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Sentencing Sex Offenders

Patterson Belknap Webb & Tyler LLP

Second Circuit Sidesteps Supervised Release Challenges

In United States v. Birkedahl, 19-2304, the Second Circuit (Sullivan, Park, Nardini) rejected Defendant-Appellant Eric Birkedahl’s challenges to the conditions of his supervised release imposed subsequent to his conviction...more

Patterson Belknap Webb & Tyler LLP

As Second Circuit Affirms Conviction for Failure to Register as a Sex Offender, Judge Calabresi Questions “Non-Punitive” Nature of...

In a per curiam opinion, United States v. Diaz, the Second Circuit (Calabresi, Chin, and Carney) held that the Sex Offender Registration and Notification Act (“SORNA”), 18 U.S.C. § 2250(a), does not permit a defendant to...more

Patterson Belknap Webb & Tyler LLP

Second Circuit: In Truth, A Polygraph Test Supervised Release Condition Can’t Be Added After Sentencing

In United States v. Washington, the Second Circuit (Cabranes and Pooler Circuit Judges, and Oetken, J., by designation) examined a discrepancy between the terms of sentence that the District Court pronounced at the sentencing...more

Patterson Belknap Webb & Tyler LLP

In Summary Order, Second Circuit Finds Plain Error in Miscalculation of Defendant’s Supervised Release Guidelines Range

In United States v. Shaday, 16-529, the Second Circuit (Jacobs, Livingston, and Kaplan (sitting by designation)) vacated and remanded the supervised release portion of defendant Yova Kana Shaday’s sentence after finding that...more

Williams Mullen

White Collar & Investigations: Hastert Receives 15 Month Sentence in Federal Structuring Case

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In June of last year former Speaker of the United States House of Representatives Dennis Hastert was indicted for structuring and false statements to the FBI in an investigation that focused on more than $900,000 in cash...more

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