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Jane Doe v. Glenn M. Seliger, et al.

Paid petition · United States Court of Appeals for the Second Circuit, No. 25-159 · judgment December 16, 2025


Certiorari denied · June 22, 2026
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. DOES THE “SAFE HARBOR” OF THE FEDERAL RULES OF CI VIL PROCEDURE, RULE 11 TERMINATE UPON PROPER FILING OF A MOTION; OR, IN THE ALTERNATIVE: IS A CHALLENGE UNDER RULE 11 A THRESHOLD MATTER THAT A COURT SHOULD RESOLVE BEFORE RESOLVING THE LEGAL ISSUE?

  2. DOES A FEDERA L COURT OF A PPEA LS’ CAREFUL CONSIDERATION OF A DISTRICT COURT’S REASONS, WITHOUT MORE, NOT CONSTITUTE SUFFICIENT INDEPENDENT REVIEW?

  3. DO THE DECISIONS BELOW IN THIS CASE REFLECT A CLEAR MISAPPREHENSION OF SUMMARY JUDGMENT STANDARDS IN LIGHT OF THIS COURT’S PRECEDENTS?

Counsel of record

For petitioner
Thuy Q. Pham
The Law Office of Thuy Q. Pham

For respondent
Tina S. Bhatt
Landman Corsi Ballaine & Ford P.C.

Case

Conference history
Distributed for 1 conference

Linked docket
25A990

Proceedings

  1. Jun 22 2026
    Petition DENIED.
  2. Jun 02 2026
    DISTRIBUTED for Conference of 6/18/2026.
  3. May 27 2026
    Waiver of right of respondent Glenn M. Seliger, Linda Egenes, Kathleen Martucci, Jacqueline Velez, and John Mathew to respond filed.
  4. May 18 2026
    Petition for a writ of certiorari filed. (Response due June 22, 2026)
  5. Mar 11 2026
    Application (25A990) granted by Justice Sotomayor extending the time to file until May 15, 2026.
  6. Mar 06 2026
    Application (25A990) to extend the time to file a petition for a writ of certiorari from March 16, 2026 to May 15, 2026, submitted to Justice Sotomayor.