A note from the Committee: Readers should be aware that the Committee generally meets twice a year to update the Instructions and Commentary. There is an inevitable delay between the announcement of new decisions, the Committee's consideration of those decisions, and the publication of any revisions to the Instructions or Commentary.
For a somewhat dramatic example, consider Carman v. Carroll, 749 F.3d 192 (3d Cir. 2014). The United States Court of Appeals for the Third Circuit decided Carman in May of 2014. At its October meeting, the Committee revised the Commentary to reflect that decision, and the revisions were posted to this site in early November. On November 10, 2014, however, the Supreme Court of the United States granted certiorari and summarily reversed. Carroll v. Carman, 135 S. Ct. 348 (2014). As of January 2015, any possible further changes to the Commentary (to reflect the Supreme Court's decision in Carroll v. Carman and otherwise) await the Committee's next meeting.
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