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Geographic-Filtering Mechanism on Website That Enabled Local Sales in New Hampshire Constituted “Purposeful Availment” for Personal Jurisdiction Purposes, Holds First Circuit

In Stokinger v. Armslist, LLC, No. 24-1697 (1st Cir. Feb. 5, 2026), the First Circuit holds that an online marketplace for firearms based in Pennsylvania engaged in “purposeful availment” of New Hampshire because it had a geographic-filtering mechanism on its website that would-be purchasers could use to search for firearms offered for sale where “they…

Third Circuit Joins Split Over Whether Successful Habeas Corpus Litigants Are Entitled to Fees and Costs Under the Equal Access to Justice Act

In Michelin v. Warden Moshannon Valley Corr. Cntr., No. 24-2990 (3d Cir. Feb. 2, 2026), the Third Circuit becomes the fourth U.S. Court of Appeals to hold that the Equal Access to Justice Act fee-shifting provision applies to successful litigants in habeas cases (while two other circuits hold that it does not). The issue is…

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