2d Circuit Case Commentaries

VICAR Enterprise Motive: “General Purpose” Suffices; Cumulative Brady Impeachment Is Not Material

Date: Feb 5, 2026

VICAR Enterprise Motive: “General Purpose” Suffices; Cumulative Brady Impeachment Is Not Material Introduction United States v. Pippins (2d Cir. Feb. 3, 2026) is a nonprecedential summary order...

Foster Children Have Standing to Challenge Relative-Certification Denials and Assert Their Own Due Process Rights

Date: Feb 3, 2026

Foster Children Have Standing to Challenge Relative-Certification Denials and Assert Their Own Due Process Rights Introduction B. B. v. Hochul (2d Cir. Feb. 2, 2026) arises from New York City’s...

United States v. Huntley — Supervised-Release Conditions Sustained Where the Record Makes Their Rationale Self-Evident and Monitoring Needs Justify Reasonable-Suspicion Searches

Date: Feb 3, 2026

United States v. Huntley — Supervised-Release Conditions Sustained Where the Record Makes Their Rationale Self-Evident and Monitoring Needs Justify Reasonable-Suspicion Searches Introduction In...

Judicial Estoppel Bars Post-Award Challenges to Arbitrator Authority Over a Non-Signatory Who Previously Invoked Arbitration

Date: Feb 1, 2026

Judicial Estoppel Bars Post-Award Challenges to Arbitrator Authority Over a Non-Signatory Who Previously Invoked Arbitration Introduction In MSV Synergy, LLC v. Shapiro (2d Cir. Jan. 30, 2026)...

Rule 46(e) Protects the Government, Not Sureties: Full Bail Forfeiture Affirmed Under the Gambino Factors

Date: Feb 1, 2026

Rule 46(e) Protects the Government, Not Sureties: Full Bail Forfeiture Affirmed Under the Gambino Factors I. Introduction In United States v. Clanton (2d Cir. Jan. 30, 2026) (summary order), the...

Parole “Special Needs” Searches: Credible Firearm Information Justifies a Home Safety Search Without Litigating Tip Provenance Absent Evidence of Police Falsity — United States v. Sims

Date: Feb 1, 2026

Parole “Special Needs” Searches: Credible Firearm Information Justifies a Home Safety Search Without Litigating Tip Provenance Absent Evidence of Police Falsity — United States v. Sims 1....

Post-Order Eligibility Under Pereira/Niz-Chavez Does Not Equitably Toll Time- and Number-Barred Reopening for Non-LPR Cancellation

Date: Jan 31, 2026

Post-Order Eligibility Under Pereira/Niz-Chavez Does Not Equitably Toll Time- and Number-Barred Reopening for Non-LPR Cancellation Case: Zhang v. Bondi, No. 24-2711 (2d Cir. Jan. 29, 2026) (summary...

§ 1406(a) Transfer May Be Denied Where Plaintiffs’ Venue Choices Show Forum Shopping and Lack of Diligence

Date: Jan 31, 2026

§ 1406(a) Transfer May Be Denied Where Plaintiffs’ Venue Choices Show Forum Shopping and Lack of Diligence Introduction In Doe 2 v. Congregation of the Sacred Hearts of Jesus and Mary (2d Cir. Jan....

Qualified Immunity After a Jury Finds Excessive Force: No Clearly Established Bar Where a Resisting Arrestee Is Reasonably (Though Mistakenly) Perceived as a Safety Threat

Date: Jan 31, 2026

Qualified Immunity After a Jury Finds Excessive Force: No Clearly Established Bar Where a Resisting Arrestee Is Reasonably (Though Mistakenly) Perceived as a Safety Threat Case: Matusak v. Daminski...

Prevailing-Party Fees Require Enduring, Judicially Sanctioned Relief—Voluntary Compliance and Intervening Legislation Do Not Suffice

Date: Jan 31, 2026

Prevailing-Party Fees Require Enduring, Judicially Sanctioned Relief—Voluntary Compliance and Intervening Legislation Do Not Suffice Introduction In DRNY v. N.Y. State Dep't of Corr. & Cmty....

Clarifying Receivership Coverage Is Not an Appealable Injunction “Modification” (and Does Not Re-“Appoint” a Receiver) Under 28 U.S.C. § 1292(a)

Date: Jan 31, 2026

Clarifying Receivership Coverage Is Not an Appealable Injunction “Modification” (and Does Not Re-“Appoint” a Receiver) Under 28 U.S.C. § 1292(a) 1. Introduction McNamara v. Fidelis arises from a...

Enduring, Judicially Sanctioned Relief as the Touchstone for § 1988 Fees After Partial Preliminary-Injunction Success

Date: Jan 31, 2026

Enduring, Judicially Sanctioned Relief as the Touchstone for § 1988 Fees After Partial Preliminary-Injunction Success Case: DRNY v. N.Y. State Dep't of Corrs. & Cmty. Supervision (2d Cir. Jan. 29,...

United States v. Hollins — Sentencing Courts Need Not “Back-Credit” Federal Writ Detention Absent Evidentiary Support of Lost State Parole

Date: Jan 31, 2026

United States v. Hollins — Sentencing Courts Need Not “Back-Credit” Federal Writ Detention Absent Evidentiary Support of Lost State Parole 1. Introduction In United States v. Hollins, the Second...

Standing Orders Cannot Mandate “Standard” Supervised-Release Conditions: Individualized Assessment Required for All Discretionary Conditions

Date: Jan 29, 2026

Standing Orders Cannot Mandate “Standard” Supervised-Release Conditions: Individualized Assessment Required for All Discretionary Conditions I. Introduction United States v. McAdam (2d Cir. Jan. 28,...

Non-Precedential Second Circuit Reaffirmation: No Plain-Error Confrontation Clause Violation from Quality-Control Corroboration and Broad Admissibility of Investigative Lay Video Testimony

Date: Jan 29, 2026

Non-Precedential Second Circuit Reaffirmation: No Plain-Error Confrontation Clause Violation from Quality-Control Corroboration and Broad Admissibility of Investigative Lay Video Testimony...

“Accumulate” Under DPA §4512 Has No Temporal Requirement; Prefatory “Prevent Hoarding” Clause Does Not Narrow the Resale-at-Above-Market-Price Prohibition

Date: Jan 29, 2026

“Accumulate” Under DPA §4512 Has No Temporal Requirement; Prefatory “Prevent Hoarding” Clause Does Not Narrow the Resale-at-Above-Market-Price Prohibition 1. Introduction United States v. Bulloch (2d...

Reaffirming Totality-of-the-Circumstances Adverse Credibility Review and Futile-Remand Doctrine in Asylum Cases (Manik v. Bondi)

Date: Jan 29, 2026

Reaffirming Totality-of-the-Circumstances Adverse Credibility Review and Futile-Remand Doctrine in Asylum Cases (Manik v. Bondi) 1. Introduction In Manik v. Bondi (2d Cir. Jan. 27, 2026) (summary...

IDEA Tuition Reimbursement: Late/Changed Placement Notice and Speculative “Capacity to Implement” Challenges Do Not Deny FAPE Absent Significant Impediment

Date: Jan 29, 2026

IDEA Tuition Reimbursement: Late/Changed Placement Notice and Speculative “Capacity to Implement” Challenges Do Not Deny FAPE Absent Significant Impediment Nonprecedential disposition. The Second...

Fraudulent-Inducement Wire/Mail Fraud After Kousisis: No “Benefit-of-the-Bargain” Safe Harbor for Subsidy Fraud

Date: Jan 29, 2026

Fraudulent-Inducement Wire/Mail Fraud After Kousisis: No “Benefit-of-the-Bargain” Safe Harbor for Subsidy Fraud I. Introduction In United States v. Fishbein (2d Cir. Jan. 27, 2026) (summary order),...

Novel Takings-Clause “Pretext” Claims Are Not “Frivolous” for § 1988 Fee-Shifting When Arguably Supported and Seriously Debated

Date: Jan 29, 2026

Novel Takings-Clause “Pretext” Claims Are Not “Frivolous” for § 1988 Fee-Shifting When Arguably Supported and Seriously Debated Case: Brinkmann v. Town of Southold (2d Cir. Jan. 23, 2026) (Summary...