ADHELASKIN for Systemic Sclerosis Skin Assessment (NCT07543679)

A clinical trial (NCT07543679) evaluating ADHELASKIN technology by Tactinnov and École Centrale de Lyon for objective assessment of skin damage in patients with systemic sclerosis has been registered on ClinicalTrials.gov. The trial addresses limitations of the modified Rodnan skin score (mRSS), including inter- and intra-observer variability and limited sensitivity to subtle changes. ADHELASKIN uses an indentation method with ruby-based measurement to quantify rigidity, firmness, and elasticity of skin with improved accuracy. The study will classify patients as diffuse cutaneous or limited cutaneous SSc based on skin fibrosis extent.

Teen Vulnerability to Irritability: Brain and Estrogen Changes (NCT07544966)

NIH registered a Phase 4 clinical trial (NCT07544966) titled "Teen Vulnerability to Irritability: Brain and Estrogen Changes," enrolling 50 female adolescents ages 12-16 at risk of suicide. The randomized, placebo-controlled, cross-over study will test the impact of estradiol (E2) and progesterone (P4) stabilization via continuous combined oral contraceptive (Kurvelo) versus placebo on brain networks associated with irritability over two 8-week treatment arms. Each participant undergoes daily hormone sampling, daily symptom ratings, and neuroimaging sessions across conditions.

MBP vs No MBP in Laparoscopic Right Hemicolectomy

A randomized controlled trial (NCT07546565) registered at University Medical Center Ho Chi Minh City will compare mechanical bowel preparation (MBP) versus no MBP in patients undergoing laparoscopic right hemicolectomy with intracorporeal anastomosis for colon cancer. The trial will enroll eligible patients randomly assigned to either group and measure surgical site infection rates within 30 days as the primary outcome, alongside secondary outcomes including anastomotic leakage, postoperative ileus, operative time, and length of hospital stay. Findings aim to clarify whether MBP reduces postoperative infections in this specific surgical context.

Nursing Intervention Based on Stress Adaptation Theory for Patients Undergoing Diabetic Retinal Laser Surgery

A randomized controlled study registered on ClinicalTrials.gov under NCT07544381 evaluates whether a nursing intervention based on stress adaptation theory improves pain trajectory and procedural tolerance in patients undergoing ambulatory retinal laser photocoagulation for diabetic retinal disease. Patients were randomized to receive routine peri-procedural care or routine care plus a structured nursing intervention including a brief treatment pause, guided slow breathing, anticipatory communication, real-time reassurance, and post-procedure observation. Outcomes measured include pain intensity, physiologic responses, procedural cooperation, and adverse events.

Serum Electrolytes and Contrast-Induced Nephropathy in Acute Ischemic Stroke Patients Undergoing Endovascular Treatment

A new observational cohort study (NCT07546448) has been registered on ClinicalTrials.gov, examining the relationship between serum electrolyte levels and contrast-induced acute kidney injury (CI-AKI) in patients with acute ischemic stroke undergoing endovascular therapy (EVT). The retrospective study will analyze patients treated between 2018 and 2026, classifying participants based on the presence or absence of CI-AKI per serum creatinine changes, with secondary objectives including 90-day mortality and dialysis dependency evaluation.

Phase 3 Megestrol Acetate Trial for T-DXd-Related Fatigue in Advanced Breast Cancer

ClinicalTrials.gov registered a new Phase 3 interventional study (NCT07543536) on April 22, 2026, evaluating whether Megestrol Acetate administered at the initiation of Trastuzumab Deruxtecan (T-DXd) treatment can prevent or alleviate T-DXd-related fatigue in patients with advanced or metastatic HER2+, HER2-low, or HER2-ultralow breast cancer. The trial will compare Megestrol Acetate plus T-DXd against placebo plus T-DXd. The study is sponsored by an unnamed party and is classified as Phase 3.

Prospective Study of Minimally Invasive Hernia Repair, 5-Year Follow-up

NIH's ClinicalTrials.gov registered an observational study (NCT07544238) on April 22, 2026, examining clinical outcomes of minimally invasive (laparoscopic and robotic) hernia repair over a 5-year follow-up period. Adult patients scheduled for elective abdominal wall hernia repair (not inguinal) will be tracked at 2-3 months, 1 year, 3 years, and 5 years post-surgery, with CT imaging at 1 year and as needed for complication suspicion. The study will analyze recurrence rates, intra- and postoperative complications, quality of life, aesthetic outcomes, and pain using standard treatment protocols.

Diaphragmatic Breathing vs Incentive Spirometry for GERD - NCT07544433

Clinical trial NCT07544433 registered on ClinicalTrials.gov evaluates two non-invasive respiratory interventions—diaphragmatic breathing exercise (DBE) and volume-oriented incentive spirometry (VIS)—against standard care in patients with gastroesophageal reflux disease (GERD). The 6-week randomized controlled trial will measure outcomes including GERD symptom scores (GERDQ), esophageal acid exposure time, lower esophageal sphincter pressure, and health-related quality of life (GERD-HRQL). Three groups of participants will undergo baseline and post-intervention assessments with daily symptom and adherence diaries.

Governor Braun Public Schedule Week of April 20

Indiana Governor Mike Braun's public schedule for April 20–22, 2026 includes three events: ceremonial signing of HEA 1200 on Monday, April 20 at 3:30 PM ET at the Indiana Statehouse, ceremonial signing of SEA 285 on Tuesday, April 21 at 10:00 AM ET, and opening remarks at the FDIC conference on Wednesday, April 22 at 8:30 AM ET at the Indiana Convention Center. Media RSVPs are required for each event.

Forestry Commission Q1 2026 Prompt Payment Performance Data

The Forestry Commission published its Q1 2026 prompt payment performance data covering January to March 2026, showing the percentage of invoices paid within 5 days and within 30 days of receipt for Forestry Commission, Forestry England, and Forest Research. The transparency data was published on 22 April 2026 on GOV.UK and applies to England.

Alaska Workers' Compensation Board Meeting May 14-15, 2026

The Alaska Workers' Compensation Board will hold a full Board meeting on May 14-15, 2026, beginning at 9:00 a.m., in Hearing Room 208 of the Department of Labor Building at 3301 Eagle Street, Anchorage, Alaska, with virtual participation available via Zoom. The meeting will cover regular business of the Board and Division, including discussion of the Alaska Workers' Compensation Act and potential regulation changes. Public comment is scheduled for 10:15-11:15 a.m. on May 14, 2026. Written comments must be received by 5:00 p.m. on May 8, 2026.

Medical Services Review Committee Meetings May 28-Aug 7, 2026

The Alaska Workers' Compensation Division's Medical Services Review Committee has scheduled four public meetings on May 28, June 26, July 17, and August 7, 2026, each from 9:00 a.m. to 5:00 p.m., with public comment periods held from 10:15 a.m. to 11:15 a.m. at each meeting. The August 7 meeting will be held in person at 3301 Eagle St. Rm 208, Anchorage, AK 99503, while the other three meetings will be conducted via Zoom only. The committee will develop recommendations relating to the Alaska Medical Fee Schedule to be adopted under 8 AAC 45.083 for calendar year 2027.

House Republicans Unveil SECURE Data Act and GUARD Financial Data Act for National Bank Data Privacy Standards

House Republicans on April 22, 2026, introduced two bills to establish national data privacy standards for the financial sector. The SECURE Data Act would create privacy and data security standards enforced by the FTC and state attorneys general, while exempting financial institutions covered by GLBA. The related GUARD Financial Data Act would modernize the 1999 Gramm-Leach-Bliley Act to account for technological advances and would preempt state laws in the financial activity space. The GUARD Act would require affirmative opt-in consent before disclosing sensitive personal information and allow customers to request access to and deletion of their financial data.

Rep. David Scott Dead at 80, Congressman

Former House Agriculture Committee Chairman David Scott (D-Ga.) died at age 80 on April 22, 2026. Scott was first elected to Congress in 2002 and became the first Black chairman of the House Agriculture Committee in 2020. He was also a member of the House Financial Services Committee. House Financial Services Committee Ranking Member Maxine Waters (D-Calif.) praised his commitment to public service and economic opportunity. The document contains no regulatory actions, compliance obligations, or legislative developments.

DOJ Extends State, Local Government Digital Accessibility Deadlines by One Year

The Department of Justice extended compliance deadlines for the 2024 ADA Title II digital accessibility rule, which requires state and local governments to make web content and mobile apps accessible under WCAG 2.1 Level AA. Governments with populations over 50,000 now have until April 26, 2026 to comply, while governments with smaller populations or special districts have until April 26, 2028. The article notes that while Title III regulations for private businesses such as banks are not yet in force, similar requirements may follow.

Bankers Seek to Communicate MDI Value at D.C. Summit

The American Bankers Association and the National Bankers Association co-hosted the fifth annual MDI Partnership Summit in Washington, D.C., bringing together representatives from minority depository institutions for a two-day event featuring congressional meetings and educational sessions on real-time payments and stablecoins. NBA President and CEO Nicole Elam emphasized MDIs' role as 'engines of economic opportunity' in underserved communities, while ABA Chief Policy Officer Naomi Camper highlighted the need for ongoing engagement with policymakers.

Senators Press Bessent on Proposed CDFI Fund Cuts

Treasury Secretary Scott Bessent appeared before the Senate Appropriations Committee on April 22, 2026 to defend the White House's proposed FY2027 budget, which seeks to cut the Community Development Financial Institutions Fund by $204.5 million, or roughly two-thirds of its current budget. A bipartisan group of 43 senators had previously urged colleagues to set aside at least $324 million for the CDFI Fund and release funds in a timely manner. Bessent stated the remaining awards would be redirected to rural communities and said the program needed to be free of waste, fraud, and abuse.

Rob Nichols, Paul Benda discuss ABA fraud strategy

The ABA Banking Journal Podcast released a crossover episode with the ABA Fraudcast on April 22, 2026, featuring ABA President and CEO Rob Nichols and ABA EVP Paul Benda discussing the ABA's ecosystem approach to fraud prevention. The episode covers participation in the UN/Interpol Global Fraud Summit, growing bipartisan co-sponsorship of the SCAM Act, collaboration with the International Banking Federation on global anti-fraud practices, and increasing state-level legislative activity on fraud issues.

Women Remain Underrepresented in Wealth Management Despite Growing Pipeline

FINTRX research published in ABA Banking Journal reports that while 37.6% of wealth management professionals aged 20-30 are women, only about 20% of producing advisors firm-wide are women, illustrating persistent underrepresentation in revenue-generating roles. Women comprise 26.5% of producing advisors with fewer than five years of tenure and remain underrepresented in CEO and CIO positions, even as they show stronger representation in COO and CFO roles. The findings, covering over 500,000 registered representatives across independent RIAs, wirehouses, and broker-dealers, suggest that effective firm support for advancement into revenue-generating and executive roles will determine the pace of gender parity over the next decade.

HUD Adopts FICO 10T, VantageScore 4.0 for Mortgages

HUD announced adoption of FICO 10T and VantageScore 4.0 for FHA loans, calling it an important milestone in credit score modernization. FHFA simultaneously launched a pilot program allowing exclusive use of VantageScore 4.0 for loans delivered to Fannie Mae and Freddie Mac, with future integration of FICO Score 10T. Fannie Mae began limited rollout to approved lenders immediately, while publication of historical credit score data for both models is scheduled for summer 2026.

Statement of Charges Against Zenith Asset Tech in Cryptocurrency Fraud

The Washington State Department of Financial Institutions Division of Securities entered a Statement of Charges (S-24-3882-25-SC01) against Zenith Asset Tech Foundation, Cirkor Inc., and 19 additional respondents on April 22, 2026. Between 2024 and 2025, the respondents allegedly defrauded at least 38 investors—including 3 Washington residents—out of nearly $9.9 million through cryptocurrency scams involving fake investment education foundations, fake trading platforms, fake AI-generated trading signals, and unregistered money transmitters. The respondents sold fake securities token offerings and were not registered to sell investments, allegedly failing to disclose material information about their AI bot system and their own registration status. Remedies sought include cease and desist orders and fines.

2026 California Rulemaking Law APA Book Available for $8

The California Office of Administrative Law announces that the 2026 California Rulemaking Law under the Administrative Procedure Act book is now available for purchase at $8.00 per copy. The book contains primary statutes and regulations governing rulemaking under the California APA, along with annotations, related statutes, and a comprehensive index. Books can be picked up at OAL's Sacramento office or mailed via USPS; payment must be by check or money order only, with delivery taking 7 to 10 working days after receipt of payment.

Governor Braun Releases First Annual Direct-to-Employer Healthcare Review

The Indiana Department of Health Consumer Services and Healthcare Regulation Commission released its inaugural Direct-to-Employer Healthcare Arrangement Plan Review for calendar year 2025 at the direction of Governor Braun. The report found that all five participating health systems—Ascension St. Vincent, Community Health Network, Franciscan Health, Indiana University Health, and Parkview Health Network—met the statutory benchmark requiring employer-direct plans to remain at or below 260% of Medicare rates. The review provides employers new visibility into hospital pricing and highlights direct-to-employer contracting as a tool for managing healthcare costs.

14 Organizations Join USP Convention Including African Medicines Agency, Egyptian Drug Authority

USP added 14 organizations to its Convention as of Spring 2026, including the African Medicines Agency, Egyptian Drug Authority, Indonesian Food and Drug Authority, and Rwandan FDA, among others. The Convention now comprises over 450 member organizations from more than 50 countries representing science, manufacturing, regulatory, patient advocacy, government, and academia. Convention Members provide input and elect USP's Board of Trustees and Council of Experts, supporting USP's mission to protect and promote health by advancing quality across the lifecycle of medicines worldwide.

Wound Dressing Patent US12605285B2, HIDRAMED SOLUTIONS

The USPTO granted Patent US12605285B2 to HIDRAMED SOLUTIONS LTD on April 21, 2026, covering a wound dressing device that includes a retaining device for encompassing a portion of the body, a dressing, and a fastening element configured external to the retaining device. The patent application was filed on July 20, 2018, under application number 16637989, and contains 21 claims. The invention also relates to a method of applying the device and a combined dressing and fastening element.

US12605286B2 Infant Umbilical Cord Stump Protector

The USPTO granted Patent US12605286B2 to ASO LLC for an infant umbilical cord stump protector comprising a pad positionable proximal to the umbilical cord stump and a fluid-impermeable cover with adhesive, deformable, and peripheral regions that form a protective dome shape. The patent, filed on January 31, 2022 under Application No. 17588842, contains 51 claims and 18 CPC classifications in the A61F medical device category. Assignees and inventors seeking to commercialize similar neonatal care products should conduct freedom-to-operate analyses to avoid potential infringement of this issued patent.

Road Traffic (Singapore Yachting Festival 2026 — Exemption) Order 2026

The Road Traffic (Singapore Yachting Festival 2026 — Exemption) Order 2026 exempts designated chauffeured private hire cars operated by RedAce Limo (UEN 53395806K) from sections 101, 106 and 107 of the Road Traffic Act 1961 and Parts II and VI of the Road Traffic (Public Service Vehicles) Rules for the period 22–27 April 2026. To qualify, vehicles must display a Registrar-issued label, be used only by the exempt sole proprietor or persons under their direction, and maintain valid insurance covering third-party death, bodily injury, and property damage while on any road.

Carr Warns Georgians of Price Gouging and Wildfire Scams

Georgia Attorney General Chris Carr warns Georgians of price gouging and scams following Governor Brian Kemp's State of Emergency declaration for 91 counties due to South Georgia wildfires. The emergency declaration took effect April 22, 2026 and remains in place until 11:59 p.m. on Friday, May 22, 2026, invoking the Price Gouging Statute for goods and services necessary for preparation, response, and recovery activities. The Consumer Protection Division provides tips to help consumers avoid contractor fraud, charity fraud, and other deceptive practices related to the disaster.

Decreto 12.881/2026 Formaliza Reestruturação Regulatória da ANPD

Decreto 12.881/2026 e Resolução CD/ANPD nº 33 concretizam a transformação da Agência Nacional de Proteção de Dados em agência reguladora, concedendo-lhe as mesmas prerrogativas previstas na Lei nº 13.853/2019, incluindo receitas vinculadas e carreira própria de pessoal. A nova estrutura organiza-se em seis Superintendências — Executiva, Inovação Tecnológica, Regulação, Fiscalização, Relações Institucionais e Internacionais e Gestão Interna — além de uma unidade de Auditoria. Com aproximadamente 500 pessoas, a ANPD prevê a criação de 200 novos cargos por meio de concurso público para a carreira de Especialista em Regulação de Dados Pessoais.

ANPD Participates in Roundtable on Ethical AI Guide Public Consultation

ANPD participated in a roundtable discussion on April 10 at the Palacio da Justiça to contribute to the public consultation process for Brazil's Ethical AI Use Guide (Guia de Uso Ético de Inteligência Artificial). Director Lorena Giuberti Coutinho represented ANPD at the panel on 'Artificial Intelligence and Gender: Contemporary Challenges and Paths to Algorithmic Justice.' The guide, being developed by multiple federal entities through the Secretaria Nacional de Direitos Digitais (SEDIGI/MJSP), aims to inform the general public about AI functioning, uses, limitations, risks, and rights and duties in technology interactions. The document specifically addresses deepfake risks and recommendation algorithm effects on mental health, noting women and girls as the most affected demographic group.

ANPD Participates in First Datified Public Services Seminar in São Paulo

Brazil's ANPD participated in the first edition of the Datified Public Services Seminar held on April 16 in São Paulo, organized by CGI.br's Working Group on Datified Public Services. Director Lorena Giuberti spoke at the third panel and closed the event, emphasizing that Brazil's LGPD provides the regulatory framework for secure and protected data processing in the public sector. The seminar brought together experts, public managers, civil society representatives, universities, and the business sector to discuss the relationship between data processing in public services and its societal impact.

Georgia Power Company Fuel Cost Recovery FCR-27 Hearing

The Georgia Public Service Commission has scheduled a hearing for Docket #56765 concerning Georgia Power Company's Fuel Cost Recovery (FCR-27) on May 6, 2026 at 9:30 am. This proceeding will examine the utility's fuel cost recovery charges, which determine how much customers pay for fuel expenses embedded in electricity rates. The hearing is listed as part of the Commission's calendar for review of Georgia Power's annual fuel cost adjustment filing.

USPS Files 12 Priority Mail Express, Priority Mail, Ground Advantage Contracts With PRC

The United States Postal Service filed 12 requests with the Postal Regulatory Commission between April 13–17, 2026, to add domestic shipping services contracts to the Mail Classification Schedule's Competitive Products List. The filings cover Priority Mail Express, Priority Mail, and USPS Ground Advantage products under negotiated service agreement categories PM-GA 957–966, PME-PM-GA 1500, and PM 954, assigned MC2026-202 through MC2026-216 and K2026-201 through K2026-214 docket numbers. Documents are available at www.prc.gov.

Rural Development Loan Servicing Information Collection Revision, OMB 0570-0015

The Rural Business-Cooperative Service (RBCS) is requesting public comments on a revision to a currently approved information collection (OMB No. 0570-0015) supporting Rural Development Loan Servicing for the Intermediary Relending Program. The collection covers loan servicing and liquidating activities under Subpart R of 7 CFR part 1951, involving both the IRP and Rural Microentrepreneur Assistance Program. RBCS estimates 500 respondents with 4 responses each, totaling 8,000 annual burden hours at 4 hours per response. Comments must be received by June 22, 2026, after which the collection will be submitted to OMB for approval.

Rural Development Loan Servicing Comment Period, June 22

This Regulations.gov form page enables individuals and organizations to submit public comments on Rural Development Loan Servicing regulations during the open comment period. The form is provided by the Rural Business-Cooperative Service (RBS), a USDA agency, and facilitates stakeholder participation in the federal regulatory process through the official government portal. Commenters may identify as an Individual, Organization, or Anonymous, and may attach supporting files up to 10MB in various formats. Affected parties seeking to provide feedback on Rural Development loan servicing policies should use this form to submit comments before the June 22 deadline. Agricultural firms, rural developers, lenders, and community organizations that participate in or are affected by USDA Rural Development loan programs may find this opportunity relevant to their operations. Submitted comments become part of the official public docket and may be publicly disclosed on Regulations.gov.

Paul Atkins, 32nd Annual International Institute for Securities Market Growth and Development Opening Remarks

SEC Chairman Paul S. Atkins delivered opening remarks at the 32nd Annual International Institute for Securities Market Growth and Development on April 22, 2026, marking 35 years since the inaugural Institute. The speech addressed the importance of international regulatory cooperation, highlighted the IOSCO Multilateral Memorandum of Understanding (MMOU) that has facilitated cross-border enforcement information exchange among over 130 regulators since 2002, and previewed discussions on capital market growth, investor protection, digital assets, and AI in finance. The event welcomed nearly 180 delegates from 54 jurisdictions.

Fuel Surcharge Guidance and Multiple Regulatory Updates from Commerce Commission NZ

The Commerce Commission NZ published a collection of regulatory updates on 22 April 2026, including guidance on fuel surcharges, merger review statements, infrastructure approvals, and enforcement actions. The High Court imposed a $2.482 million penalty on Co-operative Bank for breaching the Credit Contracts and Consumer Finance Act 2003. The Commission proposed approving Transpower's $1.1386 billion capex allowance for Cook Strait cable replacement and approved Wellington Electricity's substation upgrade for central Wellington power supply protection. Multiple merger reviews remain ongoing.

Competition Matters Conference 2026, 14th May, Auckland

The Commerce Commission NZ has announced its 2026 conference, Competition Matters, scheduled for Thursday 14 May at the New Zealand International Conference Centre in Tāmaki Makaurau, Auckland. The event will feature speakers and panellists from government, the OECD, and the business community discussing competition and consumer welfare issues. Registration is open via competitionmatters.nz/register. This is a conference announcement with no new regulatory obligations.

Subscribe to Media Releases, Newsletters, and Industry Updates

The Commerce Commission NZ invites readers to subscribe to its media releases, monthly Competition Matters newsletter, and industry-specific updates via email. Social media links to Facebook, LinkedIn, and YouTube are provided. Previous issues of the Competition Matters newsletter are archived from July 2025 through March 2026. No compliance obligations or deadlines are created by this page.

United States v. Brown - Supervised Release Monitoring Condition Affirmed

The Second Circuit affirmed Mark Richard Brown's conviction 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 was sentenced to 46 months' imprisonment and 3 years' supervised release, with forfeiture of $136,672.75. On appeal, Brown challenged three special conditions of supervised release: installation of monitoring software on all internet-accessible devices, unannounced device examinations by probation officers, and monitoring restrictions on work devices. The court upheld all conditions, finding they were reasonable given the nature of the offense and defendant's history, including a prior state conviction for a similar scheme.

Powell v. Ocwen Financial Corp. — ERISA Plan Assets and RMBS Trust Certificates

The Second Circuit partially affirmed and partially vacated the Southern District of New York's summary judgment in Powell v. Ocwen Financial Corp., a case brought by trustees of an ERISA-regulated pension fund against mortgage servicers for alleged breach of fiduciary duty regarding residential mortgage-backed securities investments. The court held that mortgages underlying RMBS notes issued under indenture agreements lack substantial equity features and therefore are not plan assets under the DOL's plan-asset regulation (29 C.F.R. § 2510.3-101). However, the court held that mortgages underlying RMBS trust certificates do represent equity interests and therefore qualify as plan assets under ERISA's look-through exception. The case was remanded for further proceedings on the certificate-based investments.

United States v. Manuel Zumba Mejia — Illegal Reentry Collateral Challenge

The Second Circuit reversed a Southern District of New York order granting Manuel Zumba Mejia's motion to dismiss an aggravated illegal reentry charge. The appellate court held that § 1326(d)'s three requirements are mandatory and that courts may not excuse a defendant's failure to satisfy any of them, expressly abrogating the Circuit's prior rule in United States v. Sosa. Mejia is barred from collaterally challenging his underlying removal order because he failed to exhaust administrative remedies. The case is remanded for further proceedings consistent with the opinion.

USA v. Ullah - Terrorism Conviction Affirmed in Part, Reversed in Part

The Second Circuit affirmed most convictions for Kayed Ullah's December 11, 2017 Manhattan subway bomb attack, reversing only Count One (material support to foreign terrorist organization) because the evidence was insufficient to prove he provided or attempted to provide material support as required under 18 U.S.C. § 2339B. The court affirmed Count Five (terrorist attack on mass transportation under 18 U.S.C. § 1992(a)(2)) and Count Six (using a destructive device during a crime of violence under 18 U.S.C. § 924(c)), rejecting his challenges to the statutory interpretation and jury instructions. The court also held that the completed offense under 18 U.S.C. § 2332f(a)(1) constitutes a crime of violence, and affirmed his sentence of multiple life terms.

Campbell v. Broome County - Fourth and Fourteenth Amendment § 1983 Claims Affirmed in Part

The Second Circuit affirmed the District Court's sua sponte dismissal under 28 U.S.C. § 1915(e) of plaintiff pro se David John Campbell's amended complaint alleging Fourth and Fourteenth Amendment constitutional violations against Broome County and City of Binghamton officials, finding the complaint factually frivolous and lacking allegations of municipal policy or personal involvement of certain defendants. The appellate court vacated and remanded solely the claim against Officer Nicholas Mushalla for allegedly unreasonably seizing firearms and other items from Campbell's home, which was not subject to the companion Binghamton I dismissal.

Goklu Bitcoin Money Laundering Conviction Affirmed

The Second Circuit affirmed Mustafa Goklu's conviction for money laundering and operating an unlicensed money transmitting business under 18 U.S.C. §§ 1956 and 1960, based on bitcoin-for-cash exchanges with undercover DEA agents. The court rejected challenges to jury empanelment, evidentiary sufficiency, and jury instructions, holding that exchanging bitcoin for cash constitutes 'money transmitting' under federal law. Goklu's sentencing challenges were dismissed as moot since he had finished serving his term of imprisonment.

Schneiderman v. American Chemical Society — Diversity Jurisdiction Affirmed

The Second Circuit affirmed dismissal of a disability discrimination suit against the American Chemical Society, holding that 28 U.S.C. § 1332(c)(1) requires state incorporation to establish corporate citizenship for diversity jurisdiction purposes. Because ACS is a federally chartered corporation not incorporated by any State, it lacks a State of citizenship under the statute, and diversity jurisdiction was not established. Judge Menashi dissented. The ruling clarifies that federally chartered corporations cannot be sued in federal court based solely on their principal place of business under § 1332(c)(1).

Vidal v. Venettozzi - Prison Disciplinary SHU Segregation Due Process

The Second Circuit vacated the Southern District of New York's grant of summary judgment to New York Department of Corrections and Community Supervision (DOCCS) officials, holding that 270 days of disciplinary segregation in the special housing unit (SHU) constitutes an atypical and significant hardship based on duration alone, triggering 14th Amendment procedural due process protections. Plaintiff-Appellant Joseph Vidal served at least 180 days of the 270-day sentence. The court found that Vidal was denied basic procedural protections at his disciplinary hearing, including the opportunity to call witnesses and present documentary evidence. The judgment is remanded for further proceedings consistent with this opinion.

Kwok v. Despins - Alter Ego Finding Affirmed, Yacht Included in Bankruptcy Estate

The Second Circuit affirmed the District of Connecticut's judgment holding that HK International Funds Investments (USA) Limited, LLC was the alter ego of debtor Ho Wan Kwok, meaning its assets—including the approximately $37 million Lady May yacht—belonged to the bankruptcy estate. The court held that the Chapter 11 trustee has standing to assert alter ego claims on behalf of creditors. The appellants, Mei Guo and HK, challenged both standing and the alter ego finding, but the Second Circuit rejected both arguments, emphasizing evidence of asset concealment through shell entities.

United States v. Barrett - Firearms Conviction Vacated, Remanded for Resentencing

The Second Circuit withdraws Part III.A.2.c. of its prior opinion in Barrett III (102 F.4th 60), which had permitted separate sentences on both Count Six (§ 924(c)(1)(A)(i)) and Count Seven (§ 924(j)) of the underlying indictment. The Supreme Court held in Barrett v. United States, 146 S. Ct. 482 (2026), that Congress did not authorize convictions under both provisions for a single act. The Second Circuit vacates the prior judgment to the extent it ordered separate sentences on both counts and remands with instructions for the district court to vacate one of the convictions, giving due weight to the government's view. The court denies Barrett's request for reassignment to a different judge on remand.

Pence Murder-for-Hire Conviction Affirmed on Appeal

The Second Circuit affirmed Christopher Pence's conviction for using a facility of interstate commerce in connection with murder-for-hire under 18 U.S.C. § 1958(a), upholding the district court's denial of his motion to suppress statements made to FBI agents before Miranda warnings. The appellate court agreed that a reasonable person in Pence's circumstances would not have believed he was in custody when he confessed to the murder-for-hire scheme after approximately two hours of questioning in an FBI vehicle. This affirmance resolves the appeal without creating new compliance obligations, as the decision applies existing Miranda custody doctrine to the specific facts.