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Courts Reinstates Embezzlement Charges Dismissed as Untimely, Holding that Dismissal was Based on a Premature Assessment of the...

In United States v. Sampson, decided August 6, 2018, the Court (Cabranes, Livingston, Carney, C.J.J.) reversed the district court’s dismissal of embezzlement charges levied against former New York State Senator John Sampson. ...more

Circuit Holds that Interstate Travel Element Confers Multiple Venues for Prosecution

In United States v. Holcombe, 16-1429-cr, the Second Circuit (Jacobs, Leval, Lohier) resolved three open issues involving a conviction for failing to register pursuant to the Sex Offender Registration and Notification Act...more

Circuit Clarifies Guidelines Provision Allowing Post-Conviction Reduction Of Drug Sentences

In United States v. Carosella, 17-896-cr, the Second Circuit clarified an open issue relating to Amendment 782 to the Sentencing Guidelines. Amendment 782 is sometimes called the “drugs minus two” amendment because it...more

Circuit Resolves Jurisdictional Questions In Context Of Section 853(n) Asset Forfeiture Proceeding

In a short opinion in United States v. Ohle, 16-601-cr, the Second Circuit (Leval, Calabresi, Cabranes) resolved two open questions about the application of Federal Rule of Appellate Procedure 4, both in the context of a...more

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