2d Circuit Case Commentaries

United States v. Mighty: Reinforcing District Court Discretion Under § 3553(a) in Compassionate Release Motions

Date: Dec 3, 2025

United States v. Mighty: Reinforcing District Court Discretion Under § 3553(a) in Compassionate Release Motions Court: United States Court of Appeals for the Second Circuit Case: United States v....

When “Notwithstanding” Controls: Shapiro v. U.S. Social Security Administration and the Priority of Social Security Act § 1306(c) over FOIA’s Fee‑Preclusion Rule

Date: Dec 1, 2025

When “Notwithstanding” Controls: Shapiro v. U.S. Social Security Administration and the Priority of Social Security Act § 1306(c) over FOIA’s Fee‑Preclusion Rule I. Introduction In Shapiro v. U.S....

Buller v. Commissioner: The § 6213(a) Deficiency Petition Deadline as a Nonjurisdictional, Equitably Tollable Rule

Date: Dec 1, 2025

Buller v. Commissioner: The § 6213(a) Deficiency Petition Deadline as a Nonjurisdictional, Equitably Tollable Rule I. Introduction In Buller v. Commissioner, No. 24-1557 (2d Cir. Nov. 26, 2025) (as...

Mootness of Interlocutory Appeals After Bankruptcy Stay Relief: Commentary on In re 155 Chambersfood, Inc.

Date: Dec 1, 2025

Mootness of Interlocutory Appeals After Bankruptcy Stay Relief: Commentary on In re 155 Chambersfood, Inc. (2d Cir. Nov. 26, 2025) I. Introduction This commentary analyzes the Second Circuit’s...

Thieriot v. Laggner: Application of New York’s Brettler Rule on Anti‑Assignment Clauses, “Consummation” of Share Sales, and Joinder of Contracting Parties

Date: Dec 1, 2025

Thieriot v. Laggner: Application of New York’s Brettler Rule on Anti‑Assignment Clauses, “Consummation” of Share Sales, and Joinder of Contracting Parties I. Introduction In Thieriot v. Laggner, No....

Erde v. Carranza: Strict Enforcement of IDEA Issue Exhaustion and Limits on “Opening the Door” in FAPE Transportation Disputes

Date: Dec 1, 2025

Erde v. Carranza: Strict Enforcement of IDEA Issue Exhaustion and Limits on “Opening the Door” in FAPE Transportation Disputes I. Introduction Erde v. Carranza, No. 25-54-cv (2d Cir. Nov. 26, 2025)...

Second Circuit Clarifies FMLA Discouragement, Notice, and Retaliation Standards in Haran v. Orange Business Services, Inc.

Date: Nov 30, 2025

Second Circuit Clarifies FMLA Discouragement, Notice, and Retaliation Standards in Haran v. Orange Business Services, Inc. I. Introduction The United States Court of Appeals for the Second Circuit’s...

Nunez v. Commissioner: Substantial Evidence and RFC Findings on Mental Health–Related Attendance and Time Off Task

Date: Nov 29, 2025

Nunez v. Commissioner of Social Security: Substantial Evidence and Residual Functional Capacity for Attendance and Time Off Task in Mental Health Disability Claims I. Introduction In Nunez v....

Recasting FRSA Whistleblower Law: Contributing‑Factor Causation and Retaliatory Hostile Work Environment After Ziparo v. CSX Transportation

Date: Nov 29, 2025

Recasting FRSA Whistleblower Law: Contributing‑Factor Causation and Retaliatory Hostile Work Environment After Ziparo v. CSX Transportation I. Introduction In Ziparo v. CSX Transportation, Inc., No....

Government Acquiescence to Prison Gang Torture Under CAT: Commentary on B.G.S. v. Bondi (2d Cir. 2025)

Date: Nov 29, 2025

Government Acquiescence to Prison Gang Torture Under CAT: Commentary on B.G.S. v. Bondi (2d Cir. 2025) I. Introduction The Second Circuit’s decision in B.G.S. v. Bondi, No. 23‑6862 (2d Cir. Nov. 24,...

Reaffirming Implied and Voluntary Consent to Home Searches: Commentary on United States v. Brooks (2d Cir. 2025)

Date: Nov 29, 2025

Reaffirming Implied and Voluntary Consent to Warrantless Home Searches: Commentary on United States v. Brooks (2d Cir. 2025) I. Introduction The Second Circuit’s summary order in United States v....

No Need to Reach Both Equitable Tolling Prongs When One Fails: Mandate Rule Clarified in Jane Doe v. United States (2d Cir. 2025)

Date: Nov 28, 2025

No Need to Reach Both Equitable Tolling Prongs When One Fails: Mandate Rule Clarified in Jane Doe v. United States (2d Cir. 2025) I. Introduction This commentary examines the Second Circuit’s summary...

Discretionary De Novo Resentencing After Partial § 2255 Vacatur: Commentary on United States v. Abu Mezer

Date: Nov 28, 2025

Discretionary De Novo Resentencing After Partial § 2255 Vacatur: Commentary on United States v. Abu Mezer I. Introduction The Second Circuit’s summary order in United States v. Abu Mezer, No. 23‑6099...

Colorable Claims, Issue Exhaustion, and CAT Review in Immigration Appeals: Commentary on Hasan v. Bondi (2d Cir. 2025)

Date: Nov 28, 2025

Colorable Claims, Issue Exhaustion, and CAT Review in Immigration Appeals: Commentary on Hasan v. Bondi (2d Cir. 2025) I. Introduction This commentary analyzes the Second Circuit’s summary order in...

Harmless Error, Expert Evidence, and Local Rule Enforcement in Civil Rights Trials: Commentary on Paul v. City of New York (2d Cir. 2025)

Date: Nov 28, 2025

Harmless Error, Expert Evidence, and Local Rule Enforcement in Civil Rights Trials: Commentary on Paul v. City of New York (2d Cir. 2025) I. Introduction This commentary examines the Second Circuit’s...

Abusive Employer Lawsuits as Attempted Forced Labor and Permissive Forum Clauses in Physician Immigration Contracts: Commentary on Hemant Patel M.D., P.C. v. Bandikatla (2d Cir. 2025)

Date: Nov 28, 2025

Abusive Employer Lawsuits as Attempted Forced Labor and Permissive Forum Clauses in Physician Immigration Contracts Comprehensive Commentary on Hemant Patel M.D., P.C. v. Bandikatla, 24-988(L),...

Plausibility Pleading and Post‑Conviction Rule 41(g) Motions: Commentary on United States v. Reddick (2d Cir. 2025)

Date: Nov 28, 2025

Plausibility Pleading and Post‑Conviction Rule 41(g) Motions: Commentary on United States v. Reddick (2d Cir. 2025) I. Introduction This commentary analyzes the Second Circuit’s summary order in...

Reaffirming the Narrow Grounds for Vacating Arbitration Awards under the FAA: Commentary on Loans on Fine Art LLC v. Peck

Date: Nov 28, 2025

Reaffirming the Narrow Grounds for Vacating Arbitration Awards under the FAA: Commentary on Loans on Fine Art LLC v. Ian S. Peck I. Introduction This Second Circuit summary order in Loans on Fine Art...

Probable Cause, Personal Involvement, and Amendment Limits in § 1983 Litigation: Commentary on Islam v. Tirelli

Date: Nov 28, 2025

Probable Cause, Personal Involvement, and Amendment Limits in § 1983 Litigation: Commentary on Islam v. Tirelli I. Introduction This commentary examines the Second Circuit’s summary order in Islam v....

Younger Abstention and Adequate State Review of Constitutional and Preemption Challenges to NYC’s Source-of-Income Law: Commentary on 216 East 29th Street Trust v. City of New York

Date: Nov 28, 2025

Younger Abstention and State-Court Review as Adequate Forums for Constitutional and Preemption Challenges to NYC’s Source-of-Income Law Commentary on 216 East 29th Street Trust v. City of New York,...