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Vidal v. Venettozzi - Due Process Rights in Prison Disciplinary Segregation

The Second Circuit vacated a Southern District of New York summary judgment in favor of DOCCS officials, holding that Joseph Vidal's 180-270 days of disciplinary segregation in the Special Housing Unit constituted an atypical and significant hardship triggering Fourteenth Amendment procedural due process protections. The court remanded for further proceedings consistent with its opinion.

United States v. Barrett: Second Circuit Remands for Resentencing After Supreme Court Clarifies Dual 18 U.S.C. § 924(c) Convictions

The Second Circuit vacated in part its prior judgment and remanded Dwayne Barrett's case to the Southern District of New York for resentencing consistent with the Supreme Court's decision in Barrett v. United States (2026). The Supreme Court clarified that Congress has not authorized convictions under both 18 U.S.C. §§ 924(c)(1)(A)(i) and (j) for one act that violates both provisions. The appellate court withdrew Part III.A.2.c. of its prior opinion and directed the district court to vacate one of the two convictions and resentence accordingly. Barrett's request for reassignment to a different judge was denied.

Day Trader Patel Charged $5M Market Manipulation from Puerto Rico

The SEC filed charges against day trader Harsh V. Patel in federal court in the Southern District of New York for an alleged market manipulation scheme conducted from San Juan, Puerto Rico. The complaint alleges Patel manipulated stock prices on more than a thousand occasions across hundreds of stocks from May 2021 to January 2024, generating more than $5 million in ill-gotten gains through a layered trading scheme involving small lot market orders, non-bona fide limit orders, and cancellation of buy orders after selling at inflated prices. The SEC charged Patel with violating Section 17(a) of the Securities Act of 1933, Sections 9(a)(2) and 10(b) of the Securities Exchange Act of 1934, and Rule 10b-5, seeking permanent injunctions, a conduct-based injunction, disgorgement with prejudgment interest, and a civil penalty.

SEC Settles Insider Trading Action Against Rakesh Ahuja

The SEC filed a settled civil action against Rakesh Ahuja, a former employee of an investment advisory firm, for insider trading based on confidential clinical trial data obtained during employment. Ahuja traded on material nonpublic information on four occasions in connection with three publicly traded biopharmaceutical and biotechnology companies, generating approximately $65,000 in profits. Without admitting or denying the allegations, Ahuja consented to a permanent injunction, a two-year ban from the securities industry, and financial penalties totaling $143,097.51 including disgorgement, prejudgment interest, and a civil penalty.

United States v. Brown - Supervised Release Computer Monitoring Condition

The Second Circuit affirmed Mark Brown’s conviction and sentence for fourteen counts of making false, fictitious, or fraudulent claims under 18 U.S.C. § 287 and one count of theft of government funds under 18 U.S.C. § 641. Brown received 46 months’ imprisonment followed by three years of supervised release, plus $136,672.75 in forfeiture. On appeal, Brown challenged a special condition permitting probation officers to monitor all activity on internet-accessible devices and conduct unannounced device examinations without reasonable suspicion, arguing it was overbroad and constituted an impermissible occupational restriction. The Second Circuit rejected both arguments, holding that district courts have broad discretion to impose supervised release conditions and that monitoring work devices does not constitute an occupational restriction under U.S.S.G. § 5F1.5.

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.

Cruz v. Banks - Second Circuit Affirms IEP Classroom Placement Ruling

The Second Circuit affirmed the SDNY judgment in Cruz v. Banks, rejecting an appeal challenging the NYC DOE's placement of student O.F. in a 12:1:4 classroom under IDEA. The NY Court of Appeals had clarified that 8 N.Y.C.R.R. § 200.6(h)(4) provides alternative placements rather than cumulative stacking requirements for students with disabilities. The court deferred to the SRO's educational judgment that the 12:1:4 placement was appropriate.

Tesla v Pelinkovic: Crypto Partnership Claim Dismissed for Failure to Plead Joint Venture Elements

The Second Circuit affirmed dismissal of Matthew Tesla's lawsuit against Brazilian Jiu-Jitsu instructor Doug Pelinkovic, rejecting Tesla's claim that the two formed a crypto investment partnership or joint venture. The federal court in the Southern District of New York found that Tesla failed to plead essential elements of partnership under New York law, including failure to contribute capital, lack of commingled property, no evidence of joint management or control, and an insufficient "backstop losses" offer. The court held that Tesla's contributions amounted to "an act of friendship, not partnership."