Here’s a quick summary of noteworthy summary orders recently issued by the Circuit:
United States v. Davis, No. 12-4836-cr (2d Cir. Apr. 2, 2014) (Katzmann, Livingston, and Carter) (summary order), available here
United States v. Marks, No. 12-3788-cr (2d Cir. Mar. 31, 2014) (Parker, Hall, and Livingston) (summary order), available here
This summary order upholds the district court’s decision to deny Marks a new trial based on alleged ineffective assistance of counsel. Though counsel failed to communicate a plea offer (of 20 years in prison) to the defendant, Marks failed to show a “reasonable probability” that he would have accepted the plea offer if it had been relayed.