2d Circuit Case Commentaries

Routine Medical Judgment Does Not Violate the Eighth Amendment: Denial of Non-Emergency MRI Is Not Deliberate Indifference

Date: Apr 9, 2025

Routine Medical Judgment Does Not Violate the Eighth Amendment: Denial of Non-Emergency MRI Is Not Deliberate Indifference Introduction In Wright v. Martin, No. 23-7762-pr (2d Cir. Apr. 8, 2025), the...

Reaffirming the Due Diligence Standard for Newly Discovered Evidence in Rule 33 Motions

Date: Apr 9, 2025

Reaffirming the Due Diligence Standard for Newly Discovered Evidence in Rule 33 Motions Introduction In United States v. Kaufman, No. 23-6807-cr (2d Cir. Apr. 8, 2025), the Second Circuit addressed a...

NYCHRL “Marital Status” Limited to General Condition, Not Specific Spousal Relationships

Date: Apr 9, 2025

NYCHRL “Marital Status” Limited to General Condition, Not Specific Spousal Relationships Introduction Hunter v. Debmar-Mercury LLC (2d Cir. Apr. 8, 2025) addressed whether the New York City Human...

Reaffirmation of Due Diligence in Newly Discovered Evidence and Venue Principles under Rule 33 (United States v. Kaufman)

Date: Apr 9, 2025

Reaffirmation of Due Diligence in Newly Discovered Evidence and Venue Principles under Rule 33 (United States v. Kaufman) Introduction United States v. Kaufman (2d Cir. Apr. 8, 2025) arose from the...

Reaffirmation of Summary Judgment Standards and Pro Se Evidentiary Obligations

Date: Apr 9, 2025

Reaffirmation of Summary Judgment Standards and Pro Se Evidentiary Obligations Introduction This commentary examines the United States Court of Appeals for the Second Circuit’s summary order in...

Deference to State Review Officers and Limits on Speculative Grouping Challenges in IDEA Disputes

Date: Apr 9, 2025

Deference to State Review Officers and Limits on Speculative Grouping Challenges in IDEA Disputes Introduction This commentary examines the Second Circuit’s summary order in Zayas v. Banks,...

Clarifying Marital Status Under NYCHRL: Exclusion of Spousal-Identity Discrimination

Date: Apr 9, 2025

Clarifying Marital Status Under NYCHRL: Exclusion of Spousal-Identity Discrimination Introduction In Hunter v. Debmar-Mercury LLC, 24-1229 (2d Cir. Apr. 8, 2025), the Second Circuit addressed for the...

Affirming IPKCA Enforcement and Voiding Child Marriages under Guatemalan Law

Date: Apr 9, 2025

Affirming IPKCA Enforcement and Voiding Child Marriages under Guatemalan Law Introduction United States v. Helbrans is a consolidated direct criminal appeal decided by the Second Circuit on April 8,...

Clarifying Summary Judgment Standards and the Scope of Extrarecord Evidence: Insights from Sterling v. Deutsche Bank Nat’l Trust Co.

Date: Apr 9, 2025

Clarifying Summary Judgment Standards and the Scope of Extrarecord Evidence: Insights from Sterling v. Deutsche Bank Nat’l Trust Co. 1. Introduction In Sterling v. Deutsche Bank Nat’l Trust Co., the...

Deference to State Review Officer Decisions in IDEA Appeals and Limits on Speculative Grouping Challenges

Date: Apr 9, 2025

Deference to State Review Officer Decisions in IDEA Appeals and Limits on Speculative Grouping Challenges Introduction In Zayas v. Banks, 24-1076-cv (2d Cir. Apr. 8, 2025), the Second Circuit...

Requirement of Individualized Justification for Special Supervised Release Conditions Under U.S.S.G. §5D1.3 and §5F1.5

Date: Apr 9, 2025

Requirement of Individualized Justification for Special Supervised Release Conditions Under U.S.S.G. §5D1.3 and §5F1.5 Introduction United States v. Love, 24-1706-cr (2d Cir. Apr. 8, 2025) arises...

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

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

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

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

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

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

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

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)

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...