Justia U.S. 2nd Circuit Court of Appeals Opinion Summaries

Joe Baltas, a Connecticut state prisoner, was transferred to the Virginia Department of Corrections (VADOC) under the Interstate Corrections Compact. While at Red Onion State Prison (ROSP) in Virginia, Baltas alleges he was threatened by VADOC officials for filing a grievance and was later attacked by inmates, resulting in his placement in restrictive housing. He also claims that Connecticut Department of Corrections (CTDOC) officials failed to review his administrative segregation (Ad Seg) status as required, violating his due process rights under the Fourteenth Amendment. Additionally, he alleges violations of his First, Sixth, and Eighth Amendment rights due to his treatment at ROSP.The United States District Court for the District of Connecticut granted summary judgment in favor of the Defendants. The court found that CTDOC had adequately reviewed Baltas’s Ad Seg classification and dismissed his due process claim. It also dismissed his First, Sixth, and Eighth Amendment claims, concluding that Baltas failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the District Court’s ruling that CTDOC’s periodic reviews of Baltas’s Ad Seg classification satisfied due process requirements. However, it found that a genuine dispute of fact existed regarding whether VADOC’s administrative remedies were available to Baltas, making summary judgment inappropriate for his First, Sixth, and Eighth Amendment claims. The court vacated the summary judgment on these claims and remanded the case for further proceedings. The court also affirmed the dismissal of Baltas’s remaining claims in a concurrently issued summary order. View "Baltas v. Maiga" on Justia Law

The case involves a dispute between two companies, 1-800 Contacts, Inc. (Plaintiff-Appellant) and JAND, Inc., doing business as Warby Parker (Defendant-Appellee). 1-800 Contacts alleged that Warby Parker used its trademarks in keyword search advertisements, violating the federal Lanham Act and New York State common law. Specifically, 1-800 Contacts claimed that Warby Parker purchased keywords consisting of 1-800 Contacts' trademarks to divert customers searching for 1-800 Contacts to Warby Parker's website. However, 1-800 Contacts did not allege that Warby Parker used its trademarks in any other way beyond purchasing them as keywords.The United States District Court for the Southern District of New York granted Warby Parker's motion for judgment on the pleadings, dismissing the case. The district court applied the Polaroid test to determine the likelihood of consumer confusion and found that although 1-800 Contacts' trademarks were strong and there were indications of bad faith by Warby Parker, these factors were insufficient to establish a likelihood of consumer confusion. The court emphasized that Warby Parker's advertisements and landing pages clearly displayed Warby Parker's own mark, which was substantially different from 1-800 Contacts' marks.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the mere act of purchasing a competitor's trademarks as keywords does not constitute trademark infringement. It found that 1-800 Contacts failed to plausibly allege any likelihood of consumer confusion under the Polaroid test. The court noted that Warby Parker's advertisements and landing pages did not use 1-800 Contacts' trademarks and were clearly marked with Warby Parker's own branding, making it unlikely that consumers would be confused about the source or affiliation of the advertisements. View "1-800 Contacts, Inc. v. JAND, Inc." on Justia Law

In 2008, Charles Anthony Giovinco pleaded guilty to enticement of a minor and possession of child pornography. He received concurrent sentences of 235 months for enticement and 120 months for possession. The First Step Act of 2018 (FSA) allows eligible prisoners to earn time credits for participating in certain programs, but excludes those serving sentences for specific offenses, including possession of child pornography.Giovinco argued that he should be eligible for FSA time credits after completing the sentence for the ineligible offense. The Bureau of Prisons (BOP) denied his request, stating that his entire term of imprisonment must be considered as a single, aggregated sentence, making him ineligible for FSA time credits. Giovinco filed a habeas petition, which the United States District Court for the District of Connecticut denied, deferring to the BOP's interpretation.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that under 18 U.S.C. § 3584(c), multiple terms of imprisonment must be treated as a single, aggregate term for administrative purposes, including the administration of FSA time credits. Therefore, a prisoner serving any part of an aggregated sentence for an ineligible offense is not eligible to earn FSA time credits. The court affirmed the district court's judgment, agreeing that the BOP correctly aggregated Giovinco's sentences and determined his ineligibility for FSA time credits. View "Giovinco v. Pullen" on Justia Law

The case involves a challenge to New York City's Guaranty Law, which was enacted in response to the COVID-19 pandemic. The law rendered personal guaranties of commercial lease obligations arising between March 7, 2020, and June 30, 2021, permanently unenforceable and identified efforts to collect on such guaranties as proscribed commercial tenant harassment. Plaintiffs, a group of New York City landlords, argued that the law violated the Contracts Clause of the U.S. Constitution.Initially, the United States District Court for the Southern District of New York dismissed the plaintiffs' constitutional challenges, but the United States Court of Appeals for the Second Circuit reversed the dismissal of the Contracts Clause challenge and remanded the case for further consideration. On remand, the district court granted summary judgment in favor of the plaintiffs, finding that the Guaranty Law was unconstitutional.The City of New York appealed, arguing that the plaintiffs lacked standing because the City did not enforce the Guaranty Law. The Second Circuit found that while the plaintiffs had standing at the pleadings stage due to the presumption of enforcement, they failed to meet the heightened burden on summary judgment to show a credible threat of imminent enforcement by the City. The City had unequivocally disavowed any intent to enforce the Guaranty Law against the plaintiffs.The United States Court of Appeals for the Second Circuit vacated the district court's award of summary judgment and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. The court denied the City's request to vacate its earlier judgment reversing the dismissal of the Contracts Clause challenge and denied the City costs on the appeal due to its negligent delay in raising the enforcement-based standing challenge. View "Bochner v. City of New York" on Justia Law

A former public school principal in Brooklyn, New York, brought a lawsuit against the New York City Department of Education (DOE) and its former chancellor, alleging retaliation after she complained about racially segregated sports teams at her school. The principal claimed that the DOE's investigation into her was a retaliatory action for her complaints about race discrimination affecting her students.The United States District Court for the Southern District of New York dismissed the principal's Title VI claim, reasoning that her challenge was related to an employment practice and that the primary objective of the federal funds received by the DOE was not to provide employment. The court also denied her motion for leave to amend her complaint, even after reconsidering its initial decision.The United States Court of Appeals for the Second Circuit reviewed the case and held that the principal's retaliation claim was not an action "with respect to any employment practice" under Title VI because her underlying protected activity was unrelated to the DOE’s employment practices. The court concluded that Title VI does provide a private right of action for retaliation claims when the retaliation is for opposing non-employment-related race discrimination. The court affirmed the dismissal of the claim against the former chancellor but vacated the dismissal of the Title VI claim against the DOE and remanded the case for further proceedings. View "Bloomberg v. N.Y.C. Department of Education" on Justia Law

In December 2019, the defendant and a co-conspirator robbed a woman in a Bronx hotel room, taking $4,000 in cash, credit cards, cell phones, and a watch. The victim, a prostitute, had earned the cash through her business. The defendant was convicted of Hobbs Act Robbery and Conspiracy to Commit Hobbs Act Robbery after a jury trial.The U.S. District Court for the Southern District of New York sentenced the defendant to two concurrent 96-month terms of imprisonment, followed by three years of supervised release. The court also imposed a two-level enhancement for obstruction of justice, based on the defendant's alleged false testimony about his drug use at a suppression hearing.The United States Court of Appeals for the Second Circuit reviewed the case. The defendant challenged the sufficiency of the evidence regarding the interstate commerce element of the Hobbs Act offenses and the obstruction of justice enhancement. The appellate court affirmed the convictions, finding sufficient evidence that the robbery affected interstate commerce by depleting the victim's business assets. However, the court vacated the obstruction of justice enhancement, noting that the district court did not make a sufficient finding that the defendant's false testimony was willful. The case was remanded for further proceedings to determine whether the defendant acted with willful intent to provide false testimony. View "United States v. Orelien" on Justia Law

In 2020, East Fork Funding LLC filed a quiet title action against U.S. Bank, N.A., regarding a mortgage recorded against East Fork’s property. The mortgage had been subject to three foreclosure actions, two of which were voluntarily discontinued by the mortgagee. The district court granted summary judgment in favor of East Fork, holding that under the Foreclosure Abuse Prevention Act (FAPA), enacted in December 2022, the voluntary discontinuances did not reset the six-year statute of limitations for bringing a foreclosure action. Consequently, the statute of limitations continued to run from the commencement of the first foreclosure action in 2010 and expired six years later, entitling East Fork to quiet title.The United States District Court for the Eastern District of New York reviewed the case and granted summary judgment in favor of East Fork. The court held that FAPA applied retroactively to the voluntary discontinuances, meaning they did not reset the statute of limitations. Therefore, the statute of limitations began running with the filing of the 2010 action and expired before East Fork commenced the quiet title action. The court also found that retroactive application of FAPA did not violate the U.S. Constitution and that even under pre-FAPA law, the statute of limitations had expired.The United States Court of Appeals for the Second Circuit is currently reviewing the case. The main issue on appeal is whether FAPA applies retroactively to voluntary discontinuances that occurred before its enactment. The court has certified this question to the New York Court of Appeals, as it is a novel question of state law necessary to resolve the appeal. The Second Circuit seeks clarification on whether Sections 4 and/or 8 of FAPA apply to a unilateral voluntary discontinuance taken prior to the Act’s enactment. The court retains jurisdiction pending the New York Court of Appeals' response. View "E. Fork Funding LLC v. U.S. Bank, Nat'l Ass'n" on Justia Law

Defendant-Appellant Varian Lefebvre pled guilty to possession with intent to distribute heroin and fentanyl and possession of a firearm after a prior felony conviction. The case began when Vermont State Police responded to a 911 call reporting an assault at a Holiday Inn in Rutland, Vermont. Officers located Lefebvre at the hotel and transported him to the nearby Vermont State Police barracks for identification by the purported victims, where he was then arrested. Lefebvre argued that all physical evidence seized from his backpack after his arrest should have been suppressed, claiming that his seizure ripened into a de facto arrest unsupported by probable cause when he was transported to the police barracks.The United States District Court for the District of Vermont denied Lefebvre’s motion to suppress the physical evidence. The court found that the seizure did not rise to the level of a de facto arrest and was supported by probable cause. Lefebvre entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Lefebvre’s seizure did not become a de facto arrest when he was transported to the police barracks because the transportation was a reasonable and non-dilatory investigative step given the unique circumstances. The court also found that even if the transportation did rise to the level of an arrest, it was supported by probable cause based on the totality of the circumstances, including the 911 call, witness descriptions, and Lefebvre’s behavior. The judgment of the district court was affirmed. View "United States of America v. Lefebvre" on Justia Law

Reporters from Bloomberg L.P. and Dow Jones & Company, Inc. requested aggregated, anonymized change-of-address (COA) data from the United States Postal Service (USPS) under the Freedom of Information Act (FOIA). They intended to use this data for reporting on population movement trends during the COVID-19 pandemic. USPS denied the requests, citing FOIA Exemption #3, which allows withholding of "information of a commercial nature" under the Postal Reorganization Act of 1970. USPS argued that the data was intended for a commercial product called "Population Mobility Trends."The United States District Court for the Southern District of New York granted summary judgment in favor of USPS. The court found that the COA data was indeed "information of a commercial nature" and that USPS had met its burden of proof under FOIA Exemption #3. The court noted that USPS had previously provided similar data but had since decided to monetize it through the Population Mobility Trends product.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the COA data was "of a commercial nature" because it had monetary value derived from USPS's core business of delivering mail. The court also found that under good business practice, a private business would not disclose such valuable data for free if it intended to sell it. Therefore, USPS was justified in withholding the data under FOIA Exemption #3 and the Postal Reorganization Act. The court emphasized that Congress had granted USPS broad exemptions to operate more like a business, including the ability to withhold commercially valuable information. View "Bloomberg L.P. v. United States Postal Service" on Justia Law

In this case, the defendant was involved in a scheme to defraud the City of West Haven, Connecticut, of COVID-19 relief funds. The defendant, along with co-conspirators, submitted fraudulent invoices for equipment and services that were never provided. The City paid over $400,000 based on these false invoices. The defendant was the only one among his co-defendants to go to trial, while the others pled guilty.The United States District Court for the District of Connecticut convicted the defendant of wire fraud and conspiracy to commit wire fraud. The court sentenced him to 96 months in prison, which was above the recommended guidelines range. The defendant appealed, challenging the sentence as substantively unreasonable, the sufficiency of the evidence, and the district court’s evidentiary rulings.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that the district court had provided a detailed explanation for the above-guidelines sentence, emphasizing the severity of the crime, the defendant’s financial gains, and the need for deterrence. The court also noted that the defendant did not receive a trial penalty, as the district court had explicitly stated that the sentence was not influenced by the defendant’s decision to go to trial. The court further found that the evidentiary rulings were not erroneous and that the evidence presented at trial was sufficient to support the conviction.The Second Circuit concluded that none of the defendant’s challenges had merit and affirmed the judgment of the district court. View "United States v. Trasacco" on Justia Law