2d Circuit Case Commentaries

Tucker v. United States — No Per Se Conflict from Counsel’s Unrelated SDNY Investigation; Conflict-Free Co-Counsel Suffices for Curcio Advice

Date: Apr 4, 2026

Tucker v. United States: Limiting “Per Se” Sixth Amendment Conflicts to the Two Traditional Categories, and Clarifying that Conflict-Free Co-Counsel Can Provide Curcio Guidance 1. Introduction In...

Time-of-Filing Domicile Controls Diversity Jurisdiction; Post-Judgment Amendment Requires Vacatur; Appellate Jurisdiction Requires a Notice of Appeal from Reconsideration

Date: Apr 4, 2026

Time-of-Filing Domicile Controls Diversity Jurisdiction; Post-Judgment Amendment Requires Vacatur; Appellate Jurisdiction Requires a Notice of Appeal from Reconsideration 1. Introduction In Powell v....

Penzo v. Consolidated Edison Co. of N.Y.: Pretrial Authentication of Medical Records Under FRE 902(11) and No New Trial Without Concrete Prejudice from Alleged Trial Misconduct

Date: Apr 4, 2026

Penzo v. Consolidated Edison Co. of N.Y.: Pretrial Authentication of Medical Records Under FRE 902(11) and No New Trial Without Concrete Prejudice from Alleged Trial Misconduct Introduction In Penzo...

Deep Fee Cuts Affirmed: Denial of “Fees on Fees” and Across-the-Board Reductions for Unreliable, Vague, and Block-Billed Time Records

Date: Apr 4, 2026

Deep Fee Cuts Affirmed: Denial of “Fees on Fees” and Across-the-Board Reductions for Unreliable, Vague, and Block-Billed Time Records 1. Introduction Gym Door Repairs, Inc. and Safepath Systems LLC...

IDEA Judicial Review: District Courts Must Defer to Reasoned SRO Findings on Mixed Fact–Law Placement/IAES Questions

Date: Apr 4, 2026

IDEA Judicial Review: District Courts Must Defer to Reasoned SRO Findings on Mixed Fact–Law Placement/IAES Questions 1. Introduction In Bd. of Educ. of the Mamaroneck Union Free Sch. Dist. v. A.N.S....

Rule-of-Reason Sherman Act Claims Against the Ivy League Require Plausible Market Definition (American Express Footnote Narrowly Construed)

Date: Apr 4, 2026

Rule-of-Reason Sherman Act Claims Against the Ivy League Require Plausible Market Definition (American Express Footnote Narrowly Construed) 1. Introduction Case: Choh v. Brown University (2d Cir....

Nonprecedential Summary Order Reinforcing Strict Limits on Late Expert Supplements, Speculative Causation Opinions, and the Narrow Scope of Connecticut’s Consumer-Expectations Design-Defect Test

Date: Apr 4, 2026

Nonprecedential Summary Order Reinforcing Strict Limits on Late Expert Supplements, Speculative Causation Opinions, and the Narrow Scope of Connecticut’s Consumer-Expectations Design-Defect Test...

Standing Traceability in Offshore Wind Challenges Requires a “Determinative or Coercive Effect” on Third-Party State/Local Decisions

Date: Apr 4, 2026

Standing Traceability in Offshore Wind Challenges Requires a “Determinative or Coercive Effect” on Third-Party State/Local Decisions Case: Kinsella v. Bureau of Ocean Energy Mgmt., No. 25-355-cv (2d...

Rys v. Davis: Reaffirming the Second Circuit’s Sham-Affidavit Doctrine and the Proof Demands for § 1983 Equal Protection Hostile Work Environment Claims

Date: Apr 4, 2026

Rys v. Davis: Reaffirming the Second Circuit’s Sham-Affidavit Doctrine and the Proof Demands for § 1983 Equal Protection Hostile Work Environment Claims 1. Introduction Rys v. Davis (2d Cir. Apr. 2,...

Vidal v. Venettozzi: 180+ Days of Disciplinary SHU Confinement Triggers a Liberty Interest Based on Duration Alone

Date: Apr 4, 2026

Vidal v. Venettozzi: 180+ Days of Disciplinary SHU Confinement Triggers a Liberty Interest Based on Duration Alone 1. Introduction In Vidal v. Venettozzi (2d Cir. Apr. 1, 2026), Plaintiff-Appellant...

Forum-Selection Clauses Do Not Bar 28 U.S.C. § 1782 Discovery and Contract-Damages Counterclaims Fall Outside § 1782’s Scope (In re Orthogen International GmbH)

Date: Apr 4, 2026

Forum-Selection Clauses Do Not Bar 28 U.S.C. § 1782 Discovery and Contract-Damages Counterclaims Fall Outside § 1782’s Scope Introduction In In Re: Orthogen Int'l GmbH (2d Cir. Apr. 1, 2026) (summary...

Qualified Immunity and “Arguable Probable Cause” Based on a Putative Victim’s Complaint in Domestic-Incident Arrests (Jeanty v. Viruet)

Date: Apr 4, 2026

Qualified Immunity and “Arguable Probable Cause” Based on a Putative Victim’s Complaint in Domestic-Incident Arrests (Jeanty v. Viruet) Nonprecedential posture. The Second Circuit resolved Jeanty v....

Federal Sentencing: Above-Guidelines Variance Justified by Similar Gun Misconduct on Probation; Court May Forbear on Concurrency With a Hypothetical Future State Sentence

Date: Apr 4, 2026

Federal Sentencing: Above-Guidelines Variance Justified by Similar Gun Misconduct on Probation; Court May Forbear on Concurrency With a Hypothetical Future State Sentence Introduction In United...

Second Circuit Reaffirms Deference to Adverse Credibility Findings and the Immigration Judge’s Record-Development Role

Date: Apr 4, 2026

Second Circuit Reaffirms Deference to Adverse Credibility Findings and the Immigration Judge’s Record-Development Role Introduction Zeng v. Bondi (2d Cir. Mar. 31, 2026) is a nonprecedential “summary...

Coram Nobis Requires “Sound Reasons” for Delay: Ruan Does Not Create Timeliness, and the Mandate Rule Bars Repackaged Claims (United States v. Bouchard)

Date: Apr 3, 2026

Coram Nobis Requires “Sound Reasons” for Delay: Ruan Does Not Create Timeliness, and the Mandate Rule Bars Repackaged Claims (United States v. Bouchard, 2d Cir. Mar. 30, 2026) (summary order) 1....

Speculative Appeals and Contingent UAE Criminal Complaints Do Not Satisfy § 1782’s “For Use” Requirement; District Courts May Vacate Ex Parte § 1782 Orders and Quash Subpoenas in Full

Date: Apr 3, 2026

Speculative Appeals and Contingent UAE Criminal Complaints Do Not Satisfy § 1782’s “For Use” Requirement; District Courts May Vacate Ex Parte § 1782 Orders and Quash Subpoenas in Full 1. Introduction...

PSJVTA Deemed-Consent Jurisdiction Justifies Recall of Mandate and Reinstatement of a Vacated ATA Money Judgment

Date: Apr 3, 2026

PSJVTA Deemed-Consent Jurisdiction Justifies Recall of Mandate and Reinstatement of a Vacated ATA Money Judgment Case: Waldman v. Palestine Liberation Org. (2d Cir. Mar. 30, 2026) Court: United...

Article 78 Review as an Adequate Post-Deprivation Remedy for NYRA Credential Confiscation and Disciplinary Sanctions (Second Circuit Summary Order)

Date: Apr 3, 2026

Article 78 Review as an Adequate Post-Deprivation Remedy for NYRA Credential Confiscation and Disciplinary Sanctions (Second Circuit Summary Order) Introduction In Cobham v. N.Y. Racing Ass'n, Inc....

Traceability Requires Federal Control: Standing Fails Where State/Local Actors Independently Approve Onshore Components of a Federally Permitted Offshore Project

Date: Apr 3, 2026

Traceability Requires Federal Control: Standing Fails Where State/Local Actors Independently Approve Onshore Components of a Federally Permitted Offshore Project Introduction Kinsella v. Bureau of...

Reaffirming Limits on COVID-Mandate Litigation Against New York Courts: Eleventh Amendment Immunity, Mootness, and Title VII’s “Policymaking Appointee” Exclusion for City Judges

Date: Apr 3, 2026

Reaffirming Limits on COVID-Mandate Litigation Against New York Courts: Eleventh Amendment Immunity, Mootness, and Title VII’s “Policymaking Appointee” Exclusion for City Judges Introduction In Mora...