2d Circuit Case Commentaries

Second Circuit Limits Tender-Offer Damages After Sovereign Expropriation: YPF Bylaws Are Not a Bilateral Shareholder Contract and GEL Art. 28 Bars Third-Party Impeding Actions

Date: Mar 29, 2026

Second Circuit Limits Tender-Offer Damages After Sovereign Expropriation: YPF Bylaws Are Not a Bilateral Shareholder Contract and GEL Art. 28 Bars Third-Party Impeding Actions Case: Petersen Energía;...

Equitable Tolling After a True Change in Law: The BIA Abuses Discretion When It Denies Reopening Based on a Misreading of the Movant’s “Change-in-Law” Theory

Date: Mar 29, 2026

Equitable Tolling After a True Change in Law: The BIA Abuses Discretion When It Denies Reopening Based on a Misreading of the Movant’s “Change-in-Law” Theory 1. Introduction Ramsay v. Bondi (2d Cir....

Article 78 Is an Adequate Post-Deprivation Remedy Even When a DOC Chief of Staff Effects Termination; Union Counsel Are Not § 1983 State Actors in NPA Negotiations

Date: Mar 29, 2026

Article 78 Is an Adeate Post-Deprivation Remedy Even When a DOC Chief of Staff Effects Termination; Union Counsel Are Not § 1983 State Actors in NPA Negotiations Introduction In Nelson v. Thomson (2d...

Settlement Releases Bar § 1983/Wiretap Claims Against County DAs Acting as County Officials; Fabrication Claims Demand Specific Allegations — Ryder v. Czajka (2d Cir. 2026)

Date: Mar 29, 2026

Settlement Releases Bar § 1983/Wiretap Claims Against County DAs Acting as County Officials; Fabrication Claims Demand Specific Allegations Introduction In Ryder v. Czajka (2d Cir. Mar. 27, 2026)...

ERISA Plan-Asset “Look-Through” for RMBS: Regular-Interest Trust Certificates Are Beneficial Interests; Indenture Notes Without Substantial Equity Features Are Not

Date: Mar 28, 2026

ERISA Plan-Asset “Look-Through” for RMBS: Regular-Interest Trust Certificates Are Beneficial Interests; Indenture Notes Without Substantial Equity Features Are Not Case: Powell v. Ocwen Fin. Corp....

FSA Earned-Time Credits Cannot Shorten Supervised Release; § 2241 Becomes Moot After Transfer to Prerelease Custody

Date: Mar 28, 2026

FSA Earned-Time Credits Cannot Shorten Supervised Release; § 2241 Becomes Moot After Transfer to Prerelease Custody I. Introduction In Rivera-Perez v. Stover (2d Cir. Mar. 26, 2026), the Second...

Singh v. Bondi: Internal Relocation Rebuttal Defeats Asylum/Withholding and Forecloses CAT Where Torture Risk Rests on the Same Speculative Nationwide-Tracking Theory

Date: Mar 28, 2026

Singh v. Bondi: Internal Relocation Rebuttal Defeats Asylum/Withholding and Forecloses CAT Where Torture Risk Rests on the Same Speculative Nationwide-Tracking Theory I. Introduction Case: Singh v....

Vacatur Required When Conflicted Defense Counsel Seeks Heightened Courtroom Security Ex Parte and Defendant Is Excluded from Critical Trial-Stage Proceedings

Date: Mar 28, 2026

Vacatur Required When Conflicted Defense Counsel Seeks Heightened Courtroom Security Ex Parte and Defendant Is Excluded from Critical Trial-Stage Proceedings Document status: This decision is a...

Conflict-of-Interest Rule 33 Claims Require a Non-Speculative Forgone Defense Strategy; Post-Offense Gang Evidence Admissible as Direct Proof of Continuing Conspiracies

Date: Mar 27, 2026

Conflict-of-Interest Rule 33 Claims Require a Non-Speculative Forgone Defense Strategy; Post-Offense Gang Evidence Admissible as Direct Proof of Continuing Conspiracies Introduction In United States...

United States v. Fabian — Standard Supervised-Release Conditions Must Be Pronounced or Expressly Incorporated at Sentencing

Date: Mar 27, 2026

Standard Supervised-Release Conditions Must Be Pronounced or Expressly Incorporated at Sentencing (Second Circuit) Case United States v. Fabian, No. 22-1247-cr (2d Cir. Mar. 25, 2026) Court United...

Reverse Splits Are Not “Sales” Under Securities Act §12 Unless They Create a New Investment; Post‑Split §11 Claims Require Tracing to the Registration Statement That Actually Offered the Securities

Date: Mar 26, 2026

Reverse Splits Are Not “Sales” Under Securities Act §12 Unless They Create a New Investment; Post‑Split §11 Claims Require Tracing to the Registration Statement That Actually Offered the Securities...

Non-Actionable Commodity-Cost Disclosures: “If Unable to Recover” Risk Warnings, Contextual Earnings-Call Statements, and Item 303 Materiality in the Face of Public Market Data

Date: Mar 26, 2026

Non-Actionable Commodity-Cost Disclosures: “If Unable to Recover” Risk Warnings, Contextual Earnings-Call Statements, and Item 303 Materiality in the Face of Public Market Data I. Introduction In...

State-Court PURPA Compliance Rulings Collaterally Estop Later Federal Preemption Suits Against Vermont’s Standard Offer Program

Date: Mar 26, 2026

State-Court PURPA Compliance Rulings Collaterally Estop Later Federal Preemption Suits Against Vermont’s Standard Offer Program Introduction In Allco Fin. Ltd. v. Roisman (2d Cir. Mar. 23, 2026)...

Asset-Freezes Against Guarantors Barred Absent a Lien or Equitable Interest: Extending Grupo Mexicano to Unsecured Guarantor Property

Date: Mar 26, 2026

Asset-Freezes Against Guarantors Barred Absent a Lien or Equitable Interest: Extending Grupo Mexicano to Unsecured Guarantor Property 1. Introduction In Leadenhall Capital Partners LLP v. Advantage...

United States v. Bishop — Waiver of § 5G1.3(b) Concurrent-Sentence Claims by Affirmative “No Objection” to the PSR; Dual-Sovereignty Double Jeopardy Rejection; § 3553(a) as an Independent Bar to Compassionate Release

Date: Mar 26, 2026

United States v. Bishop — Waiver of § 5G1.3(b) Concurrent-Sentence Claims by Affirmative “No Objection” to the PSR; Dual-Sovereignty Double Jeopardy Rejection; § 3553(a) as an Independent Bar to...

Parker v. Alexander — Certification of State–City Preemption Question on Claim-Revival Windows (CVA/ASA vs. VGMVPL)

Date: Mar 26, 2026

Certification of Whether New York’s CVA/ASA Preempt New York City’s Later VGMVPL Claim-Revival Window Case: Parker v. Alexander, No. 25-487-cv (2d Cir. Mar. 23, 2026) Court: United States Court of...

Executive Recognition Governs “Foreign State” Status Under the FSIA; TRIA Agency/Instrumentality Status Fixed at the Asset-Blocking Date

Date: Mar 24, 2026

Executive Recognition Governs “Foreign State” Status Under the FSIA; TRIA Agency/Instrumentality Status Fixed at the Asset-Blocking Date Introduction Havlish v. Taliban; Aliganga v. Taliban are...

Invited Error and Unpreserved Challenges Bar Appellate Reversal of FMLA “Motivating-Factor” Instructions and Alleged Verdict Inconsistencies

Date: Mar 24, 2026

Invited Error and Unpreserved Challenges Bar Appellate Reversal of FMLA “Motivating-Factor” Instructions and Alleged Verdict Inconsistencies Introduction Ramadei v. Radiall USA, Inc. (2d Cir. Mar....

Government Knowledge and Continued Payment as “Very Strong Evidence” Against FCA Materiality at Summary Judgment

Date: Mar 24, 2026

Government Knowledge and Continued Payment as “Very Strong Evidence” Against FCA Materiality at Summary Judgment 1. Introduction In United States of America ex rel. Hassan Foreman v. AECOM (2d Cir....

Villa-Loja v. Bondi: Harassment and Non-Deliberate Economic Hardship Do Not Meet the “Persecution” Threshold (and BIA Affirmance Is Read Narrowly to the Ground Actually Adopted)

Date: Mar 24, 2026

Villa-Loja v. Bondi: Harassment and Non-Deliberate Economic Hardship Do Not Meet the “Persecution” Threshold (and BIA Affirmance Is Read Narrowly to the Ground Actually Adopted) 1. Introduction In...