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“Drawing the Line Between Fact and Law in Qualified-Immunity Appeals” A Comprehensive Commentary on Horn v. Adger, 24-1034(L) (2d Cir. 2025) 1. Introduction Parties and posture. In Horn v. Adger, two...
Clarifying the Weight of Direct Contradictions: Paguay-Acosta v. Bondi and the Second Circuit’s Refinement of Credibility Analysis in Asylum Proceedings 1. Introduction In Paguay-Acosta v. Bondi, the...
Strict Application of Lozada & the “Reasonable Probability” Prejudice Test in Ineffective-Assistance Motions: Salazar-Asencio v. Bondi Introduction Salazar-Asencio v. Bondi (2d Cir. No. 24-1230, June...
Singh v. Bondi: Re-affirming the “Unable-or-Unwilling” Threshold and Issue-Exhaustion in Asylum & CAT Litigation Introduction Bhupinder Singh, an Indian national and follower of a Sikh splinter...
Ventura-Duarte v. Bondi: Second Circuit Clarifies the “One-Central-Reason” Nexus in Gang-Related Asylum Claims after Matter of L-E-A- 1. Introduction Ventura-Duarte v. Bondi is a 2025 summary order...
Power of Attorney ≠ Article III Standing: The Second Circuit Reinforces the Real-Party-in-Interest Requirement in ERISA Litigation and Opens the Door to Rule 17 Substitution Introduction In Karkare...
“The Underlying-Conduct Rule” – Second Circuit Clarifies Extraditable-Offense Analysis in Lalama Gomez v. United States (2025) I. Introduction In Lalama Gomez v. United States, the U.S. Court of...
Zherka v. Bondi – The Second Circuit Confirms Congress’s Power to Disarm All Felons, Violent or Not, Without Individualized Review 1. Introduction In Zherka v. Bondi, Docket No. 22-1108-cv (decided...
Refining Pro Se Solicitude and Pleading Standards under Section 1983: Craig v. City of New York Introduction The United States Court of Appeals for the Second Circuit’s summary order in Craig v. The...
Second Circuit Upholds the “Reasonable Opportunity to Observe” Mens Rea Standard in 18 U.S.C. § 1591(c) Introduction United States v. Concepcion, decided June 4, 2025 by the Second Circuit, tested...
Reaffirming the Boundaries of Interlocutory Appellate Jurisdiction and Mandamus Relief Under §1291: Ameriway Corp. v. Chen Introduction The Second Circuit’s summary order in Ameriway Corp. v. Chen...
Preservation of Unmodified Contractual Provisions in Copyright Assignments: Catala v. Joombas Co. Ltd. Introduction Catala v. Joombas Co. Ltd. is a summary‐order decision by the United States Court...
Encompassment of Final Judgment by Appeals from Rule 59(e)/60(b) Orders and the Non-Disability Character of Neutral COVID-19 Mandates: Johnson v. Maximus Services LLC Introduction Johnson v. Maximus...
State Protection Nexus in Private-Party Persecution Claims: Singh v. Bondi Introduction Singh v. Bondi (23-6074, 2d Cir. June 3, 2025) involved petitioner Sarbjit Singh’s challenge to the Board of...
Affirmation of Broad Discretion in Imposing Extended Supervised Release Terms upon Revocation under 18 U.S.C. § 3583 Introduction United States v. Patterson is a summary order issued by the United...
Next Friend Standing Under Rule 17(c): Relationship Not Required, Identification Essential Introduction In Doe v. Hochul (2d Cir. 2025), Mary Doe, a social worker proceeding under a pseudonym,...
Hadwan v. US Dep’t of State: APA and Due Process Limits on Passport Revocation Introduction In the Second Circuit’s June 3, 2025 decision in Hadwan v. US Department of State, the court confronted a...
Singh v. Bondi: REAL ID Act’s Totality-of-the-Circumstances Standard in Credibility Determinations Introduction In Singh v. Bondi, 22-6077 (2d Cir. June 3, 2025), the U.S. Court of Appeals for the...
Reaffirmation of Mens Rea Requirements under 18 U.S.C. § 875(c) in True Threat Prosecutions Introduction In United States v. Bedell, No. 24-1783 (2d Cir. June 2, 2025), the Second Circuit addressed...