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  • Commentaries
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new-precedent-on... Case Commentaries

United States v. Gunn: Consecutive Sentences for Hobbs Act Conspiracy and Attempt Beyond the 20‑Year Maximum

United States v. Gunn: Consecutive Sentences for Hobbs Act Conspiracy and Attempt Beyond the 20‑Year Maximum

Date: Dec 20, 2025
United States v. Gunn: Consecutive Sentences for Hobbs Act Conspiracy and Attempt Beyond the 20‑Year Maximum I. Introduction The Second Circuit’s decision in United States v. Gunn, No. 24‑2430‑cr (2d...
Poor v. Parking Systems Plus, Inc.: Winter, McKinney, and the “Perfectly Clear” Successor in § 10(j) Practice

Poor v. Parking Systems Plus, Inc.: Winter, McKinney, and the “Perfectly Clear” Successor in § 10(j) Practice

Date: Dec 20, 2025
Poor v. Parking Systems Plus, Inc.: The Second Circuit’s First Full Winter–McKinney § 10(j) Decision and a Strong Reaffirmation of Successor Employer Obligations I. Introduction Poor v. Parking...
Specific Evidence, Not Generalized Religious Fears: Jessop v. Combs and Unsupervised Parenting Time in the Shadow of Alleged FLDS Ties

Specific Evidence, Not Generalized Religious Fears: Jessop v. Combs and Unsupervised Parenting Time in the Shadow of Alleged FLDS Ties

Date: Dec 20, 2025
Specific Evidence, Not Generalized Religious Fears: Jessop v. Combs and Unsupervised Parenting Time in the Shadow of Alleged FLDS Ties I. Introduction The South Dakota Supreme Court’s decision in...
Open‑Ended Answer Extensions as “Good Cause” Against Failure‑to‑Prosecute Dismissals: Commentary on Arrowsmith v. Odle, 2025 S.D. 70

Open‑Ended Answer Extensions as “Good Cause” Against Failure‑to‑Prosecute Dismissals: Commentary on Arrowsmith v. Odle, 2025 S.D. 70

Date: Dec 20, 2025
Open‑Ended Answer Extensions as “Good Cause” Precluding Failure‑to‑Prosecute Dismissals: A Commentary on Arrowsmith v. Odle, 2025 S.D. 70 I. Introduction In Arrowsmith v. Odle, 2025 S.D. 70, the...
Matter of Hernandez: Reciprocal Disbarment, Self‑Reporting Duties, and Supervisory Liability in Virtual Law Offices

Matter of Hernandez: Reciprocal Disbarment, Self‑Reporting Duties, and Supervisory Liability in Virtual Law Offices

Date: Dec 20, 2025
Matter of Hernandez: Reciprocal Disbarment, Self‑Reporting Duties, and Supervisory Liability in Virtual Law Offices I. Introduction The Appellate Division, First Department’s decision in Matter of...
Co‑Counsel Duties, Charging Liens, and Joint Contingency Fees: Commentary on Gelwan v. De Ratafia

Co‑Counsel Duties, Charging Liens, and Joint Contingency Fees: Commentary on Gelwan v. De Ratafia

Date: Dec 20, 2025
Co‑Counsel Duties, Charging Liens, and Joint Contingency Fees: A Comprehensive Commentary on Gelwan v. De Ratafia, 2025 NY Slip Op 07093 I. Introduction Gelwan v. De Ratafia (App Div 1st Dept, Dec....
Plain Error, Dual‑Role Experts, and Sentencing Waiver: Commentary on United States v. De’Andre Owens

Plain Error, Dual‑Role Experts, and Sentencing Waiver: Commentary on United States v. De’Andre Owens

Date: Dec 20, 2025
Plain Error, Dual‑Role Experts, and Sentencing Waiver: Commentary on United States v. De’Andre Owens I. Introduction United States v. De’Andre Owens (7th Cir. Dec. 19, 2025) is a tightly focused...
Reaffirming Summary Dismissal and the Prejudice Requirement in Immigration Ineffective-Assistance Claims: Commentary on Alba Castillo‑De Molina v. Bondi

Reaffirming Summary Dismissal and the Prejudice Requirement in Immigration Ineffective-Assistance Claims: Commentary on Alba Castillo‑De Molina v. Bondi

Date: Dec 20, 2025
Reaffirming Summary Dismissal and the Prejudice Requirement in Immigration Ineffective-Assistance Claims: Commentary on Alba Castillo‑De Molina v. Bondi I. Introduction This nonprecedential order...
Harmless Error Review of Erlinger Violations in ACCA Sentencing: Commentary on United States v. Beasley (7th Cir. 2025)

Harmless Error Review of Erlinger Violations in ACCA Sentencing: Commentary on United States v. Beasley (7th Cir. 2025)

Date: Dec 20, 2025
Harmless Error Review of Erlinger Violations in ACCA Sentencing: Commentary on United States v. Beasley (7th Cir. 2025) I. Introduction The Seventh Circuit’s decision in United States v. Alvin...
United States v. Jones: Plain Error in Prosecutorial Use of Unadmitted Evidence and Limits on Rap Evidence in § 924(c) Prosecutions

United States v. Jones: Plain Error in Prosecutorial Use of Unadmitted Evidence and Limits on Rap Evidence in § 924(c) Prosecutions

Date: Dec 20, 2025
United States v. Hassan Jones (11th Cir. 2025): Plain Error in Prosecutorial Use of Unadmitted Evidence and Limits on Rap Evidence in § 924(c) Prosecutions I. Introduction United States v. Hassan...
Substantive Parental Change, Domestic Violence, and Child Preference in Alaska CINA Terminations: Commentary on Millie T. & Frank L. v. State

Substantive Parental Change, Domestic Violence, and Child Preference in Alaska CINA Terminations: Commentary on Millie T. & Frank L. v. State

Date: Dec 20, 2025
Substantive Parental Change, Domestic Violence, and Child Preference in Alaska CINA Terminations: Commentary on Millie T. & Frank L. v. State I. Introduction This memorandum opinion of the Alaska...
United States v. Boone: Applying § 2G2.2 with “Great Care” and a Flexible Paroline Restitution Analysis in a Non‑Precedential Summary Order

United States v. Boone: Applying § 2G2.2 with “Great Care” and a Flexible Paroline Restitution Analysis in a Non‑Precedential Summary Order

Date: Dec 20, 2025
United States v. Boone: Applying § 2G2.2 with “Great Care” and a Flexible Paroline Restitution Analysis in a Non‑Precedential Summary Order I. Introduction In United States v. Boone, Nos. 25‑272‑cr...
Matthews v. Rasa: Pleading Standards for Pro Se Title VII and ADEA Claims in the Second Circuit

Matthews v. Rasa: Pleading Standards for Pro Se Title VII and ADEA Claims in the Second Circuit

Date: Dec 20, 2025
Matthews v. Rasa: Pleading Standards for Pro Se Title VII and ADEA Claims in the Second Circuit I. Introduction Matthews v. Rasa, No. 24-2499-cv (2d Cir. Dec. 19, 2025) (summary order), is a...
Strict Enforcement of Issue Preservation and Counsel Competence in Immigration Appeals: Commentary on Salazar‑Gutierrez v. Bondi (2d Cir. Dec. 19, 2025)

Strict Enforcement of Issue Preservation and Counsel Competence in Immigration Appeals: Commentary on Salazar‑Gutierrez v. Bondi (2d Cir. Dec. 19, 2025)

Date: Dec 20, 2025
Strict Enforcement of Issue Preservation and Counsel Competence in Immigration Appeals: Commentary on Salazar‑Gutierrez v. Bondi (2d Cir. Dec. 19, 2025) I. Introduction This commentary analyzes the...
Material Omissions, Authorship Inconsistencies, and “Canned” Corroboration: The Second Circuit’s Application of Adverse Credibility Principles in Padilla‑Guaman v. Bondi

Material Omissions, Authorship Inconsistencies, and “Canned” Corroboration: The Second Circuit’s Application of Adverse Credibility Principles in Padilla‑Guaman v. Bondi

Date: Dec 20, 2025
Material Omissions, Authorship Inconsistencies, and “Canned” Corroboration: The Second Circuit’s Application of Adverse Credibility Principles in Padilla‑Guaman v. Bondi I. Introduction This...
Veksler v. Wipro, LLC: Reaffirming the “Conscious Objective” Intent Standard Under ECPA, SCA, and CFAA

Veksler v. Wipro, LLC: Reaffirming the “Conscious Objective” Intent Standard Under ECPA, SCA, and CFAA

Date: Dec 20, 2025
Veksler v. Wipro, LLC: Reaffirming the “Conscious Objective” Intent Standard Under ECPA, SCA, and CFAA Court: United States Court of Appeals for the Second Circuit (Summary Order) Docket: No. 25-369...
United States v. Brazoban: Silence at Sentencing Is Not Waiver and Typographical Corrections to Supervised-Release Conditions Are Permissible Clarifications

United States v. Brazoban: Silence at Sentencing Is Not Waiver and Typographical Corrections to Supervised-Release Conditions Are Permissible Clarifications

Date: Dec 20, 2025
United States v. Brazoban: Silence at Sentencing Is Not Waiver and Typographical Corrections to Supervised-Release Conditions Are Permissible Clarifications Court: United States Court of Appeals for...
Younger Abstention and Probation Violation Appeals: Commentary on Torres v. Office of Adult Probation (2d Cir. 2025)

Younger Abstention and Probation Violation Appeals: Commentary on Torres v. Office of Adult Probation (2d Cir. 2025)

Date: Dec 20, 2025
Younger Abstention and Probation Violation Appeals: Commentary on Torres v. Office of Adult Probation (2d Cir. 2025) I. Introduction This commentary analyzes the Second Circuit’s summary order in...
Residual Hearsay, Mistrial Standards, and Completed Hobbs Act Robbery as a § 924(j) Predicate: Commentary on United States v. Kidd (2d Cir. 2025)

Residual Hearsay, Mistrial Standards, and Completed Hobbs Act Robbery as a § 924(j) Predicate: Commentary on United States v. Kidd (2d Cir. 2025)

Date: Dec 20, 2025
Residual Hearsay, Mistrial Standards, and Completed Hobbs Act Robbery as a § 924(j) Predicate: A Commentary on United States v. Kidd (2d Cir. 2025) I. Introduction This commentary analyzes the Second...
United States v. Snipe and the Oral Pronouncement of Supervised Release Conditions After Maiorana

United States v. Snipe and the Oral Pronouncement of Supervised Release Conditions After Maiorana

Date: Dec 20, 2025
United States v. Snipe and the Oral Pronouncement of Supervised Release Conditions After Maiorana I. Introduction The Second Circuit’s summary order in United States v. Snipe, No. 24‑2101 (2d Cir....
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