2d Circuit Case Commentaries

Oral Pronouncement or Express Incorporation Required for “Standard” Supervised Release Conditions; Defendant-Requested Special Conditions Are Waived: Commentary on United States v. Wilson (2d Cir. 2025)

Date: Sep 8, 2025

Oral Pronouncement or Express Incorporation Required for “Standard” Supervised Release Conditions; Defendant-Requested Special Conditions Are Waived: Commentary on United States v. Wilson (2d Cir....

Baltas v. Chapdelaine: No Qualified Immunity for Blanket Denial of Access to Existing Congregate Religious Services Absent Penological Justification

Date: Sep 8, 2025

No Qualified Immunity for Blanket Denial of Access to Existing Congregate Religious Services Absent Penological Justification Introduction In Baltas v. Chapdelaine, No. 22-2813-cv (2d Cir. Sept. 3,...

“Direct and Significant” Means What It Says: Second Circuit Clarifies CEA § 2(i)(1) Extraterritorial Reach and Confirms No Artificial-Price Element for Rule 180.1 Fraud

Date: Sep 8, 2025

“Direct and Significant” Means What It Says: Second Circuit Clarifies CEA § 2(i)(1) Extraterritorial Reach and Confirms No Artificial-Price Element for Rule 180.1 Fraud Introduction United States v....

“Restoration Period” Includes Functional Replacement of Lost Data; Audit and Covenant‑Compliance Costs Qualify as Extra Expenses After Electronic Equipment Failure (2d Cir. Summary Order)

Date: Sep 4, 2025

“Restoration Period” Includes Functional Replacement of Lost Data; Audit and Covenant‑Compliance Costs Qualify as Extra Expenses After Electronic Equipment Failure (2d Cir. Summary Order) Case: Ariz....

No Placeholders on Form I-589: Second Circuit Upholds Abandonment for Lack of “Specific Substantive Answers,” Highlights Withholding/CAT Standards, and Flags Counsel Conduct

Date: Sep 4, 2025

No Placeholders on Form I-589: Second Circuit Upholds Abandonment for Lack of “Specific Substantive Answers,” Highlights Withholding/CAT Standards, and Flags Counsel Conduct Introduction In...

Second Circuit Holds That Nonpayment of Arbitral Fees Mid‑Arbitration Is Not a “Refusal to Arbitrate” Under FAA § 4

Date: Sep 4, 2025

Second Circuit Holds That Nonpayment of Arbitral Fees Mid‑Arbitration Is Not a “Refusal to Arbitrate” Under FAA § 4 Introduction In Frazier v. X Corp., No. 24-1948 (2d Cir. Sept. 2, 2025), the U.S....

No Oral Hearing Required Under FRAP 46(b)(3) in Reciprocal Discipline; Baseless Judicial-Corruption Accusations Are Unprotected: Commentary on In re Jordan (2d Cir. 2025)

Date: Sep 2, 2025

No Oral Hearing Required Under FRAP 46(b)(3) in Reciprocal Discipline; Baseless Judicial-Corruption Accusations Are Unprotected: Commentary on In re Jordan (2d Cir. 2025) Introduction This commentary...

No “Front‑End” Sentence Increases to Offset First Step Act Credits or RDAP: The Second Circuit’s Sentencing Blueprint in United States v. James

Date: Sep 2, 2025

No “Front‑End” Sentence Increases to Offset First Step Act Credits or RDAP: The Second Circuit’s Sentencing Blueprint in United States v. James Introduction United States v. James is a consequential...

Rule 16b-3(d) Board Approval Needs Facts, Not Formal Labels: Second Circuit Clarifies Knowledge Standard for Deputized Directors in Roth v. Armistice Capital

Date: Aug 31, 2025

Rule 16b-3(d) Board Approval Needs Facts, Not Formal Labels: Second Circuit Clarifies Knowledge Standard for Deputized Directors in Roth v. Armistice Capital Introduction In Roth v. Armistice...

Second Circuit (en banc) Overrules Truscello: All Non‑Mandatory Supervised‑Release Conditions Must Be Pronounced at Sentencing

Date: Aug 31, 2025

Second Circuit (en banc) Overrules Truscello: All Non‑Mandatory Supervised‑Release Conditions Must Be Pronounced at Sentencing Introduction In United States v. Maiorana, the U.S. Court of Appeals for...

Castro‑Castro v. Bondi: Second Circuit Reaffirms Limits on Reopening and Administrative Closure to Pursue DHS Prosecutorial Discretion; DHS Enforcement Memos Are Not “New Evidence”

Date: Aug 31, 2025

Castro‑Castro v. Bondi: Second Circuit Reaffirms Limits on Reopening and Administrative Closure to Pursue DHS Prosecutorial Discretion; DHS Enforcement Memos Are Not “New Evidence” Court: U.S. Court...

Ambiguity in State Confidentiality Law Defeats “Clearly Established” Prong: Second Circuit Grants Qualified Immunity for VHRC Officials and Confirms the Commission’s Sovereign Immunity

Date: Aug 31, 2025

Ambiguity in State Confidentiality Law Defeats “Clearly Established” Prong: Second Circuit Grants Qualified Immunity for VHRC Officials and Confirms the Commission’s Sovereign Immunity Case: Leise v....

Good-Faith Reliance on Cellphone Warrants with Minimal Nexus: The Second Circuit’s Guidance in United States v. Santos

Date: Aug 31, 2025

Good-Faith Reliance on Cellphone Warrants with Minimal Nexus: The Second Circuit’s Guidance in United States v. Santos Court: U.S. Court of Appeals for the Second Circuit (Summary Order) Date: August...

When “Hypothetical” Risk Factors Mask Realized Risks—and Strategy Labels Mislead: The Second Circuit’s Partial Revival of Peloton Securities Claims

Date: Aug 31, 2025

When “Hypothetical” Risk Factors Mask Realized Risks—and Strategy Labels Mislead: The Second Circuit’s Partial Revival of Peloton Securities Claims Introduction This commentary analyzes the Second...

O’Neill v. Deml: Second Circuit Holds No Duty to Warn Pro Se § 2254 Petitioners About Mixed Petitions, Stays, or AEDPA Deadlines

Date: Aug 31, 2025

O’Neill v. Deml: Second Circuit Holds No Duty to Warn Pro Se § 2254 Petitioners About Mixed Petitions, Stays, or AEDPA Deadlines Introduction In O’Neill v. Deml, No. 23-620 (2d Cir. Aug. 27, 2025),...

After Egbert, DHS’s § 287.10 Grievance Scheme Forecloses Bivens Claims Against HSI Agents; Fabrication‑Based False Arrest Presents a New Bivens Context in the Second Circuit

Date: Aug 31, 2025

After Egbert, DHS’s § 287.10 Grievance Scheme Forecloses Bivens Claims Against HSI Agents; Fabrication‑Based False Arrest Presents a New Bivens Context in the Second Circuit Introduction In...

Schnabel Goes Offline: Later‑Sent, Unflagged Arbitration Clauses in Mailed “Welcome Packages” Do Not Bind Absent Clear Notice and Assent

Date: Aug 31, 2025

Schnabel Goes Offline: Later‑Sent, Unflagged Arbitration Clauses in Mailed “Welcome Packages” Do Not Bind Absent Clear Notice and Assent Introduction In Sudakow v. CleanChoice Energy, Inc., the...

Depraved‑Mind Attempted Murder Qualifies as a “Crime of Violence” Under the Guidelines: United States v. Delgado (2d Cir. 2025)

Date: Aug 31, 2025

Depraved‑Mind Attempted Murder Qualifies as a “Crime of Violence” Under the Guidelines: United States v. Delgado (2d Cir. 2025) Introduction United States v. Delgado is a precedential Second Circuit...

Post-Bruen Challenges to Pistol Permit Denials: Second Circuit Reaffirms Absolute Judicial Immunity and Eleventh Amendment Limits on Suits Against State Judges

Date: Aug 31, 2025

Post-Bruen Challenges to Pistol Permit Denials: Second Circuit Reaffirms Absolute Judicial Immunity and Eleventh Amendment Limits on Suits Against State Judges Introduction This commentary analyzes...

Terminal-Only Mandates Are ANCA “Access Restrictions” Even If Valid Under the ADA’s Proprietor Exception: Commentary on Delux Public Charter v. County of Westchester (2d Cir. 2025, Summary Order)

Date: Aug 31, 2025

Terminal-Only Mandates Are ANCA “Access Restrictions” Even If Valid Under the ADA’s Proprietor Exception In Delux Public Charter v. County of Westchester, the Second Circuit (by summary order) held...