2d Circuit Case Commentaries

Russell v. Scott: Objective-Reasonableness Rule for Pretrial Detainee Sexual-Abuse Claims Under the Fourteenth Amendment

Date: Mar 24, 2026

Russell v. Scott: Objective-Reasonableness Rule for Pretrial Detainee Sexual-Abuse Claims Under the Fourteenth Amendment 1. Introduction In Russell v. Scott (2d Cir. Mar. 19, 2026),...

Notice-Based Waiver of Evidentiary Objections and Authentication of Foreclosure Damages Records Through Annexed Documents

Date: Mar 20, 2026

Notice-Based Waiver of Evidentiary Objections and Authentication of Foreclosure Damages Records Through Annexed Documents Introduction In CIT Bank N.A. v. Schiffman, No. 23-487-cv (2d Cir. Mar. 18,...

King v. Davis: Video-Controlled Excessive-Force Summary Judgment and Reviving NY Negligence Claims Amid Unsettled “Negligent Assault” Doctrine

Date: Mar 20, 2026

King v. Davis: Video-Controlled Excessive-Force Summary Judgment and Reviving NY Negligence Claims Amid Unsettled “Negligent Assault” Doctrine 1. Introduction In King v. Davis (2d Cir. Mar. 18, 2026)...

Mandatory State-Court Release Orders + DOCCS Housing Duties Can Create a Fourteenth Amendment Liberty Interest Against Prolonged Custody

Date: Mar 20, 2026

Mandatory State-Court Release Orders + DOCCS Housing Duties Can Create a Fourteenth Amendment Liberty Interest Against Prolonged Custody Note: This decision was issued as a Second Circuit Summary...

Past Persecution as the Gateway to Presumed Future Fear, and the “Unable-or-Unwilling” Threshold for Private-Actor Harm (Second Circuit Summary Order)

Date: Mar 20, 2026

Past Persecution as the Gateway to Presumed Future Fear, and the “Unable-or-Unwilling” Threshold for Private-Actor Harm (Second Circuit Summary Order) Case: Lucero-Lucero v. Bondi, No. 23-8092 (2d...

Adverse Credibility Sustained by Material Inconsistencies, Missing Corroboration, and Unexhausted Excuses; “Pattern or Practice” Requires Systemic Persecution Beyond Discrimination

Date: Mar 20, 2026

Adverse Credibility Sustained by Material Inconsistencies, Missing Corroboration, and Unexhausted Excuses; “Pattern or Practice” Requires Systemic Persecution Beyond Discrimination Note on...

Patel v. Bondi: DHS Rebuttal of the Past-Persecution Presumption Through Safe and Reasonable Internal Relocation, and Appellate Abandonment of Unbriefed Issues

Date: Mar 20, 2026

Patel v. Bondi: DHS Rebuttal of the Past-Persecution Presumption Through Safe and Reasonable Internal Relocation, and Appellate Abandonment of Unbriefed Issues Court: U.S. Court of Appeals for the...

Stidhum v. 161-10 Hillside Auto Ave, LLC — Discrimination Claims Fail Without Evidence of Disparate Treatment; Pre-Suit Loss of Records Defeats Spoliation Relief

Date: Mar 20, 2026

Stidhum v. 161-10 Hillside Auto Ave, LLC — Discrimination Claims Fail Without Evidence of Disparate Treatment; Pre-Suit Loss of Records Defeats Spoliation Relief Note on status: The Second Circuit...

Circumstantial Proof of “Pecuniary Value” and Mandatory Life Sentencing Under 18 U.S.C. § 1958(a) in Murder-for-Hire Prosecutions

Date: Mar 20, 2026

Circumstantial Proof of “Pecuniary Value” and Mandatory Life Sentencing Under 18 U.S.C. § 1958(a) in Murder-for-Hire Prosecutions Note on disposition: This decision is a Second Circuit summary order...

Context-and-Record May Satisfy 18 U.S.C. § 3553(c)(2) for Upward Variances Without “Magic Words” (Second Circuit)

Date: Mar 20, 2026

Context-and-Record May Satisfy 18 U.S.C. § 3553(c)(2) for Upward Variances Without “Magic Words” Case: United States v. Marganda, No. 25-959-cr (2d Cir. Mar. 18, 2026) (summary order) Court: United...

United States v. Caesar: Specific, Area-Linked Facts Required to Establish Fourth Amendment “Standing” and to Obtain a Suppression Hearing

Date: Mar 19, 2026

United States v. Caesar: Specific, Area-Linked Facts Required to Establish Fourth Amendment “Standing” and to Obtain a Suppression Hearing Court: U.S. Court of Appeals for the Second Circuit Date:...

Deliberate Indifference Requires Both Subjective Awareness and Practical Ability to Mitigate Risk—And May Be Proven Circumstantially Despite an Inmate’s Symptom Denials (Suarez v. Sullivan)

Date: Mar 19, 2026

Deliberate Indifference Requires Both Subjective Awareness and Practical Ability to Mitigate Risk—And May Be Proven Circumstantially Despite an Inmate’s Symptom Denials Case: Suarez v. Sullivan, No....

Short-Term Disability Approval Does Not Establish Long-Term Disability; Claimant Must Prove Total Disability Throughout the Elimination Period with Evidence of Functional Limitation

Date: Mar 19, 2026

Short-Term Disability Approval Does Not Establish Long-Term Disability; Claimant Must Prove Total Disability Throughout the Elimination Period with Evidence of Functional Limitation Introduction In...

Sexual-Assault Allegations Are Not “Near-Dispositive” for Pseudonymity: Individualized Harm and Litigation Prejudice Control the Sealed Plaintiff Balancing

Date: Mar 19, 2026

Sexual-Assault Allegations Are Not “Near-Dispositive” for Pseudonymity: Individualized Harm and Litigation Prejudice Control the Sealed Plaintiff Balancing Introduction In Doe v. Combs, et al. (2d...

Pleading Specificity for Title VII Religious Objections to Testing and Limits on Disparate-Treatment Comparators

Date: Mar 19, 2026

Pleading Specificity for Title VII Religious Objections to Testing and Limits on Disparate-Treatment Comparators Introduction In Jackson v. Amazon.com, Inc., the United States Court of Appeals for...

Contempt Requires a Violated Court Order; Sua Sponte Rule 11 Sanctions After the Safe Harbor Require Specific Findings of Subjective Bad Faith

Date: Mar 19, 2026

Contempt Requires a Violated Court Order; Sua Sponte Rule 11 Sanctions After the Safe Harbor Require Specific Findings of Subjective Bad Faith Case: Sheehan v. Starbucks Corp. (No. 25-189) Court:...

Dickerson v. BPP PCV Owners LLC — Private Landlord’s Call to Police Does Not Create § 1983 State Action; FHA/ADA Claims Require Plausible Discriminatory Animus and Retaliatory Nexus

Date: Mar 19, 2026

Private Landlord’s Call to Police Does Not Create § 1983 State Action; FHA/ADA Claims Require Plausible Discriminatory Animus and Retaliatory Nexus 1. Introduction In Dickerson v. BPP PCV Owners LLC...

Ioio v. City of New York: Premature Appeals May Ripen After Final Judgment, but Undesignated Orders Remain Unreviewable; No Private OSHA Claims and COVID Vaccine Mandates Survive Rational-Basis Review

Date: Mar 18, 2026

Ioio v. City of New York: Premature Appeals May Ripen After Final Judgment, but Undesignated Orders Remain Unreviewable; No Private OSHA Claims and COVID Vaccine Mandates Survive Rational-Basis...

Medicaid Waiver Payroll Intermediaries Are Not “Employers” Under the FLSA/CMWA Absent Hiring, Supervision, or Pay-Setting Control

Date: Mar 15, 2026

Medicaid Waiver Payroll Intermediaries Are Not “Employers” Under the FLSA/CMWA Absent Hiring, Supervision, or Pay-Setting Control I. Introduction Kolonziaa v. Allied Cmty. Res., Inc. is a Second...

Rule 32.1 Revocation Hearings: Courts Must Make Explicit “Good Cause” Findings Before Admitting Hearsay and Must Narrowly Tailor Computer/Internet Monitoring Conditions

Date: Mar 14, 2026

Rule 32.1 Revocation Hearings: Courts Must Make Explicit “Good Cause” Findings Before Admitting Hearsay and Must Narrowly Tailor Computer/Internet Monitoring Conditions Case: United States v. Davis...