Circuit Splits Reported in U.S. Law Week—January 2025

U.S. Law Week summarizes selected splits among U.S. federal courts of appeals each month.

Criminal Law

Case:

United States v. O’Donovan, 2025 BL 13053 (Article)

Issue:

Is use of the internet alone sufficient to establish that messages traveled across state lines? The First Circuit agrees with the Third and Fifth Circuits, taking the position that evidence of transmission over the internet is “per se sufficient” to show something was transmitted through interstate commerce. The Ninth and Tenth Circuits reject the per se rule.

Labor

Case:

Luna Vanegas v. Signet Builders Inc., 2025 BL 9833 (Article)

Issue:

Can out-of-state ...