Daily Case Law
Wednesday, September 23, 2026 · 12 decisions worth your morning coffee
Hawaii

Patrickson v. Dow Chemical Co. — Hawaii Supreme Court revived toxic-tort claims and adopted a three-part causation framework

Supreme Court of Hawaii · Vladimir P. Devens; Sabrina S. McKenna; Todd W. Eddins; Lisa M. Ginoza; Taryn R. Tomasa · 2026-09-21personal injury tort

Background: Central and South American banana-plantation workers alleged injuries from exposure to dibromochloropropane, or DBCP, a pesticide manufactured by Dow Chemical Company and used on farms operated by a Del Monte Fresh Produce N.A. subsidiary. Plaintiff Fernando Jimenez Arias worked as a fruit-quality inspector on Bandeco banana farms in Costa Rica from 1971 to 1973. He…

Held: The Hawaii Supreme Court affirmed the ICA and remanded for further proceedings. It adopted the Restatement (Third) of Torts approach for causation in toxic-tort cases, organizing the inquiry as: exposure to the agent, general causation—whether the agent can cause the disease—and specific causation—whether the exposure caused the particular plaintiff’s disease. Plaintiffs must prove but-for causation by a preponderance of the…

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Israel

Ofek–Atarim 10 v. Herzliya Development Company — Supreme Court refused to halt performance of a public-works tender

Supreme Court of Israel · חאלד כבוב (Judicial Selection Committee of Israel, 2022) · 2026-09-22breach of contract

Background: Herzliya Development Company Ltd. issued a January 2026 tender for pipe-jacking and pumping works in the Kiryat Shחקים project, the first in a sequence of tenders supporting a planned residential and commercial development. Ofek–Atarim 10 Ltd. competed against Avrahami Yoav & Sons Ltd. and another bidder. After Avrahami was selected, Ofek sought its disqualification on…

Held: Justice Khaled Kabub denied leave to appeal without requesting responses from the respondents. The Supreme Court emphasized that trial courts have broad discretion over interim relief and that appellate intervention is reserved for exceptional cases. It found the District Court’s detailed decision consistent with that demanding standard and with the public interest.

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Delaware

Wilson v. State — Delaware Supreme Court affirmed denial of postconviction relief

Delaware Supreme Court · Traynor; LeGrow; Griffiths · 2026-09-21constitutionalcriminal

Background: Brian Wilson was convicted of first-degree murder, first-degree conspiracy, and first-degree criminal solicitation for arranging the killing of Allen Cannon after Cannon and his nephew attempted to rob Wilson. The prosecution presented a recorded call involving Wilson, testimony from four jailhouse witnesses who said Wilson admitted hiring the shooter, communications between intermediaries, and other evidence.…

Held: The Delaware Supreme Court affirmed. It held that Wilson had not established an actual conflict of interest because the record did not show that counsel’s prior representation of the State’s proposed witness was substantially related to Wilson’s case or materially limited the defense. The court distinguished Purnell v. State, reasoning that Wilson identified no viable defense strategy foreclosed by divided…

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United Kingdom

Hinton v Stobinski — Director ordered to pay £190,153.99 for breaches involving company funds

High Court (Chancery Division) · Deputy ICC Judge Curl (Lord Chancellor, 2020) · 2026-09-22insolvency

Background: Lloyd Hinton, liquidator of St. Mark Lions Limited, brought proceedings under section 212 of the Insolvency Act 1986 against the company’s sole director and shareholder, Dr Marek Stobinski. The company, which principally provided services for Dr Stobinski’s medical work, entered creditors’ voluntary liquidation in October 2022. Its books and records were largely absent, while an…

Held: Deputy ICC Judge Curl KC held that Dr Stobinski breached his duties in his treatment of the director’s loan account. Once the company was bordering on insolvency, a reasonable director would have stopped further drawings and taken steps to recover the account so that the corporation-tax liability could be addressed. Instead, Dr Stobinski continued to draw on it. The court…

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France

M. [F] [K] — Court rejects challenges to investigative evidence and procedures

Court of Cassation (France) — Criminal Chamber · 2026-09-22criminal

Background: M. [F] [K] was placed under formal investigation on July 22, 2024, for offenses including assassination and criminal conspiracy. He sought annulment of numerous investigative acts and records, challenging matters that included an unsigned record of a telephone conversation, the notice given to the investigating judge when he was placed in police custody, the audiovisual…

Held: The Criminal Chamber dismissed the appeal. It held that the signature formalities governing witness interviews did not apply to the caller’s brief, spontaneous, and imprecise statements. Notice that M. [K] had been placed in custody was sufficient because the investigating judge had already issued a search warrant for him concerning the same conduct and legal classifications, and therefore had personally…

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Ireland

M.R. v Minister for Justice — High Court upholds refusal of Irish naturalisation

High Court (Ireland) · Conleth Bradley (Michael D. Higgins, 2023) · 2026-09-21constitutionalcriminal

Background: M.R., a Pakistani national, entered Ireland in 2014. After marrying a Romanian EU citizen, he obtained an EU-family-member residence card in 2016. In May 2017, however, the Minister revoked that card after finding that documentation submitted to support the EU residence application was false and misleading as to a material fact. M.R. did not challenge…

Held: The High Court refused judicial review. It held that the Minister had lawfully carried out a comprehensive balancing exercise, expressly considering M.R.’s residence, work history, Irish citizen son, absence of criminal convictions, current immigration permission, and submissions explaining the earlier EU-residence issue.

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Singapore

Ser Kang Wei v Salas Porras — High Court refuses to lift worldwide asset freeze or Mauritius enforcement order

Singapore High Court · Tan Siong Thye (Tony Tan Keng Yam, 2014) · 2026-09-22sanctions

Background: Ser Kang Wei and Lucent Trading Ltd sued Carlos Luis Salas Porras, Mark Yong Khong Yoong, and Emily Hwang Mei Chen for alleged misrepresentation, conspiracy, joint tortfeasorship and unjust enrichment arising from cryptocurrency investments. In July 2025, the High Court granted a worldwide Mareva injunction freezing the defendants’ assets up to US$38.6 million and requiring…

Held: The High Court dismissed both applications. It found that the claimants had not breached their duty of full and frank disclosure concerning the purported transfer to Absolute Digital Technology: they were unaware of it when seeking the injunction, and the authenticity of the transfer document was a matter for trial. The alleged discrepancy over whether certain cryptocurrency transfers went to…

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Australia

Roberts v Mawabe Pty Ltd (No 2) — Court refused the proposed amended trust claim but allowed the children to be joined as defendants

Supreme Court of New South Wales · Parker J (David Hurley, 2017) · 2026-09-22civil procedure

Background: The proceedings concern the Waller Family Trust, a discretionary family trust established for Margaret Roberts, Bernard Waller and their five children. Mawabe Pty Ltd was trustee, controlled by Mr Waller. Ms Roberts alleged that trust distributions allocated to her between 2004 and 2015 remained partly unpaid, that she was wrongly excluded from distributions in 2016…

Held: Parker J held that some proposed claims could potentially be viable, but the proposed pleading was not fit to be filed. A claim for acknowledged distributions from 2004 to 2015 was properly characterised as a common-law debt claim, rather than a claim for equitable compensation. Claims concerning alleged exclusion from later distributions could be pursued, if properly pleaded, as claims…

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Ohio

Perrigo Sales Corp. v. Harris — Ohio Supreme Court affirms CAT applies to drugmaker’s actual receipts, not invoice list prices

Supreme Court of Ohio · DeWine, J. · 2026-09-22tax

Background: Perrigo Sales Corporation manufactures generic prescription drugs and sells them through wholesale distributors, which then sell to retailers such as CVS and Walmart. Perrigo invoices distributors at a wholesale acquisition cost, referred to by the court as a list price. Separately, Perrigo contracts with retailers for lower prices. Under the industry-standard chargeback arrangement, distributors pay…

Held: The Supreme Court of Ohio affirmed. Ohio’s CAT applies to “gross receipts,” defined as the total “amount realized” by the taxpayer. Because Perrigo never received the distributors’ invoiced list prices, the amount realized was the lower amount distributors actually paid under Perrigo’s retailer pricing agreements.

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Oklahoma

Pate — Oklahoma Supreme Court accepts resignation pending discipline

Oklahoma Supreme Court · Not specified · 2026-09-21civil procedure

Background: W.E. Pat Pate sought to resign from the Oklahoma Bar Association while disciplinary proceedings were pending. The court denied his initial request in April 2025 because it lacked sufficient specificity about the alleged misconduct. In June 2026, Pate submitted an amended affidavit acknowledging the allegations, waiving the right to contest them, and accepting responsibility.

Held: The Oklahoma Supreme Court granted the Bar Association's application and accepted Pate's amended resignation pending disciplinary proceedings. His relinquishment of the right to practice law became effective on the date he executed the amended affidavit.

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Massachusetts

Commonwealth v. Beechman — Equally divided Appeals Court affirms firearm suppression

Massachusetts Appeals Court · Gabrielle R. Wolohojian D'Angelo (appointment info not available) (concurring); Edward J. Meade (appointment info not available) (dissenting) · 2026-09-21constitutionalcriminalsearch and seizure

Background: Massachusetts prosecutors lost an interlocutory appeal from an order suppressing a loaded firearm after the full Appeals Court divided evenly over whether Boston police lawfully impounded and searched an unregistered vehicle. Because an equally divided appellate court leaves the order under review in place, the Superior Court's suppression order was affirmed. The unusual result matters…

Held: The Appeals Court affirmed by an equally divided court. A concurrence authored by Justice D'Angelo, joined by ten other justices, concluded that the Commonwealth failed to establish either part of the constitutional justification for impoundment: a legitimate, noninvestigative purpose and reasonable necessity under the circumstances. The concurrence reasoned that Beechman had not been arrested and could remain with the SUV…

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Pennsylvania

Commonwealth v. Thomas — CyberTip report hearsay requires new trial on dissemination count

Superior Court of Pennsylvania · Stabile · 2026-09-21constitutionalcriminalevidence

Background: Electronic service providers sent reports to the National Center for Missing and Exploited Children after automated systems flagged files associated with Clinton M. Thomas's accounts as suspected child sexual abuse material. NCMEC forwarded the information to Pennsylvania investigators. Police obtained search warrants, seized Thomas's phones, and recovered images from one device. A Fayette County jury…

Held: In a precedential opinion by Judge Stabile, the Superior Court held that the challenged exhibit was inadmissible hearsay when used to prove the truth of the service providers' assertions. Pennsylvania permits a custodian or other qualified witness to authenticate business records, including some records incorporating information received from another business. But the proponent still must establish circumstances showing that the…

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Full analyses at Case Law Wire. Summaries are AI-generated and are not legal advice.