The U.S. Court of Appeals for the Second Circuit issued a summary order on January 27, 2026, in the criminal case *United States v. Jesus Concepcion* (No. 24-2532-cr), resolving a federal criminal appeal from the Southern District of New York.
The three-judge panel included Circuit Judges Dennis Jacobs, José A. Cabranes, and Raymond J. Lohier Jr., who convened at the Thurgood Marshall United States Courthouse in Manhattan to decide the appeal. The case involved defendant Jesus Concepcion challenging a judgment from a federal district court in the Southern District of New York.
Defendant Concepcion was represented by Michelle Anderson Barth from the Law Office of Michelle Anderson Barth in Burlington, Vermont. The government's position was argued by Assistant United States Attorney Camille L. Fletcher, with assistance from Alexandra S. Messiter and Michael D. Maimin, representing Jay Clayton, the United States Attorney for the Southern District of New York.
The Second Circuit emphasized in its order that summary orders carry no precedential effect, meaning the ruling does not establish binding legal precedent for future cases. This designation is common for appeals courts when addressing routine matters or cases that do not raise novel legal questions requiring detailed written opinions.
Despite lacking precedential value, the summary order format allows the Second Circuit to efficiently resolve appeals while providing parties with a final resolution of their case. The court noted that citations to summary orders filed on or after January 1, 2007, are permitted under Federal Rule of Appellate Procedure 32.1 and the court's Local Rule 32.1.1.
When parties cite summary orders in future court filings, they 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 parties not represented by counsel, ensuring proper notice and access to the referenced decision.
The Second Circuit Court of Appeals serves Connecticut, New York, and Vermont, handling appeals from federal district courts within those states. The court regularly issues both published opinions that establish precedent and summary orders that resolve individual cases without creating binding law for future disputes.
Summary orders represent a significant portion of federal appellate decisions, allowing courts to manage heavy caseloads while ensuring each appeal receives appropriate judicial review. While these orders lack precedential effect, they provide final resolution for the specific parties involved and demonstrate how established legal principles apply to particular fact patterns.
The case number 24-2532-cr indicates this was a criminal appeal filed in 2024, with the "cr" designation confirming its criminal nature. Criminal appeals to circuit courts typically involve challenges to convictions, sentences, or pre-trial rulings from federal district courts.
Circuit Judge Dennis Jacobs, appointed to the Second Circuit in 1992, previously served as Chief Judge of the court from 2006 to 2013. Judge José A. Cabranes, appointed in 1994, is a senior member of the court with extensive experience in federal criminal law. Judge Raymond J. Lohier Jr., appointed in 2010, brings additional criminal law expertise to the panel.
The involvement of the U.S. Attorney's Office for the Southern District of New York, one of the most prominent federal prosecutor's offices in the country, suggests the underlying case involved federal criminal charges prosecuted in Manhattan's federal courthouse.
While the summary order format means limited public details about the specific legal issues or factual background, the case represents the Second Circuit's ongoing role in reviewing federal criminal cases and ensuring proper application of federal law in criminal prosecutions.
The January 27, 2026 date places this decision within the current judicial year, reflecting the Second Circuit's active docket in addressing criminal appeals from across its three-state jurisdiction. The court's efficient resolution through summary order demonstrates the appellate system's capacity to handle diverse criminal cases while maintaining appropriate judicial oversight of district court decisions.
For defendant Concepcion and the government, the summary order provides final resolution of the appellate process, concluding the federal court proceedings unless further review is sought from the Supreme Court through a petition for writ of certiorari, though such petitions are rarely granted in routine criminal appeals.