Feb 27 2026
3rd Cir. 26-1120 Panel Decision

United States v. Hafner

The Third Circuit affirmed the denial of Eric Hafner's motion to withdraw his guilty plea, finding he failed to prove ineffective assistance of counsel or a fair and just reason for withdrawal. The court also upheld a 240-month sentence that exceeded the advisory Guidelines range, ruling that the District Court properly applied enhancements for threatening conduct and obstruction.

Feb 27 2026
3rd Cir. 23-3258 Panel Decision

Nos. 23-3258 & 26-1120 UNITED STATES OF AMERICA v. ERIC HAFNER

The Third Circuit affirmed the denial of Eric Hafner's motion to withdraw his guilty plea, ruling that he failed to prove ineffective assistance of counsel or a fair and just reason for withdrawal. The court also upheld a 240-month sentence, finding no error in the application of sentencing enhancements for threatening conduct and obstruction of justice.

Feb 25 2026
U.S. Sup. Ct. 24-557 8-0

Villarreal v. Texas

The Supreme Court held that a trial court may prohibit a testifying defendant from discussing his own testimony with counsel during an overnight recess without violating the Sixth Amendment. The Court clarified that while defendants retain rights to consult on tactics and sentencing, they have no constitutional entitlement to confer about ongoing testimony itself.

Jan 21 2026
1st Cir. 25-1126 Panel Decision

UNITED STATES v. STAVROS PAPANTONIADIS

The First Circuit affirmed the convictions of a Massachusetts pizzeria owner for forced labor, ruling that a pattern of physical abuse and threats of deportation against undocumented workers satisfied the statutory elements of coercion. The court also upheld the defendant's 102-month sentence, rejecting challenges to evidentiary rulings and sentencing enhancements.

Dec 2 2025
9th Cir. 2:22-cr-00482- Published

UNITED STATES OF AMERICA v. JERRY NEHL BOYLAN

The Ninth Circuit affirmed Jerry Boylan's conviction for seaman's manslaughter, clarifying that the statute requires only simple negligence rather than gross negligence. The court further held that any potential error in the jury instructions regarding the term 'misconduct' was harmless given the overwhelming evidence of guilt.

Dec 2 2025
9th Cir. 2:22-cr-00482- Published

UNITED STATES OF AMERICA v. JERRY NEHL BOYLAN

The Ninth Circuit affirmed Jerry Boylan's conviction for seaman's manslaughter, clarifying that the statute requires only negligence rather than gross negligence. The court further held that any error in the jury instructions regarding the term 'misconduct' was harmless given the overwhelming evidence of guilt.

Nov 10 2025
11th Cir. 3:21-cv-00329-MCR-ZCB Published

Watson v. Kingdom of Saudi Arabia

The Eleventh Circuit affirmed the dismissal of most tort and contract claims against Saudi Arabia but reversed the dismissal of claims alleging gross negligence in hiring and vetting a terrorist trainee. The court held that the Kingdom's affirmative acts in sending Mohammed Al-Shamrani to the United States were sufficient to overcome sovereign immunity under the Justice Against Sponsors of Terrorism Act.

Jan 13 2025
2nd Cir. 22-2884 Panel Decision

Mallet v. New York State Department of Corrections and Community Supervision

The Second Circuit reversed the dismissal of an inmate's Eighth Amendment claim, holding that the statute of limitations did not begin to run until he reasonably suspected he had prostate cancer, not when he was released from prison. The court remanded the case for further proceedings on the claims against two prison doctors while dismissing the claims against a third provider and state officials.