The U.S. Court of Appeals for the Second Circuit said for the first time Thursday that the general two-year discovery of injury accrual rule applies to claims made under the Commodities Exchange Act.

The panel—composed of Circuit Judges Ralph Winter and Rosemary Pooler, and U.S. District Court Judge Ronnie Abrams for the Southern District of New York, who was sitting by designation—affirmed the October 2017 dismissal of a number of federal pro se claims, including under the Commodities Exchange Act, by the plaintiff, attorney Susan Levy, by U.S. District Judge Gregory Woods of the Southern District of New York.

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