Elena Steiger Reich
Patterson Belknap Webb & Tyler LLP
Articles
Second Circuit Affirms Sentencing Enhancement for Altered Serial Number on a Gun, Despite Legible Serial Numbers On Other Parts of the Firearm
USA - May 26 2020 In United States v. St. Hilaire, 19-640 (May 21, 2020), the Second Circuit (Jacobs, Calabresi, Chin) affirmed a sentencing enhancement for possessing…
Second Circuit Concludes that Restitution Includes Losses from Wire Fraud Scheme that Occurred Outside the Limitations Period
USA - May 20 2020 In United States v. Parnell, 19-649-cr (May 19, 2020), the Second Circuit (Hall, Lohier, Park) affirmed a judgment ordering the defendant-appellant to…
Second Circuit Affirms Conviction for Drug Trafficking in Violation of MDLEA
USA - December 2 2019 On November 14, 2019, the Second Circuit (Newman, Pooler, Cote) issued a decision in United States v. Van Der End, affirming the conviction of a…
Second Circuit Grants Rehearing and Vacates Guilty Plea Following Supreme Court’s Decision in Rehaif v. United States
USA - November 25 2019 On November 13, 2019, the Second Circuit (Hall, Lynch, Gardephe) issued a decision in United States v. Balde, vacating the defendant's guilty plea for…
Government Need Only Show that it Employed Procedures Reasonably Calculated to Provide Notice to a Prisoner of Civil Forfeiture Action
USA - November 12 2019 On November 7, 2019, the Second Circuit (Calabresi, Livingston, Lohier) issued a per curiam decision in United States v. Brome, holding that the…
