Federal Defenders of New York Blog

In Stinn v. United States, No. 25-293 (2d Cir. Aug. 17, 2026) (Walker (writing), Sullivan, Bianco), the Second Circuit affirmed the denial of Bradley Stinn’s petition for a writ of error coram nobis, holding as a matter of first impression that harmless-error review on coram nobis is governed by Kotteakos v. United States, 328 U.S. ...

United States v. Matos, No. 22-1561 (2d Cir. Aug. 13, 2026) (Cabranes, Livingston, Nardini), is the Second Circuit’s first published application of Hunter v. United States, 146 S. Ct. 1702 (2026). The result of Judge Livingston’s opinion is unremarkable: Matos’s challenges to his criminal history calculation under the Guidelines and to the substantive reasonableness of ...