Second Circuit Employs “Mini-En Banc” to Relieve District Court of Requirement to Complete Non-Existent Form

In United States v. Karim Smith, the Second Circuit (Wesley, Chin, Sullivan) overturned its prior precedent and held that district courts need not complete a written ‘statement of reasons’ (“SOR”) form when sentencing a defendant during a violation...
By: Patterson Belknap Webb & Tyler LLP

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