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  • Commentaries
  • Judgments

2d Circuit Case Commentaries

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...
Affirming the IPKCA’s Reach and Voiding Underage Foreign Marriages: United States v. Helbrans

Affirming the IPKCA’s Reach and Voiding Underage Foreign Marriages: United States v. Helbrans

Date: Apr 9, 2025
Affirming the IPKCA’s Reach and Voiding Underage Foreign Marriages: United States v. Helbrans Introduction In United States v. Helbrans (2d Cir. Apr. 8, 2025), the Second Circuit addressed a...
Deference to State Review Officer Determinations and Speculative IEP Placement Challenges: Zayas v. Banks

Deference to State Review Officer Determinations and Speculative IEP Placement Challenges: Zayas v. Banks

Date: Apr 9, 2025
Deference to State Review Officer Determinations and Speculative IEP Placement Challenges: Zayas v. Banks Introduction Zayas v. Banks is a summary order issued on April 8, 2025, by the United States...
Affirmation of International Parental Kidnapping Provisions and the Void Effect of Child Marriages under Foreign Law

Affirmation of International Parental Kidnapping Provisions and the Void Effect of Child Marriages under Foreign Law

Date: Apr 9, 2025
Affirmation of International Parental Kidnapping Provisions and the Void Effect of Child Marriages under Foreign Law Introduction This commentary addresses the Second Circuit’s summary order in...
Deference to State Review Officer and Limits on Speculative Grouping: Zayas v. Banks

Deference to State Review Officer and Limits on Speculative Grouping: Zayas v. Banks

Date: Apr 9, 2025
Deference to State Review Officer and Limits on Speculative Grouping: Zayas v. Banks Introduction In Zayas v. Banks, 24-1076-cv (2d Cir. April 8, 2025), Rosa and Edwin Zayas, individually and as...
Marital Status under NYCHRL: Distinction Between General Condition and Specific Spousal Relationship

Marital Status under NYCHRL: Distinction Between General Condition and Specific Spousal Relationship

Date: Apr 9, 2025
Marital Status under NYCHRL: Distinction Between General Condition and Specific Spousal Relationship Introduction Hunter v. Debmar-Mercury LLC is a Second Circuit interlocutory appeal that tested the...
Establishing Awareness and But-For Causation: Clarifying Title VII Retaliation Standards in Khazin v. City of New York

Establishing Awareness and But-For Causation: Clarifying Title VII Retaliation Standards in Khazin v. City of New York

Date: Apr 9, 2025
Establishing Awareness and But-For Causation: Clarifying Title VII Retaliation Standards in Khazin v. City of New York Introduction Khazin v. City of New York is a summary order issued by the United...
United States v. Love: Particularized On-the-Record Justification for Severe Supervised Release Conditions

United States v. Love: Particularized On-the-Record Justification for Severe Supervised Release Conditions

Date: Apr 9, 2025
United States v. Love: Particularized On-the-Record Justification for Severe Supervised Release Conditions Introduction The Court of Appeals for the Second Circuit’s summary order in United States v....
Clarification of Employer Awareness and But-For Causation in Title VII Retaliation Claims: Khazin v. City of New York

Clarification of Employer Awareness and But-For Causation in Title VII Retaliation Claims: Khazin v. City of New York

Date: Apr 9, 2025
Clarification of Employer Awareness and But-For Causation in Title VII Retaliation Claims: Khazin v. City of New York Introduction In Khazin v. City of New York, 24-1236-cv (2d Cir. Apr. 8, 2025),...
Affirmation of Summary Judgment Standards and Limits on New Evidence in Sterling v. Deutsche Bank

Affirmation of Summary Judgment Standards and Limits on New Evidence in Sterling v. Deutsche Bank

Date: Apr 9, 2025
Affirmation of Summary Judgment Standards and Limits on New Evidence in Sterling v. Deutsche Bank Introduction Sterling v. Deutsche Bank Nat’l Tr. Co. is a pro se appeal decided by the United States...
Clarification of “Marital Status” Under NYCHRL: Exclusion of Relationship-Specific Discrimination

Clarification of “Marital Status” Under NYCHRL: Exclusion of Relationship-Specific Discrimination

Date: Apr 9, 2025
Clarification of “Marital Status” Under NYCHRL: Exclusion of Relationship-Specific Discrimination Introduction The Court of Appeals for the Second Circuit’s summary order in Hunter v. Debmar-Mercury...
Permissible Disclosure of Presentence Reports and Medical Records in Supervised Release: United States v. Harris

Permissible Disclosure of Presentence Reports and Medical Records in Supervised Release: United States v. Harris

Date: Apr 9, 2025
Permissible Disclosure of Presentence Reports and Medical Records in Supervised Release: United States v. Harris Introduction United States v. Harris is a Second Circuit summary order, decided April...
Hunter v. Debmar-Mercury LLC: “Marital Status” Under NYCHRL Limited to Legal Condition, Not Specific Spousal Relationship

Hunter v. Debmar-Mercury LLC: “Marital Status” Under NYCHRL Limited to Legal Condition, Not Specific Spousal Relationship

Date: Apr 9, 2025
Hunter v. Debmar-Mercury LLC: “Marital Status” Under NYCHRL Limited to Legal Condition, Not Specific Spousal Relationship Introduction Hunter v. Debmar-Mercury LLC is a interlocutory appeal decided...
Clarifying Deference to State Review Officers and Substantive Standards for FAPE under IDEA

Clarifying Deference to State Review Officers and Substantive Standards for FAPE under IDEA

Date: Apr 9, 2025
Clarifying Deference to State Review Officers and Substantive Standards for FAPE under IDEA 1. Introduction In Zayas v. Banks, 24-1076-cv (2d Cir. Apr. 8, 2025), the United States Court of Appeals...
Reaffirmation of Due Diligence Requirement for Newly Discovered Evidence in Rule 33 Motions: United States v. Kaufman

Reaffirmation of Due Diligence Requirement for Newly Discovered Evidence in Rule 33 Motions: United States v. Kaufman

Date: Apr 9, 2025
Reaffirmation of Due Diligence Requirement for Newly Discovered Evidence in Rule 33 Motions: United States v. Kaufman 1. Introduction United States v. Kaufman is a summary order issued by the United...
Evidentiary Requirements for Summary Judgment and Appellate Review of New Evidence

Evidentiary Requirements for Summary Judgment and Appellate Review of New Evidence

Date: Apr 9, 2025
Evidentiary Requirements for Summary Judgment and Appellate Review of New Evidence Introduction Sterling v. Deutsche Bank Nat’l Trust Co., 23-7645-cv (2d Cir. Apr. 8, 2025), is a pro se appeal from...
Mandating Due Diligence for Newly Discovered Evidence and Venue Determination under 18 U.S.C. § 215: United States v. Kaufman

Mandating Due Diligence for Newly Discovered Evidence and Venue Determination under 18 U.S.C. § 215: United States v. Kaufman

Date: Apr 9, 2025
Mandating Due Diligence for Newly Discovered Evidence and Venue Determination under 18 U.S.C. § 215: United States v. Kaufman Introduction United States v. Kaufman is a Second Circuit summary order...
Awareness and But-For Causation in Title VII Retaliation Claims: Khazin v. City of New York

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

Date: Apr 9, 2025
Awareness and But-For Causation in Title VII Retaliation Claims: Khazin v. City of New York Introduction In Khazin v. City of New York (2d Cir. Apr. 8, 2025), the United States Court of Appeals for...
Extension of Insured Status to Third Parties and Co-Excess Allocation in Risk Retention Group Policies

Extension of Insured Status to Third Parties and Co-Excess Allocation in Risk Retention Group Policies

Date: Apr 8, 2025
Extension of Insured Status to Third Parties and Co-Excess Allocation in Risk Retention Group Policies Introduction County of Ulster v. Alliance of Nonprofits for Insurance Risk Retention Group,...
Endorsement-Extended Insured Status and Co-Excess Coverage: County of Ulster v. Alliance of Nonprofits

Endorsement-Extended Insured Status and Co-Excess Coverage: County of Ulster v. Alliance of Nonprofits

Date: Apr 8, 2025
Endorsement-Extended Insured Status and Co-Excess Coverage: County of Ulster v. Alliance of Nonprofits for Insurance Risk Retention Group Introduction County of Ulster v. Alliance of Nonprofits for...
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