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  • Commentaries
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2d Circuit Case Commentaries

United States v. Helbrans: Void Child Marriage No Defense under the IPKCA and Illicit Sexual‐Conduct Statutes

United States v. Helbrans: Void Child Marriage No Defense under the IPKCA and Illicit Sexual‐Conduct Statutes

Date: Apr 9, 2025
United States v. Helbrans: Void Child Marriage No Defense under the IPKCA and Illicit Sexual-Conduct Statutes 1. Introduction In United States v. Helbrans, 22-1680 (2d Cir. Apr. 8, 2025), the U.S....
Void Foreign Minor Marriages Do Not Bar Federal Illicit Sexual Conduct and Kidnapping Charges Under 18 U.S.C. § 2423 and the IPKCA

Void Foreign Minor Marriages Do Not Bar Federal Illicit Sexual Conduct and Kidnapping Charges Under 18 U.S.C. § 2423 and the IPKCA

Date: Apr 9, 2025
Void Foreign Minor Marriages Do Not Bar Federal Illicit Sexual Conduct and Kidnapping Charges Under 18 U.S.C. § 2423 and the IPKCA Introduction United States v. Helbrans (2d Cir. Apr. 8, 2025) arises...
Medical Judgment and Eighth Amendment: Discretion in Diagnostic Imaging Established in Wright v. Martin

Medical Judgment and Eighth Amendment: Discretion in Diagnostic Imaging Established in Wright v. Martin

Date: Apr 9, 2025
Medical Judgment and Eighth Amendment: Discretion in Diagnostic Imaging Established in Wright v. Martin Introduction Wright v. Martin (2nd Cir. April 8, 2025) involves a former Connecticut inmate,...
United States v. Love: Requirement for Individualized Findings in Imposing Internet-Use and Employment-Notification Conditions on Supervised Release

United States v. Love: Requirement for Individualized Findings in Imposing Internet-Use and Employment-Notification Conditions on Supervised Release

Date: Apr 9, 2025
United States v. Love: Requirement for Individualized Findings in Imposing Internet-Use and Employment-Notification Conditions on Supervised Release Introduction United States v. Love is a summary...
Khazin v. City of New York: Reaffirming the Awareness Requirement and But-For Causation Standard in Title VII Retaliation Claims

Khazin v. City of New York: Reaffirming the Awareness Requirement and But-For Causation Standard in Title VII Retaliation Claims

Date: Apr 9, 2025
Khazin v. City of New York: Reaffirming the Awareness Requirement and But-For Causation Standard in Title VII Retaliation Claims Introduction Khazin v. City of New York, decided by the United States...
Defining “Marital Status” under the NYCHRL: General Condition vs. Specific Spousal Relationship

Defining “Marital Status” under the NYCHRL: General Condition vs. Specific Spousal Relationship

Date: Apr 9, 2025
Defining “Marital Status” under the NYCHRL: General Condition vs. Specific Spousal Relationship Introduction The Second Circuit’s decision in Hunter v. Debmar-Mercury LLC addresses a pivotal question...
Medical Judgment Exemption under the Eighth Amendment: Denial of MRI Not Deliberate Indifference

Medical Judgment Exemption under the Eighth Amendment: Denial of MRI Not Deliberate Indifference

Date: Apr 9, 2025
Medical Judgment Exemption under the Eighth Amendment: Denial of MRI Not Deliberate Indifference Introduction The case of Wright v. Martin, decided by the United States Court of Appeals for the...
Deliberate Indifference and Medical Judgment: Diagnostic Imaging under the Eighth Amendment in Wright v. Martin

Deliberate Indifference and Medical Judgment: Diagnostic Imaging under the Eighth Amendment in Wright v. Martin

Date: Apr 9, 2025
Deliberate Indifference and Medical Judgment: Diagnostic Imaging under the Eighth Amendment in Wright v. Martin Introduction Wright v. Martin is a 2025 decision of the United States Court of Appeals...
New Standards for Internet-Access and Employment-Notification Conditions in Supervised Release (United States v. Love)

New Standards for Internet-Access and Employment-Notification Conditions in Supervised Release (United States v. Love)

Date: Apr 9, 2025
New Standards for Internet-Access and Employment-Notification Conditions in Supervised Release Introduction United States v. Love, 24-1706-cr (2d Cir. Apr. 8, 2025) arose on appeal from a conviction...
Void Foreign Minor Marriages Cannot Defeat Federal Child-Kidnapping and Sex-Trafficking Statutes

Void Foreign Minor Marriages Cannot Defeat Federal Child-Kidnapping and Sex-Trafficking Statutes

Date: Apr 9, 2025
Void Foreign Minor Marriages Cannot Defeat Federal Child-Kidnapping and Sex-Trafficking Statutes Introduction This commentary examines the Second Circuit’s summary order in United States v. Helbrans,...
Permissible Disclosure of Presentence Reports and Medical Records to Treatment Providers under Supervised Release: United States v. Harris

Permissible Disclosure of Presentence Reports and Medical Records to Treatment Providers under Supervised Release: United States v. Harris

Date: Apr 9, 2025
Permissible Disclosure of Presentence Reports and Medical Records to Treatment Providers under Supervised Release: United States v. Harris 1. Introduction United States v. Harris, 24-1099-cr (2d Cir....
Particularized Justification for Internet-Device and Employer-Notification Conditions in Supervised Release: United States v. Love

Particularized Justification for Internet-Device and Employer-Notification Conditions in Supervised Release: United States v. Love

Date: Apr 9, 2025
Particularized Justification for Internet-Device and Employer-Notification Conditions in Supervised Release: United States v. Love Introduction United States v. Love (2d Cir. Apr. 8, 2025) arises...
Affirmation of IPKCA Liability and Non-Recognition of Void Foreign Child Marriage: United States v. Helbrans

Affirmation of IPKCA Liability and Non-Recognition of Void Foreign Child Marriage: United States v. Helbrans

Date: Apr 9, 2025
Affirmation of IPKCA Liability and Non-Recognition of Void Foreign Child Marriage: United States v. Helbrans Introduction The Second Circuit’s summary order in United States v. Helbrans...
Limits of Delegation in Supervised Release: Probation Officer Disclosure of Presentence and Treatment Records

Limits of Delegation in Supervised Release: Probation Officer Disclosure of Presentence and Treatment Records

Date: Apr 9, 2025
Limits of Delegation in Supervised Release: Probation Officer Disclosure of Presentence and Treatment Records 1. Introduction United States v. Harris, 24-1099-cr (2d Cir. Apr. 8, 2025), arises from...
Self-Evident Rationale for PSR and Medical Record Disclosure to Treatment Providers in Supervised Release

Self-Evident Rationale for PSR and Medical Record Disclosure to Treatment Providers in Supervised Release

Date: Apr 9, 2025
Self-Evident Rationale for PSR and Medical Record Disclosure to Treatment Providers in Supervised Release Introduction United States v. Harris is a summary order issued on April 8, 2025 by the United...
Particularized Justification Required for Special Supervised Release Conditions in Child Pornography Cases

Particularized Justification Required for Special Supervised Release Conditions in Child Pornography Cases

Date: Apr 9, 2025
Particularized Justification Required for Special Supervised Release Conditions in Child Pornography Cases Introduction United States v. Love is a Second Circuit summary order issued on April 8,...
Clarifying Employer Awareness and But-For Causation in Title VII Retaliation Claims

Clarifying Employer Awareness and But-For Causation in Title VII Retaliation Claims

Date: Apr 9, 2025
Clarifying Employer Awareness and But-For Causation in Title VII Retaliation Claims Introduction This commentary examines the Second Circuit’s summary order in Khazin v. City of New York (2d Cir....
Reaffirmation of Venue and Due Diligence Standards for Newly Discovered Evidence in Criminal Appeals

Reaffirmation of Venue and Due Diligence Standards for Newly Discovered Evidence in Criminal Appeals

Date: Apr 9, 2025
Reaffirmation of Venue and Due Diligence Standards for Newly Discovered Evidence in Criminal Appeals Introduction United States v. Kaufman is an appeal decided by the United States Court of Appeals...
MRI Denial Not Deliberate Indifference: Clarifying Eighth Amendment Medical Judgment in Prisons

MRI Denial Not Deliberate Indifference: Clarifying Eighth Amendment Medical Judgment in Prisons

Date: Apr 9, 2025
MRI Denial Not Deliberate Indifference: Clarifying Eighth Amendment Medical Judgment in Prisons Introduction Wright v. Martin is a summary order issued by the United States Court of Appeals for the...
Reaffirmation of Strict Due Diligence Requirement for Newly Discovered Evidence under Federal Rule of Criminal Procedure 33

Reaffirmation of Strict Due Diligence Requirement for Newly Discovered Evidence under Federal Rule of Criminal Procedure 33

Date: Apr 9, 2025
Reaffirmation of Strict Due Diligence Requirement for Newly Discovered Evidence under Federal Rule of Criminal Procedure 33 Introduction United States v. Kaufman (2d Cir. Apr. 8, 2025) is a...
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