The U.S. Court of Appeals for the Second Circuit affirmed the criminal conviction of defendant Laquan Warren in a summary order issued January 29, 2026, marking the conclusion of his appeal from a May 28, 2024 judgment by the U.S. District Court for the Eastern District of New York.
The three-judge panel, consisting of Chief Judge Debra Ann Livingston and Circuit Judges William J. Nardini and Myrna Pérez, issued the ruling in case number 24-1538. The court's decision was rendered as a summary order, which carries significant procedural implications under federal appellate practice.
Summary orders represent a streamlined form of appellate decision-making used by federal circuit courts for cases that do not require extensive written analysis. As the Second Circuit explicitly noted in its order, "rulings by summary order do not have precedential effect." This means the decision cannot be cited as binding authority in future cases, though it may be cited under specific procedural rules.
Under Federal Rule of Appellate Procedure 32.1 and the Second Circuit's Local Rule 32.1.1, parties may cite summary orders filed on or after January 1, 2007, but 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 involved Warren appealing his conviction from the Eastern District of New York, where Judge Irizarry presided over the proceedings that led to the May 28, 2024 judgment. The specific charges and details of Warren's conviction were not elaborated upon in the summary order, which contained only the court's conclusion that the lower court's decision should be upheld.
Representing the government in the appeal were Assistant U.S. Attorneys Jonathan Siegel and Amy Busa, acting on behalf of Joseph Nocella Jr., the U.S. Attorney for the Eastern District of New York. Warren was represented by Kendra L. Hutchinson from Federal Defenders of New York, Inc., the federally funded organization that provides legal representation to indigent defendants in federal criminal cases.
The involvement of Federal Defenders suggests Warren likely qualified for appointed counsel due to financial circumstances, a common scenario in federal criminal cases where defendants face the full resources of the federal government's prosecution apparatus.
The Second Circuit's decision to resolve the appeal through a summary order rather than a full opinion suggests the panel found no novel legal questions or complex factual disputes requiring detailed analysis. Summary orders are typically used when the law is well-settled and the outcome is clear based on existing precedent.
This procedural approach allows appellate courts to manage their caseloads more efficiently while ensuring that defendants receive full appellate review of their convictions. The Second Circuit, which covers New York, Connecticut, and Vermont, handles hundreds of criminal appeals annually and uses summary orders for a significant portion of these cases.
The timing of the appeal, from a May 2024 district court judgment to a January 2026 appellate decision, reflects typical federal appellate processing times. Criminal appeals generally receive priority over civil matters, but the appellate process still involves briefing schedules, record preparation, and judicial review that can extend over many months.
Warren's case represents one of numerous criminal appeals processed by the Second Circuit annually. While the summary order format provides limited insight into the specific legal issues raised, the affirmance indicates that the appellate panel found no reversible error in the district court proceedings.
The court's direction to the Clerk to amend the caption suggests there was a minor clerical correction needed in how Warren's name was styled, likely involving the spelling of his first name from "LaQuan" to "Laquan" to match official records.
Federal criminal appeals typically challenge various aspects of district court proceedings, including evidentiary rulings, jury instructions, sentencing decisions, or constitutional violations. Without access to the appellate briefs or lower court record, the specific grounds for Warren's appeal remain unclear.
The affirmance means Warren's conviction and any associated sentence imposed by the district court remain in effect. While defendants in federal criminal cases may petition for Supreme Court review through a writ of certiorari, the high court accepts only a small percentage of such petitions, particularly in routine criminal matters resolved through summary orders.
The Second Circuit's efficient resolution of Warren's appeal through summary order reflects the federal judiciary's efforts to balance thorough appellate review with practical case management needs, ensuring that criminal defendants receive meaningful appellate consideration while maintaining court operations.