Almost 10 years after he was convicted of killing his wife and discarding her dismembered body from an airplane over the Atlantic Ocean, Robert Bierenbaum is just about out of options for regaining his freedom.

The U.S. Court of Appeals for the Second Circuit yesterday rejected Mr. Bierenbaum’s claim that his lawyer was ineffective at his 2000 trial for killing Gail Katz Bierenbaum, one of the rare cases where a person was convicted of murder even though the victim’s body was never found.