The U.S. Court of Appeals for the Second Circuit affirmed a district court judgment in *Groisman v. Jeffrey Zwick & Associates*, issuing a summary order on January 6, 2026. The three-judge panel, consisting of Circuit Judges Gerard E. Lynch, William J. Nardini, and Steven J. Menashi, upheld a January 22, 2025, order from the U.S. District Court for the Eastern District of New York.
The case involved plaintiff-appellant Daniel Groisman challenging a decision by District Judge Carol B. Amon that favored defendants Jeffrey Zwick & Associates and Jeffrey Zwick. The appeals court's brief summary order stated that "upon due consideration, it is hereby ordered, adjudged, and decreed that the judgment of the district court is AFFIRMED."
The litigation included multiple parties beyond the primary defendants. Additional defendants named in the case include Moshe Feler, also known as Yosef Feler, described as an assignee of A/K/A Feller, Law Offices of N.C. Caller P.C., Carl N. Caller, and unnamed John Does and XYZ Corporations. The inclusion of these various entities suggests the dispute may have involved complex business relationships or assignment of claims.
Representing Groisman on appeal was attorney Joseph H. Neiman of Hackensack, New Jersey. The defendants were represented by Henry M. Mascia of Rivkin Radler LLP in Uniondale, New York, with assistance from colleagues Cheryl F. Korman and Amanda R. Griner.
The Second Circuit's decision came in the form of a summary order, which the court explicitly noted "do not have precedential effect." This type of ruling is typically used for cases where the legal issues are well-settled or where the appeals court determines that a full written opinion would not significantly contribute to legal precedent.
Under Federal Rule of Appellate Procedure 32.1 and the Second Circuit's Local Rule 32.1.1, summary orders filed after January 1, 2007, may be cited in legal documents. However, parties citing such orders must reference either the Federal Appendix or an electronic database with the notation "summary order." Additionally, any party citing a summary order must serve a copy on unrepresented parties.
The case was heard at the Thurgood Marshall United States Courthouse at 40 Foley Square in New York City. The Second Circuit, which covers New York, Connecticut, and Vermont, regularly conducts proceedings at this location for appeals from federal district courts within its jurisdiction.
While the summary order does not provide details about the underlying dispute or the specific legal issues that led to the original district court decision, the affirmance indicates that the appeals court found no reversible error in Judge Amon's ruling. The Eastern District of New York, where the original case was decided, handles federal civil and criminal matters for Brooklyn, Queens, Staten Island, and Nassau and Suffolk counties.
The involvement of multiple law firms and associates in the defendant list suggests the case may have centered on legal practice issues, fee disputes, or professional responsibility matters. The presence of assignees and various business entities indicates potential complications involving the transfer of legal claims or business relationships.
The January 2025 district court order that formed the basis of Groisman's appeal was likely dispositive of major claims in the case, given that it resulted in a judgment that Groisman felt compelled to challenge. Such orders typically involve summary judgment motions, dismissals, or other rulings that resolve significant portions of litigation.
For practitioners in the Second Circuit, this case demonstrates the court's continued use of summary orders to efficiently resolve appeals that do not require extensive legal analysis or precedent-setting opinions. The quick turnaround from the January 22, 2025, district court order to the January 6, 2026, appeals court decision reflects the streamlined process often employed for summary order cases.
The affirmance leaves the district court's ruling intact, meaning whatever relief or dismissal Judge Amon granted to the defendants remains in effect. For Groisman, the appeals court's decision represents the end of this particular legal challenge, barring any potential petition for Supreme Court review, which would face significant hurdles given the summary nature of the Second Circuit's ruling.
The case adds to the body of non-precedential decisions that, while not binding, may provide guidance to practitioners handling similar disputes in federal court. The Second Circuit's handling of the matter through summary order reflects the court's assessment that the legal issues presented were sufficiently clear to warrant affirmance without extended analysis.