Manslaughter

First-degree manslaughter is a “categorical violent” crime, because a person can only be guilty of that crime if they cause death while “intending to cause at least serious bodily injury,” the Second Circuit ruled, finding that the lower court improperly ruled that the crime is not a categorical “violent felony” because it’s possible to commit such a homicide by “omission.”

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Settlement Scuffle

In a suit arising from employment discrimination claims against IBM brought by an employee who said he was fired for being deaf, the Second Circuit ruled a lower court properly denied the former employee’s request to reopen the case, which was settled for $207,000. The employee claims his attorneys miscommunicated to him in American Sign Language and he thought the settlement amount was $207 million.

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Education Benefits

The Second Circuit ruled that a lower court improperly rejected a girl’s request for a preliminary injunction to require Vermont’s Agency of Education to allow her to access benefits pending adjudication of her claims alleging the dual enrollment program, which pays for high schoolers to take college courses, violated her rights with its requirement that her private school tuition be “publicly funded.”

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