Espitia and Eberhart:

While law geeks everywhere were focused on the Alito nomination today, it is worth noting that the Supreme Court issued two per curiam summary reversals this morning. The first, Kane v. Espitia, is a 2-pager that unanimously reversed a Ninth Circuit panel for failing to apply AEDPA (shocked, aren’t ya?). The second, an in forma pauperis case called Eberhart v. United States, clarified the statutory deadlines for filing new trial motions in federal criminal cases.

  Thanks to Doug Berman for the heads-up. (Oh, and for the curious, the Ninth Circuit panel was Canby, Rawlinson, and David Hansen from the 8th Circuit.)