2d Circuit Case Commentaries

PLRA Grievances Must Signal Retaliation; Evidence Beyond Disagreement or Injury‑Free Delay Needed to Survive Summary Judgment on Prison Medical Claims

Date: Sep 13, 2025

PLRA Grievances Must Signal Retaliation; Evidence Beyond Disagreement or Injury‑Free Delay Needed to Survive Summary Judgment on Prison Medical Claims Editorial note: This is a Second Circuit summary...

Mootness of § 1443 Removal Appeals After State Discontinuance—and Vacatur as the Default Remedy: Commentary on Town of Newburgh v. Newburgh EOM LLC (2d Cir. 2025)

Date: Sep 12, 2025

Mootness of § 1443 Removal Appeals After State Discontinuance—and Vacatur as the Default Remedy Case: Town of Newburgh v. Newburgh EOM LLC (d/b/a Crossroads Hotels) Court: United States Court of...

Respondent Must Invoke Right to Review Evidence: Second Circuit Reads 8 C.F.R. § 1240.10(a)(4) as Advisory Only and Reaffirms Presumption of Competence in Removal Proceedings

Date: Sep 12, 2025

Respondent Must Invoke Right to Review Evidence: Second Circuit Reads 8 C.F.R. § 1240.10(a)(4) as Advisory Only and Reaffirms Presumption of Competence in Removal Proceedings Note: This is a summary...

Clarifying “Antitrust Injury” vs. Substantive Pleading and Reaffirming Rule‑of‑Reason Requirements for Vertical Restraints: Amigo Shuttle v. Port Authority (2d Cir. 2025)

Date: Sep 12, 2025

Clarifying “Antitrust Injury” vs. Substantive Pleading and Reaffirming Rule‑of‑Reason Requirements for Vertical Restraints: Amigo Shuttle v. Port Authority (2d Cir. 2025) Court: U.S. Court of Appeals...

NCMEC Is a Governmental Entity for Fourth Amendment Purposes, But ESP Hash-Matching Alone Does Not Make Providers Government Agents: A Comprehensive Commentary on United States v. Guard (2d Cir. 2025)

Date: Sep 11, 2025

NCMEC Is a Governmental Entity for Fourth Amendment Purposes, But ESP Hash-Matching Alone Does Not Make Providers Government Agents Comprehensive Commentary on United States v. Guard, No. 23-6886 (2d...

Accommodation Cannot Compel Illegality: Second Circuit Reaffirms that Title VII Does Not Require Employers to Violate State Vaccination Rules, and Uniform Mandates Do Not Support ADA “Regarded As” Claims

Date: Sep 11, 2025

Accommodation Cannot Compel Illegality: Second Circuit Reaffirms that Title VII Does Not Require Employers to Violate State Vaccination Rules, and Uniform Mandates Do Not Support ADA “Regarded As”...

Device‑Location Data Is CPNI Under § 222: Second Circuit Upholds FCC Forfeiture and Clarifies Seventh Amendment Path via § 504(a)

Date: Sep 11, 2025

Device‑Location Data Is CPNI Under § 222: Second Circuit Upholds FCC Forfeiture and Clarifies Seventh Amendment Path via § 504(a) Introduction This commentary analyzes the Second Circuit’s decision...

For Pre‑2021 Asylum Filings, Past Persecution Triggers a Presumption that Internal Relocation Is Unreasonable—Burden Rests with DHS (Sahni v. Bondi)

Date: Sep 11, 2025

For Pre‑2021 Asylum Filings, Past Persecution Triggers a Presumption that Internal Relocation Is Unreasonable—Burden Rests with DHS (Sahni v. Bondi) Introduction This commentary analyzes the Second...

Second Circuit: Rule 37(b) Attorney Sanctions—Including MDL Leadership Removal and Common Benefit Restrictions—Are Not Immediately Appealable Under the Collateral Order Doctrine

Date: Sep 11, 2025

Second Circuit: Rule 37(b) Attorney Sanctions—Including MDL Leadership Removal and Common Benefit Restrictions—Are Not Immediately Appealable Under the Collateral Order Doctrine Introduction In In...

New York Claim Preclusion Reaffirmed: “Convenient Trial Unit” Is Non‑Dispositive; Different Contracts Do Not Avoid Res Judicata When Tied to the Same Transactional Nucleus

Date: Sep 11, 2025

New York Claim Preclusion Reaffirmed: “Convenient Trial Unit” Is Non‑Dispositive; Different Contracts Do Not Avoid Res Judicata When Tied to the Same Transactional Nucleus Introduction This...

Content-Neutral, Not Content-Based: Second Circuit Holds New York’s UPL Restrictions on One-to-One Legal Advice Are Subject to Intermediate Scrutiny

Date: Sep 10, 2025

Content-Neutral, Not Content-Based: Second Circuit Holds New York’s UPL Restrictions on One-to-One Legal Advice Are Subject to Intermediate Scrutiny Introduction In Upsolve, Inc. v. James, the United...

Walton v. Comfort Systems: Fire Alarm Testing and Inspection Is Covered “Maintenance” Under NYLL § 220; Second Circuit Certifies Whether the Prevailing-Wage Promise Is Implied in All Public Works Contracts and Whether One‑Year Limitations Clauses Bind Workers

Date: Sep 10, 2025

Walton v. Comfort Systems: Fire Alarm Testing and Inspection Is Covered “Maintenance” Under NYLL § 220; Second Circuit Certifies Whether the Prevailing-Wage Promise Is Implied in All Public Works...

Neutral Laws Require Neutral Enforcement: Second Circuit Holds that Hostility-Tainted Discipline by a State Athletics Association Violates the Free Exercise Clause

Date: Sep 10, 2025

Neutral Laws Require Neutral Enforcement: Second Circuit Holds that Hostility-Tainted Discipline by a State Athletics Association Violates the Free Exercise Clause Introduction In Mid Vermont...

Second Circuit Reaffirms Strict Pleading, Causation, and Timeliness Requirements for Hybrid § 301/Duty of Fair Representation Claims: Goodman v. Local 804 (IBT) & UPS

Date: Sep 10, 2025

Second Circuit Reaffirms Strict Pleading, Causation, and Timeliness Requirements for Hybrid § 301/Duty of Fair Representation Claims: Goodman v. Local 804 (IBT) & UPS Note: This disposition is a...

Footnotes Don’t Preserve Arguments: Second Circuit’s Waiver Ruling on Grokster-Based “Right and Ability to Control” under DMCA §512(c) in Capitol Records v. Vimeo (Rehearing)

Date: Sep 10, 2025

Footnotes Don’t Preserve Arguments: Second Circuit’s Waiver Ruling on Grokster-Based “Right and Ability to Control” under DMCA §512(c) in Capitol Records v. Vimeo (Rehearing) Introduction This...

Applying Maiorana, the Second Circuit Confirms Incorporation-by-Reference of Supervised-Release Conditions and Upholds Broad Reasonable-Suspicion Search Condition: United States v. Gomez

Date: Sep 10, 2025

Applying Maiorana, the Second Circuit Confirms Incorporation-by-Reference of Supervised-Release Conditions and Upholds Broad Reasonable-Suspicion Search Condition: United States v. Gomez Introduction...

Punitive Damages in New York Defamation Need Not Be “Sole-Motive” Malice and Are Proven by a Preponderance: The Second Circuit’s Clarification in Carroll v. Trump

Date: Sep 9, 2025

Punitive Damages in New York Defamation Need Not Be “Sole-Motive” Malice and Are Proven by a Preponderance: The Second Circuit’s Clarification in Carroll v. Trump Introduction In Carroll v. Trump,...

Temporal Proximity Must Be Very Close: One-Year Gap and Isolated Stray Remarks Are Insufficient to Plausibly Plead Discrimination or Retaliation under Title VII, NYSHRL, and NYCHRL

Date: Sep 9, 2025

Temporal Proximity Must Be Very Close: One-Year Gap and Isolated Stray Remarks Are Insufficient to Plausibly Plead Discrimination or Retaliation under Title VII, NYSHRL, and NYCHRL Introduction This...

Medication-Compliance Clarifications and Reasonable‑Suspicion Digital‑Search Conditions on Supervised Release: The Second Circuit’s Guidance in United States v. Woods (Summary Order)

Date: Sep 9, 2025

Medication-Compliance Clarifications and Reasonable‑Suspicion Digital‑Search Conditions on Supervised Release: The Second Circuit’s Guidance in United States v. Woods (Summary Order) Court: U.S....

No Constructive Amendment From Alternative MNPI Inferences; SDNY Venue Firmly Grounded for Nasdaq Trades: Commentary on United States v. Dagar (2d Cir. 2025)

Date: Sep 8, 2025

No Constructive Amendment From Alternative MNPI Inferences; SDNY Venue Firmly Grounded for Nasdaq Trades: Commentary on United States v. Dagar (2d Cir. 2025) Note on precedential status: The decision...