Recent changes
Vidal v. Venettozzi - Prison Disciplinary Due Process
The Second Circuit vacated the Southern District of New York's summary judgment in Vidal v. Venettozzi, ruling that 270 days (or 180 days served) of disciplinary segregation in the Special Housing Unit constitutes an atypical and significant hardship triggering Fourteenth Amendment due process protections. The court held that prison officials must provide basic procedural safeguards including the opportunity to call witnesses and present documentary evidence at disciplinary hearings when confinement duration meets this threshold.
Waldman v. Palestine Liberation Org. - Terrorism Damages
The Second Circuit decided motions in consolidated terrorism damages cases Waldman v. PLO (15-3135-cv) and Sokolow v. PLO, reducing the prior $218.5 million judgment. The court addressed damages for terrorist attacks in Jerusalem and Tel Aviv. The decision affects how civil damages are calculated in terrorism-related cases under the Anti-Terrorism Act.
Ramsay v. Bondi - Immigration Removal Proceedings
The Second Circuit granted John Marcus Ramsay's petition challenging the BIA's denial of his motion to reopen removal proceedings. The court found the BIA misread Ramsay's arguments regarding equitable tolling and due diligence in filing his motion within thirty days of United States v. Minter. The case is remanded to the BIA for further consideration consistent with the opinion.
Petersen Energía v. Argentina - Securities Expropriation
The Second Circuit decided consolidated cases involving Petersen Energía and Eton Park Capital Management as minority shareholders of YPF S.A. against Argentina and YPF S.A. The court affirmed in part and reversed in part the SDNY judgment stemming from Argentina's expropriation of oil company shares, held that breach of contract damages claims are not cognizable under Argentine law, and remanded for further proceedings. The district court had entered judgment awarding $16.1 billion in damages.
Rivera-Perez v. Stover habeas corpus, Second Circuit, March 26
Rivera-Perez v. Stover habeas corpus, Second Circuit, March 26
United States v. Maurice Lawrence - Criminal Appeal
The Sixth Circuit affirmed Maurice Lawrence's conviction on federal gun and drug charges, rejecting his appeal challenging the validity of a search warrant for his motel room at the Kings Inn in Nashville, Tennessee. The three-judge panel upheld the district court's denial of Lawrence's motion to suppress evidence, finding the warrant application established probable cause based on controlled buys and informant tips. Lawrence's conviction is now final.
United States v. LeSean Roberts - Supervised Release Termination
The Sixth Circuit vacated the District Court for the Northern District of Ohio's denial of LeSean Roberts's motion to terminate supervised release. The appellate court found the district court failed to clearly demonstrate consideration of the required 18 U.S.C. § 3553(a) factors in denying the motion. The case (No. 25-3789) has been remanded for further proceedings.
United States v. Tony Wilkinson - Felon Firearm Possession
The Sixth Circuit affirmed Tony Wilkinson's conviction for possessing a firearm as a felon in violation of 18 U.S.C. § 922(g)(1). Wilkinson had pleaded guilty to the single count in the Eastern District of Kentucky. The appellate court found no reversible error in the proceedings. The decision is non-precedential.
United States v. Michael Williams - Supervised Release Revocation
The Sixth Circuit affirmed the district court's revocation of Michael Williams's supervised release and consecutive sentences. Williams had violated supervised release conditions by distributing cocaine while on supervision following a prior federal drug trafficking conviction. The appellate court rejected Williams's claims that his within-Guidelines sentence for the supervised release violation was procedurally unreasonable and that the district court inadequately explained its rationale for consecutive sentences.
Campbell v. Campbell - Military Retirement Pay Division in Divorce
The Maryland Court of Special Appeals affirmed a ruling granting Kelly Marie Harrigan Campbell 15.96% of her ex-husband's military retirement pay. The court held that for mixed active/reserve military service, courts should use point-based calculations to determine the marital property portion of retirement benefits. The case arose after the ex-husband retired approximately nine years post-divorce.
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