NYLJ Eastern District Roundup
Lack of Jurisdiction, Rulings Concerning ‘Crime of Violence’
This column reports on several significant representative decisions handed down recently in the U.S. District Court for the Eastern District of New York. Judge Rachel P. Kovner granted a motion to dismiss for lack of subject matter jurisdiction because claims were not brought under the Administrative Procedures Act (APA). Judge Ann M. Donnelly similarly found jurisdiction lacking over a pro se complaint seeking review of an order under the Perishable Agricultural Commodities Act (PACA). And Judges Frederic Block and Pamela K. Chen issued rulings concerning whether crimes fell within the “crime of violence” definition under 18 U.S.C. §924(c).