2d Circuit Case Commentaries

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

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

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

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

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

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

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

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

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

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...

Due Diligence Requirement in Rule 33 Motions and Venue Principles for Corrupt Gratuities under 18 U.S.C. § 215(a)(2)

Date: Apr 9, 2025

Due Diligence Requirement in Rule 33 Motions and Venue Principles for Corrupt Gratuities under 18 U.S.C. § 215(a)(2) 1. Introduction United States v. Kaufman (2d Cir. Apr. 8, 2025) arises from the...

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

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

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

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

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

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

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

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

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),...