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Not So Strange: Circuit Affirms Sentencing Enhancement Where Defendant Fabricated Letters Submitted to Sentencing Court

In a recent opinion, the Second Circuit upheld a 57-month sentence that applied a two-level sentencing enhancement for obstruction of justice and rejected a request for a sentencing reduction for acceptance of responsibility...more

Circuit Affirms Conviction, Finding No Coerced Confession When Made in Presence of Attorney

Recently, the Second Circuit upheld the conviction and 40-year sentence of a Hezbollah operative.  In United States v. Kourani, No. 19-cr-4292 (Cabranes, Kearse, Pooler), the Court rejected the defendant’s various arguments...more

Circuit Remands After Potential Brady Violation

Recently, the Second Circuit remanded a consolidated appeal of three cases to the district court to consider whether the government violated Brady such that new trials should be granted.  In United States v. Stillwell, Nos....more

Failure to Challenge Eyewitness ID Evidence is Ineffective, Circuit Finds

On April 15, 2020, the Second Circuit (Rakoff, by designation, Sack, Hall) vacated the conviction of Ralph Nolan, who was convicted of conspiracy and attempt to commit a Hobbs Act robbery, on ineffective assistance of counsel...more

New York Court of Appeals Delivers News to Employers in Postmates Case: Couriers are Employees, Not Independent Contractors

The New York State Court of Appeals recently issued a decision in a closely-watched case that helps to clarify the landscape regarding independent contractors and employees in the gig economy. In In the Matter of the Claim...more

Documentation Requirements for COVID-19-Related Leave

As employees begin requesting leave under the recently-passed New York legislation providing COVID-19-related sick leave (the “New York Act”) and the Families First Coronavirus Response Act (the “FFCRA”), employers should...more

CARES Act: Unemployment Relief

On March 27, 2020, the President signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” or the “Act”), a $2 trillion COVID-19 relief and stimulus package that offers extraordinary financial...more

COVID-19 Reporting and Privacy Issues

The COVID-19 pandemic has raised new and important questions for employers, including those about balancing employee privacy with the need to warn employees about possible exposure to the novel coronavirus. Here are some...more

Circuit Reinstates Securities Fraud and Wire Fraud Conspiracy Conviction In Case Of RMBS Trader

On Friday, the Second Circuit (Livingston, Carney, Sullivan) reinstated the conviction of a former Nomura Securities International, Inc. (“Nomura”) bond trader, Michael Gramins, in United States v. Gramins, No. 18-2007-cr,...more

Circuit Affirms Sentence Enhancement for Child Porn but Remands as to Conditions of Supervised Release

The Second Circuit (Walker, Cabranes, Sack) issued a per curiam decision in United States v. Bleau, 18-cr-1574 affirming a sentence based on a conviction for receiving and possessing child pornography, but remanding for...more

Circuit Upholds Forfeiture Based On Appreciation

The Second Circuit (Pooler, Jacobs, Wesley) issued an opinion holding that a criminal forfeiture order in an insider trading case is not limited to the amount of funds acquired through illegal activity but may extend to the...more

Second Circuit Remands for Suppression Hearing

Last week, the Second Circuit (Cabranes, Pooler, Droney) issued a non-precedential summary order remanding a case to the district court for an evidentiary hearing on a motion to suppress. ...more

Second Circuit Vacates Life Sentence, Citing Failure to Apply the Categorical Approach

The Second Circuit (Leval, Lynch, Droney) issued a decision reversing a mandatory life sentence, finding plain error because the district court failed to apply the categorical approach when considering whether the...more

Circuit Upholds Rajaratnam SEC Civil Penalty

In an appeal arising in the aftermath of Raj Rajaratnam’s criminal conviction for insider trading, the Second Circuit (Lynch, Raggi, Droney) issued an opinion upholding an almost $93 million Securities and Exchange Commission...more

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