Rajat Gupta Loses Post-Conviction Appeal

Gupta v. United States, 2d Cir., Jan. 11, 2019 (per curiam) The Second Circuit affirmed Judge Rakoff’s denial of Rajat Gupta’s post-conviction motion under 28 U.S.C. § 2255. Gupta argued that the district court’s jury instructions regarding the “personal benefit” component of insider trading offenses was invalid under the Second Circuit’s later decision in United […]

Second Circuit determines that Connecticut robbery crimes, and all state “robbery” crimes, qualify as ACCA predicates

United States v. Shabazz, 2d Cir. Jan. 2, 2019 (Leval, C.J.) In an extraordinary opinion that was nominally about a particular state robbery statute, the Second Circuit indicated that any robbery crime under the law of any state will qualify as a “violent felony” under the Armed Career Criminal Act (“ACCA”) “force clause,” 18 U.S.C. […]