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United States v. Goklu — Bitcoin Money Laundering Conviction Affirmed

The Second Circuit affirmed Mustafa Goklu's conviction for money laundering and operating an unlicensed money transmitting business based on bitcoin-for-cash exchanges with a DEA undercover agent totaling approximately $130,000. The court rejected Goklu's challenge to jury empanelment, his sufficiency-of-evidence challenge on the unlicensed money transmitter charge, and his challenge to the jury instruction defining 'money transmitting' to include bitcoin-for-cash exchanges. The defendant's sentencing challenges were dismissed as moot because he had completed serving his term of imprisonment.

Schneiderman v. American Chemical Society - Diversity Jurisdiction Ruling

The Second Circuit affirmed the dismissal of plaintiff Arnold Schneiderman's disability discrimination lawsuit against the American Chemical Society for lack of subject matter jurisdiction. The court held that 28 U.S.C. § 1332(c)(1)'s principal-place-of-business provision does not independently establish corporate citizenship for diversity purposes—it applies only in conjunction with the state-of-incorporation provision. Because ACS is a federally chartered corporation not incorporated by any state, it is not a citizen of any state for diversity jurisdiction purposes. Judge Menashi dissented.