Galanis Appeal Leads To Limited Remand To Determine Whether Counsel Was Ineffective
The appeal in United States v. Galanis, 17-629 (Sack, Parker, Chin) resulted in a limited remand in a summary order so that the district court can determine whether there was ineffective assistance of counsel. The facts of the case are somewhat unusual. Galanis was indicted in two different and separately-charged securities fraud cases. In September 2015, Galanis was indicted in the Gerova matter, and in May 2016, he was indicted in the Wakpamni matter. He was represented by a California law firm in the Gerova matter, but that firm declined to appear in the Galanis matter (perhaps due to unpaid invoices by the client). This left Galanis unrepresented in the Genova matter.