trade mark opposition case JANUS (Figurative), covering Classes 06, 07, 09, 20, 42, and 45. The Hearing Officer Ms L Bailey considered grounds under Sections 5(1), 5(2), and 5(3) regarding distinctive components, average consumer assessment, and proof of use requirements. This is a final decision resolving the opposition proceeding.

MAGNA HOTELS & RESORTS Opposes Trademark Decision O/0314/26

The UK Intellectual Property Office issued decision O/0314/26 on 14 April 2026 regarding the MAGNA HOTELS & RESORTS figurative trademark (Classes 03, 39, 41, 44). Hearing Officer Joanne Roberts considered the opposition under Sections 5(1), 5(2) and 5(3) of the Trade Marks Act, examining issues relating to goods versus retail services classification.

Drummond Leads 45 AGs Demanding PBM Transparency

Oklahoma Attorney General Gentner Drummond led a coalition of 45 attorneys general in sending a letter to the U.S. Department of Labor urging adoption of a new rule requiring pharmacy benefit managers (PBMs) to disclose twice annually how they generate revenue and grant employers the right to audit them. The coalition also requested that the Department clarify the rule does not override existing state PBM transparency laws and commit to coordinating enforcement with state AGs. The letter affects approximately 136 million Americans receiving employer-sponsored health coverage and the three PBMs that control roughly 80% of prescription drug claims nationwide. Oklahoma's own PBM Compliance and Enforcement Unit has already secured a $32 million settlement recovering funds for the state employee health plan.

Notice of Public Meeting of the Alabama Advisory Committee

The U.S. Commission on Civil Rights announces a public meeting of the Alabama Advisory Committee scheduled for Thursday, April 30, 2026, from 2:00 p.m. to 3:00 p.m. Central Time. The meeting is open to the public and appears to be a routine advisory committee convening. No compliance obligations or regulatory changes are being made through this notice.

Alaska Advisory Committee Public Meeting via Zoom - April 29, 2026

The U.S. Commission on Civil Rights has published notice of a public virtual meeting of its Alaska Advisory Committee, scheduled for April 29, 2026, from 11:00 a.m. to 12:30 p.m. Alaska Standard Time via Zoom. The meeting is open to public participation. This is a routine meeting announcement with no regulatory obligations or compliance requirements.

Zhan v. United States Department of State - Voluntary Dismissal

Yue Zhan voluntarily dismissed their civil case against the United States Department of State on April 16, 2026. The case was filed on March 2, 2026 under 'Other Immigration Actions' nature of suit and assigned to Judge Susan van Keulen in the San Jose division. The voluntary dismissal terminates the litigation without a judgment on the merits, and the case summary is not publicly available.

Reclassification of Non-Invasive Bone Growth Stimulators to Class II

FDA issued a final order reclassifying non-invasive bone growth stimulators (a physical medicine device under 21 CFR 890) from Class III to Class II. The reclassification downgrades the regulatory pathway from premarket approval (PMA) to 510(k) premarket notification. The order is effective May 18, 2026.

Medical Devices; Orthopedic Devices; Classification of Manual Surgical Instrument for Patient Selection for Orthopedic Implant

The FDA issued a final rule classifying the manual surgical instrument for appropriate patient selection for orthopedic implant as a Class II medical device under 21 CFR 888, effective April 16, 2026. The classification was applicable as of May 28, 2019. Manufacturers of these orthopedic surgical instruments must comply with Class II device requirements.

FDA Classifies TENS for Congestion Relief as Class II Medical Device

FDA has classified Transcutaneous Electrical Nerve Stimulators (TENS) intended for relief of congestion as Class II medical devices under 21 CFR 874. The classification is effective April 16, 2026, with the classification determination applicable since March 5, 2021. Manufacturers of these devices must comply with applicable Class II requirements.

US v. Cartagena - Partial Vacatur of Excessive Force Convictions

The First Circuit vacated José Cartagena's conviction on one count of deprivation of rights under 18 U.S.C. § 242 because the government introduced a hearsay statement from the victim, Calep Carvajal, who was never available for cross-examination, violating the Sixth Amendment Confrontation Clause. The court affirmed Cartagena's remaining convictions on Counts 1, 2, 6, and 7 — including pistol-whipping and punching Carvajal, falsifying a use-of-force report under § 1519, and lying to a juvenile prosecutor under § 1512(b)(3) — as supported by sufficient evidence. Cartagena was sentenced to 84 months concurrent on each count.

US v. Cartagena - Criminal Appeal Affirmed

The First Circuit Court of Appeals issued an opinion in US v. Cartagena, affirming, reversing, or modifying the judgment from the District Court of Puerto Rico. The appellate court reviewed the district court's decision and issued its ruling on April 15, 2026. This is a federal criminal appeal with binding precedential effect for the First Circuit jurisdiction.

Synthetic CAR-T Cells for Treating IL13Ra2 Positive Human and Canine Tumors

The European Patent Office published patent application EP4021464A1 (A1 kind, April 8, 2026) for synthetic CAR-T cells targeting IL13Ra2 positive tumors in humans and canines. Applicant is The Trustees of The University of Pennsylvania. Inventors include O'ROURKE, Donald M., YIN, Yibo, JOHNSON, Laura, BINDER, Zev, and THOKALA, Radhika. The patent covers compositions and methods for treating IL13Ra2-positive tumors using synthetic chimeric antigen receptor T-cells.

Gene Therapy for Alzheimer's Disease - Brigham and Women's Hospital EP3976637

The European Patent Office published patent application EP3976637A1, filed by The Brigham and Women's Hospital, Inc. and The General Hospital Corporation, covering a gene therapy approach for treating Alzheimer's disease. The invention, developed by inventors Shen Jie and Kelleher III Raymond J., is classified under C12N 15/86 and related protein classification C07K 14/47. The patent is designated across all EU member states including AL, AT, BE, BG, CH, CY, CZ, DE, DK, EE, ES, FI, FR, GB, GR, HR, HU, IE, IS, IT, LI, LT, LU, LV, MC, MK, MT, NL, NO, PL, PT, RO, RS, SE, SI, SK, SM, and TR.

Determining Structured Medical Findings in a Medical Report and Adjusting a Medical Report

The EPO published patent application EP4553842A1 by Koninklijke Philips N.V. titled 'Determining Structured Medical Findings in a Medical Report and Adjusting a Medical Report.' The invention covers methods for extracting structured findings from medical reports and adjusting medical report content. The patent is classified under G16H (Health Informatics) and designates 36 European countries including Germany, France, and the United Kingdom.

Dexcom EP4318489A2 Patent, Continuous Glucose Monitoring App Compatibility Check

The European Patent Office published patent application EP4318489A2 for Dexcom, Inc. covering a system and method for verifying compatibility of continuous glucose monitoring (CGM) applications. The patent application includes claims related to wireless communication protocols (H04W 4/20), healthcare data management systems (G16H 40/40), and software update mechanisms (G06F 8/65) for medical device applications. The patent is designated across 31 EPO member states including Germany, France, Italy, Spain, and the United Kingdom.