2d Circuit Case Commentaries

Revenue Rule Does Not Bar Foreign Tax Authority’s Fraud Suit to Recover Refund Payments Where No Tax Was Owed

Date: Sep 2, 2026

Revenue Rule Does Not Bar Foreign Tax Authority’s Fraud Suit to Recover Refund Payments Where No Tax Was Owed 1. Introduction Skatteforvaltningen v. Markowitz (2d Cir. Aug. 31, 2026) is a bellwether...

Second Circuit Adopts “Representative Sample” Pleading for Direct FCA Claims While Reviving Reverse FCA Liability for Concealed Overpayment Retention

Date: Sep 2, 2026

Second Circuit Adopts “Representative Sample” Pleading for Direct FCA Claims While Reviving Reverse FCA Liability for Concealed Overpayment Retention 1. Introduction In United States v. Amerisource...

Lowell v. Lyft, Inc.: ADA Plaintiffs Must Prove Proposed Modifications Will Likely Produce Effective WAV Service; “Facial Reasonableness” Alone Is Not Enough

Date: Aug 29, 2026

Lowell v. Lyft, Inc.: ADA Plaintiffs Must Prove Proposed Modifications Will Likely Produce Effective WAV Service; “Facial Reasonableness” Alone Is Not Enough 1. Introduction In Lowell v. Lyft, Inc....

Waters v. Kory: Second Circuit Defines PREP Act “Causal Relationship” (No Sole-Cause Requirement) and Holds Denials of PREP Act Immunity Immediately Appealable; CUTPA Cannot Recast Medical Malpractice

Date: Aug 28, 2026

Second Circuit Defines PREP Act “Causal Relationship” (No Sole-Cause Requirement) and Holds Denials of PREP Act Immunity Immediately Appealable; CUTPA Cannot Recast Medical Malpractice I....

Upward Variances May Not Punish Non‑Cooperation: The Second Circuit Requires Sindima-Specific Findings and Reassignment When Sentencing References Failure to Help Recover Firearms

Date: Aug 26, 2026

Upward Variances May Not Punish Non‑Cooperation: The Second Circuit Requires Sindima-Specific Findings and Reassignment When Sentencing References Failure to Help Recover Firearms 1. Introduction In...

First Step Act § 404(b) Resentencing Cannot Reduce Statutory Mandatory-Minimum Supervised Release Using Nonretroactive § 401 Changes or Related Guidelines (Post-Concepcion)

Date: Aug 26, 2026

First Step Act § 404(b) Resentencing Cannot Reduce Statutory Mandatory-Minimum Supervised Release Using Nonretroactive § 401 Changes or Related Guidelines (Post-Concepcion) Introduction United States...

FVRA Incumbent-First-Assistant Rule and Anti-Circumvention Bar on “Total Delegation” of a Vacant U.S. Attorney’s Powers

Date: Aug 26, 2026

FVRA Incumbent-First-Assistant Rule and Anti-Circumvention Bar on “Total Delegation” of a Vacant U.S. Attorney’s Powers 1. Introduction Case: In re Grand Jury Subpoenas to the Office of the New York...

Section 1958 “Consideration” Means Reciprocal Inducement (Not Employment): The Second Circuit’s Rule for Murder-for-Hire

Date: Aug 26, 2026

Section 1958 “Consideration” Means Reciprocal Inducement (Not Employment): The Second Circuit’s Rule for Murder-for-Hire I. Introduction In United States v. Martin (2d Cir. Aug. 21, 2026), the Second...

IDEA “Stay-Put” Relief Is Unavailable for Past, Completed School Years Absent a Showing of Current Jeopardy (and Post-Relief Claims Are Moot)

Date: Aug 26, 2026

IDEA “Stay-Put” Relief Is Unavailable for Past, Completed School Years Absent a Showing of Current Jeopardy (and Post-Relief Claims Are Moot) 1. Introduction Juca v. Banks (2d Cir. Aug. 20, 2026)...

FIRREA Succession Clause Does Not Transfer Investors’ Rule 10b-5 Purchase-and-Sale Claims to the FDIC; No FIRREA Exhaustion for Third-Party Securities Claims

Date: Aug 21, 2026

FIRREA Succession Clause Does Not Transfer Investors’ Rule 10b-5 Purchase-and-Sale Claims to the FDIC; No FIRREA Exhaustion for Third-Party Securities Claims Introduction Sjunde AP-Fonden v. FDIC (2d...

Residual-Exception Admission of Unsworn Recantation Letters to Defeat Grand-Jury Probable Cause at Summary Judgment

Date: Aug 21, 2026

Residual-Exception Admission of Unsworn Recantation Letters to Defeat Grand-Jury Probable Cause at Summary Judgment I. Introduction Batista-Reyes v. Paul (2d Cir. Aug. 17, 2026) arises from a 1993...

Post–Loper Bright “Best Reading” Rule: INA “Conviction” Requires (1) Foundational Criminal-Procedure Protections and (2) Criminal Sentencing

Date: Aug 21, 2026

Post–Loper Bright “Best Reading” Rule: INA “Conviction” Requires (1) Foundational Criminal-Procedure Protections and (2) Criminal Sentencing I. Introduction Wong v. Blanche (2d Cir. Aug. 19, 2026)...

Second Circuit: Church Autonomy Bars Defamation Claims Inextricably Intertwined with Clergy Selection, Discipline, and Internal Governance—even After Social-Media Dissemination

Date: Aug 21, 2026

Second Circuit: Church Autonomy Bars Defamation Claims Inextricably Intertwined with Clergy Selection, Discipline, and Internal Governance—even After Social-Media Dissemination 1. Introduction Belya...

Section 3559(e)(1) “Minor Victim” Clause Is Circumstance-Specific; State Predicate May Categorically Match Any Listed Federal Sex Offense

Date: Aug 21, 2026

Section 3559(e)(1) “Minor Victim” Clause Is Circumstance-Specific; State Predicate May Categorically Match Any Listed Federal Sex Offense 1. Introduction United States v. Valder (2d Cir. Aug. 18,...

Second Circuit Recognizes a First Amendment Right to Record Publicly Visible Police-Station Exteriors from a Public Sidewalk (Subject to Qualified Immunity for Pre-Decision Conduct)

Date: Aug 21, 2026

Second Circuit Recognizes a First Amendment Right to Record Publicly Visible Police-Station Exteriors from a Public Sidewalk (Subject to Qualified Immunity for Pre-Decision Conduct) 1. Introduction...

Coram Nobis Harmless-Error Review: Kotteakos Governs (and Petitioner Bears the Burden)

Date: Aug 21, 2026

Coram Nobis Harmless-Error Review: Kotteakos Governs (and Petitioner Bears the Burden) Case: Stinn v. United States of America, No. 25-293 (2d Cir. Aug. 17, 2026) Court: United States Court of...

Defective Trustee Substitution Goes to Capacity—Not Article III Standing—and May Be Cured by Waiver/Ratification

Date: Aug 14, 2026

Defective Trustee Substitution Goes to Capacity—Not Article III Standing—and May Be Cured by Waiver/Ratification 1. Introduction In UMB Bank, N.A. v. Bristol-Myers Squibb Company (2d Cir. Aug. 13,...

United States v. Matos: “Miscarriage of Justice” Limits on Appeal Waivers After Hunter; Incorporation-by-Reference Pronouncement of Supervised-Release Conditions

Date: Aug 14, 2026

United States v. Matos: The Second Circuit Adopts Hunter’s “Miscarriage of Justice” Exception to Appeal Waivers—But Holds Routine Guidelines Disputes Still Waived; Standing-Order Incorporation...

Ex Parte Buccal-Swab DNA Warrants: No Pre-Issuance Hearing Required, and Probable Cause Need Not Identify a Viable Comparison Sample

Date: Aug 14, 2026

Ex Parte Buccal-Swab DNA Warrants: No Pre-Issuance Hearing Required, and Probable Cause Need Not Identify a Viable Comparison Sample 1. Introduction United States v. Leeper (2d Cir. Aug. 13, 2026)...

Second Circuit: Compelled Disclosure of Third-Party Customer Data Is Outside Zauderer and Invalid Absent a Reasonable Central Hudson Fit

Date: Aug 7, 2026

Second Circuit: Compelled Disclosure of Third-Party Customer Data Is Outside Zauderer and Invalid Absent a Reasonable Central Hudson Fit 1. Introduction In DoorDash, Inc. v. City of New York (2d Cir....