Though upstaged by Dimaya, the Second Circuit issued a remarkable summary order yesterday–one that calls attention to potential Brady violations in the EDNY, and to the CJA resources necessary to detect such violations. See United States v. Djibo, No. 16-3956 (2d Cir. 2018) (Sack, Hall, Droney) (appeal from Johnson, J, EDNY). In Djibo, the Circuit vacated the denial … Read more