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  • Commentaries
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2d Circuit Case Commentaries

Spring v. Allegany-Limestone: Motivating-Factor Causation and Recognition of Communication Impairments Under Title II ADA and the Rehabilitation Act

Spring v. Allegany-Limestone: Motivating-Factor Causation and Recognition of Communication Impairments Under Title II ADA and the Rehabilitation Act

Date: Apr 11, 2025
Spring v. Allegany-Limestone: Motivating-Factor Causation and Recognition of Communication Impairments Under Title II ADA and the Rehabilitation Act Introduction In Spring v. Allegany-Limestone...
Affirming Probable Cause for Counterfeit‐Bill Arrests: Glover v. Onondaga County Sheriff's Department

Affirming Probable Cause for Counterfeit‐Bill Arrests: Glover v. Onondaga County Sheriff's Department

Date: Apr 11, 2025
Affirming Probable Cause for Counterfeit‐Bill Arrests: Glover v. Onondaga County Sheriff's Department Introduction In Glover v. Onondaga County Sheriff’s Department, 24-630-cv (2d Cir. Apr. 10,...
Consent‐Based Home Entries and Probable Cause in §1983 Arrest Claims – Glover v. Onondaga County Sheriff's Dept.

Consent‐Based Home Entries and Probable Cause in §1983 Arrest Claims – Glover v. Onondaga County Sheriff's Dept.

Date: Apr 11, 2025
Consent‐Based Home Entries and Probable Cause in §1983 Arrest Claims Introduction This commentary examines the Second Circuit’s summary order in Glover v. Onondaga County Sheriff's Dept. (No....
Ripening Non-Final Section 1915 Dismissals into Final Appealable Judgments Under 28 U.S.C. § 1291

Ripening Non-Final Section 1915 Dismissals into Final Appealable Judgments Under 28 U.S.C. § 1291

Date: Apr 11, 2025
Ripening Non-Final Section 1915 Dismissals into Final Appealable Judgments Under 28 U.S.C. § 1291 Introduction Lewis v. R.L. Vallee, Inc. (2d Cir. Apr. 10, 2025) arises from Scott Phillip Lewis’s pro...
Ripening of Dismissals and Heightened Pleading Standards Under ADA, NYCRL §50, and Defamation Law

Ripening of Dismissals and Heightened Pleading Standards Under ADA, NYCRL §50, and Defamation Law

Date: Apr 11, 2025
Ripening of Dismissals and Heightened Pleading Standards Under ADA, NYCRL §50, and Defamation Law Introduction Lewis v. R.L. Vallee, Inc. is a pro se appeal decided by the United States Court of...
Clarifying Probable Cause in Counterfeit Currency Arrests and Prompt Arraignment Requirements

Clarifying Probable Cause in Counterfeit Currency Arrests and Prompt Arraignment Requirements

Date: Apr 11, 2025
Clarifying Probable Cause in Counterfeit Currency Arrests and Prompt Arraignment Requirements Introduction Glover v. Onondaga County Sheriff’s Dept. (2nd Cir. Apr. 10, 2025) is a Second Circuit...
Defining “Disability” and “Motivating Factor” Causation Under Title II of the ADA and Limits on Fee Reductions: Spring v. Allegany-Limestone Central School District

Defining “Disability” and “Motivating Factor” Causation Under Title II of the ADA and Limits on Fee Reductions: Spring v. Allegany-Limestone Central School District

Date: Apr 11, 2025
Defining “Disability” and “Motivating Factor” Causation Under Title II of the ADA and Limits on Fee Reductions: Spring v. Allegany-Limestone Central School District Introduction The Second Circuit’s...
Counterfeit Bill Identification as Probable Cause: Clarifying §1983 False Arrest Standards

Counterfeit Bill Identification as Probable Cause: Clarifying §1983 False Arrest Standards

Date: Apr 11, 2025
Counterfeit Bill Identification as Probable Cause: Clarifying §1983 False Arrest Standards Introduction Glover v. Onondaga County Sheriff's Dept, decided April 10, 2025 by the Second Circuit,...
Clarifying Accrual of Section 1983 Due Process Claims in Land‐Use Disputes

Clarifying Accrual of Section 1983 Due Process Claims in Land‐Use Disputes

Date: Apr 11, 2025
Clarifying Accrual of Section 1983 Due Process Claims in Land-Use Disputes Introduction Potter v. Incorporated Village of Ocean Beach (2d Cir. Apr. 10, 2025) centers on Philip G. Potter’s challenge...
Spring v. Allegany-Limestone: Recognizing Disability-Related Conduct as Protected Under Title II ADA and the Rehabilitation Act

Spring v. Allegany-Limestone: Recognizing Disability-Related Conduct as Protected Under Title II ADA and the Rehabilitation Act

Date: Apr 11, 2025
Spring v. Allegany-Limestone: Recognizing Disability-Related Conduct as Protected Under Title II ADA and the Rehabilitation Act Introduction Spring v. Allegany-Limestone Central School District is a...
Accrual of §1983 Due Process Claims from Revoked Certificates of Occupancy: Discrete Acts and Statute of Limitations Clarified

Accrual of §1983 Due Process Claims from Revoked Certificates of Occupancy: Discrete Acts and Statute of Limitations Clarified

Date: Apr 11, 2025
Accrual of §1983 Due Process Claims from Revoked Certificates of Occupancy: Discrete Acts and Statute of Limitations Clarified Introduction Potter v. Incorporated Village of Ocean Beach (2d Cir. Apr....
Jimenez v. Bondi: Clarifying “Particularly Serious Crime” Determinations and CAT Relief Review in Aggravated Felony Cases

Jimenez v. Bondi: Clarifying “Particularly Serious Crime” Determinations and CAT Relief Review in Aggravated Felony Cases

Date: Apr 11, 2025
Jimenez v. Bondi: Clarifying “Particularly Serious Crime” Determinations and CAT Relief Review in Aggravated Felony Cases Introduction In Jimenez v. Bondi, Nos. 23-6005, 23-6143, 23-6895 & 24-665 (2d...
Jimenez v. Bondi: Clarifying the “Particularly Serious Crime” Standard and CAT Review in Removal Proceedings

Jimenez v. Bondi: Clarifying the “Particularly Serious Crime” Standard and CAT Review in Removal Proceedings

Date: Apr 11, 2025
Jimenez v. Bondi: Clarifying the “Particularly Serious Crime” Standard and CAT Review in Removal Proceedings Introduction Jimenez v. Bondi (2nd Cir. 2025) consolidates four challenges by Dayvid De...
Spring v. Allegany-Limestone: Affirming the Motivating-Factor Test and Constraining ADA Fee Reductions

Spring v. Allegany-Limestone: Affirming the Motivating-Factor Test and Constraining ADA Fee Reductions

Date: Apr 11, 2025
Spring v. Allegany-Limestone Central School District: Affirming the Motivating-Factor Test and Constraining ADA Fee Reductions Introduction Spring v. Allegany-Limestone Central School District is a...
Defining “Particularly Serious Crime” and CAT Standards: Insights from Jimenez v. Bondi

Defining “Particularly Serious Crime” and CAT Standards: Insights from Jimenez v. Bondi

Date: Apr 11, 2025
Defining “Particularly Serious Crime” and CAT Standards: Insights from Jimenez v. Bondi Introduction Jimenez v. Bondi arises from consolidated petitions for review of Board of Immigration Appeals...
Section 1367(a) Common Nucleus Standard Controls Supplemental Jurisdiction Over Intervenor Claims

Section 1367(a) Common Nucleus Standard Controls Supplemental Jurisdiction Over Intervenor Claims

Date: Apr 11, 2025
Section 1367(a) Common Nucleus Standard Controls Supplemental Jurisdiction Over Intervenor Claims Introduction In Hamilton Reserve Bank Ltd. v. Democratic Socialist Republic of Sri Lanka (2d Cir....
Clarifying “By Reason Of” Causation under Title II of the ADA and Proportional Fee Reductions under the ADA and Rehabilitation Act

Clarifying “By Reason Of” Causation under Title II of the ADA and Proportional Fee Reductions under the ADA and Rehabilitation Act

Date: Apr 11, 2025
Clarifying “By Reason Of” Causation under Title II of the ADA and Proportional Fee Reductions under the ADA and Rehabilitation Act Introduction This commentary examines the Second Circuit’s summary...
Accrual of §1983 Land-Use Due Process Claims: Potter v. Incorporated Village of Ocean Beach

Accrual of §1983 Land-Use Due Process Claims: Potter v. Incorporated Village of Ocean Beach

Date: Apr 11, 2025
Accrual of §1983 Land-Use Due Process Claims: Potter v. Incorporated Village of Ocean Beach Introduction Potter v. Incorporated Village of Ocean Beach, decided April 10, 2025 by the Second Circuit,...
Spring v. Allegany-Limestone: Disability-Driven Conduct as ADA-Protected and Limits on Fee Reductions

Spring v. Allegany-Limestone: Disability-Driven Conduct as ADA-Protected and Limits on Fee Reductions

Date: Apr 11, 2025
Spring v. Allegany-Limestone Central School District: Recognizing Disability-Linked Conduct Under Title II of the ADA and Curbing Excessive Fee Awards Introduction In Spring v. Allegany-Limestone...
Establishing the Two-Step “Particularly Serious Crime” Test and CAT Deferral Standards: Jimenez v. Bondi

Establishing the Two-Step “Particularly Serious Crime” Test and CAT Deferral Standards: Jimenez v. Bondi

Date: Apr 11, 2025
Establishing the Two-Step “Particularly Serious Crime” Test and CAT Deferral Standards: Jimenez v. Bondi Introduction The Second Circuit’s summary order in Jimenez v. Bondi (2025) addresses the...
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