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

Three former employees of Amazon filed a class action complaint seeking payment for straight-time and overtime wages under Connecticut’s wage laws for time spent undergoing mandatory security screenings after clocking out. The employees argued that this time should be compensable under state law. Amazon required employees to pass through security screenings when exiting the secured area of their fulfillment centers, but not upon entry. The screenings involved metal detectors and varied based on the personal belongings employees carried. Employees were not compensated for the time spent in these screenings.The United States District Court for the District of Connecticut granted summary judgment in favor of Amazon, dismissing the employees' complaint. The court relied on the United States Supreme Court’s decision in Integrity Staffing Solutions, Inc. v. Busk, which held that time spent in mandatory security screenings is not compensable under federal law. The employees appealed the decision and moved to certify a question to the Connecticut Supreme Court regarding the applicability of Connecticut’s wage laws to their case.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the question of whether Connecticut’s wage laws require compensation for time spent in mandatory security screenings is unresolved. The court decided to certify this question to the Connecticut Supreme Court for a definitive resolution. Additionally, the court asked the Connecticut Supreme Court to address whether a de minimis exception applies to such compensable time and, if so, what amount of time is considered de minimis. The Second Circuit reserved its decision and dismissed the employees' motion to certify as moot, pending the Connecticut Supreme Court's response. View "Del Rio v. Amazon.com.DECE, LLC" on Justia Law

Nasir Cooper was convicted after pleading guilty to one count of possessing ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Cooper was sentenced to 57 months in prison, followed by three years of supervised release, and a $100 mandatory special assessment. Cooper appealed, arguing that the district court erred in classifying his prior conviction for second-degree attempted assault under New York Penal Law § 120.05(7) as a crime of violence under the United States Sentencing Guidelines.The United States District Court for the Southern District of New York determined that Cooper's prior conviction for second-degree attempted assault was a crime of violence, which resulted in a base offense level of 24 under the Sentencing Guidelines. Cooper objected, arguing that the conviction should not be considered a crime of violence, which would have resulted in a lower base offense level of 20. The district court rejected Cooper's argument and sentenced him based on the higher offense level.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 Cooper had waived any argument that his conviction was not under N.Y.P.L. § 120.05(7) by acknowledging it in his sentencing submissions. The court also held that a conviction for second-degree attempted assault under N.Y.P.L. § 120.05(7) categorically constitutes a crime of violence for purposes of U.S.S.G. § 2K2.1(a). The court reasoned that the statute requires the use of physical force capable of causing physical pain or injury, meeting the criteria for a crime of violence under the Guidelines. Consequently, the appellate court found no procedural error in the district court's determination of Cooper's base offense level and affirmed the sentence. View "United States v. Cooper" on Justia Law

On October 24, 2016, Syracuse Police Department officers entered Troy Alexander's home without a warrant after receiving a report of a sexual assault. They searched the home for 12.5 hours before obtaining a warrant, during which they also towed Alexander's cars. After obtaining the warrant, they found narcotics in Alexander's bedroom. Alexander was arrested and faced multiple charges, including burglary, narcotics, and sexual assault. He posted bail twice but was not immediately released. Eventually, all charges were dropped.Alexander filed a lawsuit alleging violations of his constitutional rights and state law by the City of Syracuse, County of Onondaga, and Detective Rory Gilhooley. He claimed the warrantless entry and prolonged seizure of his home violated his Fourth Amendment rights, that he was falsely arrested, maliciously prosecuted, and improperly detained after posting bail. The United States District Court for the Northern District of New York granted summary judgment to the defendants on all claims.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that Alexander's claims regarding the warrantless entry, search, and seizure of his home, as well as his false arrest and malicious prosecution claims related to the burglary charges, presented triable issues of fact. The court also found gaps in the evidentiary record regarding Alexander's state law claims of continued detention after posting bail, precluding summary judgment for the City and County on these claims. The court vacated and remanded the judgment on these claims but affirmed the judgment in all other respects. View "Alexander v. City of Syracuse" on Justia Law

Plaintiffs, representing a putative class, filed an antitrust lawsuit against Grubhub Inc., Postmates Inc., and Uber Technologies, Inc. (collectively, "Defendants"). The plaintiffs alleged that the defendants violated Section 1 of the Sherman Antitrust Act and its state analogues by entering into no-price competition clauses (NPCCs) with restaurants, which prevented the restaurants from offering lower prices through other channels. The plaintiffs claimed that these NPCCs led to artificially high prices for restaurant meals. The class included customers who purchased takeout or delivery directly from restaurants subject to NPCCs, customers who dined in at such restaurants, and customers who used non-defendant platforms to purchase from these restaurants.The United States District Court for the Southern District of New York denied the defendants' motion to compel arbitration. The court held that the scope of the arbitration clauses was an issue for the court to decide and that the clauses did not apply to the plaintiffs' claims as they lacked a nexus to the defendants' Terms of Use. The court also found that the plaintiffs had not agreed to Grubhub's Terms of Use.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's decision in part, ruling that the question of arbitrability for the plaintiffs' claims against Grubhub is for the court to decide and that Grubhub's arbitration clause does not apply to the plaintiffs' antitrust claims. However, the court reversed the district court's decision in part, finding that Grubhub had established an agreement to arbitrate with the plaintiffs and that the threshold question for the plaintiffs' claims against Uber and Postmates is for the arbitrator to decide. The case was remanded for further proceedings consistent with this opinion. View "Davitashvili v. Grubhub" on Justia Law

Anna Gristina, the plaintiff-appellant, sought to unseal transcripts related to her 2012 New York State criminal conviction for promoting prostitution. Nearly ten years after her guilty plea, she filed motions before Justice Juan Merchan, requesting the unsealing of several transcripts. After her motion was partially denied and while the decision was under review by higher state courts, Gristina filed a federal suit under 42 U.S.C. § 1983 against Justice Merchan and New York District Attorney Alvin Bragg, seeking declaratory and injunctive relief to unseal three specific transcripts.The United States District Court for the Southern District of New York dismissed Gristina's complaint for lack of subject-matter jurisdiction, citing the Younger abstention doctrine. The district court concluded that it was required to abstain from exercising jurisdiction because the state court order denying the unsealing of transcripts was a pending matter in New York State court involving a judicial function. Alternatively, the district court held that the Rooker-Feldman doctrine prohibited it from reviewing the state court order as it was a final state court judgment.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court properly abstained from exercising jurisdiction under the Younger abstention doctrine. The court found that the state court's order denying the unsealing of transcripts, which was still under review by higher state courts at the time Gristina filed her federal suit, was a pending civil proceeding uniquely in furtherance of the state court's ability to perform its judicial functions. Therefore, Younger abstention was required, and the district court's dismissal of the complaint was affirmed. View "Gristina v. Merchan" on Justia Law

In 2020, the Vermont Superior Court transitioned to electronic filing and adopted a policy that delayed public access to newly filed civil complaints until a court clerk reviewed them for compliance with technical requirements and the absence of unredacted confidential information. Plaintiffs, consisting of news and media organizations, challenged this practice, claiming it violated their First Amendment right of access to court documents.The United States District Court for the District of Vermont held a bench trial and ruled in favor of the Plaintiffs. The court found that Vermont’s pre-access review process violated the First Amendment and issued a permanent injunction preventing the Defendants from withholding complaints until the completion of the review process. The Defendants, administrators and clerks of the Vermont Superior Court, appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that Vermont’s practice, as reviewed, violated the Plaintiffs’ First Amendment rights. However, the appellate court found that the terms of the permanent injunction were not supported by the court’s findings. The Second Circuit affirmed the district court’s judgment to the extent it found the practice violated the First Amendment but vacated the permanent injunction. The case was remanded for further proceedings to reconsider the terms of an appropriate injunction. The court also addressed and rejected the Defendants' arguments regarding abstention and mootness. View "Courthouse News Service v. Corsones" on Justia Law

Defendant-Appellant Kenston Harry was convicted of possessing controlled substances with intent to distribute and conspiracy to distribute the same. The case centers on the use of a stationary pole camera by the Drug Enforcement Administration (DEA) to monitor the exterior of Harry's business, Action Audio, for approximately 50 days without a warrant. The camera captured footage of the business's exterior, parking lot, and occasionally the interior when the garage door was open. Harry was arrested after investigators found narcotics and firearms at Action Audio and his residence.The United States District Court for the District of Connecticut denied Harry's motion to suppress the pole-camera evidence, which was introduced at trial. The jury convicted Harry, and the district court sentenced him to ten years for the fentanyl- and cocaine-related charges, including conspiracy, and five years for the marijuana charge, to run concurrently. The court also denied Harry's request for safety-valve relief from the mandatory minimum sentence under 18 U.S.C. § 3553(f).The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the use of the stationary pole camera did not constitute a Fourth Amendment search, as Harry did not have a reasonable expectation of privacy in the publicly visible areas of his business. The court also found that the district court did not err in denying Harry safety-valve relief, as he failed to prove that the firearms found were not connected to his drug-trafficking activities. The Second Circuit affirmed the judgment of the district court. View "United States v. Harry" on Justia Law

Diego Penaranda Arevalo, a citizen of Ecuador unlawfully present in the United States, sought cancellation of a removal order under 8 U.S.C. § 1229b(b)(1). An immigration judge denied his application, and the Board of Immigration Appeals (BIA) affirmed. Penaranda then petitioned the United States Court of Appeals for the Second Circuit for review. While this petition was pending, Penaranda filed a motion with the BIA to terminate or remand his removal proceedings, arguing that his removal order was invalid because his original notice to appear did not include the date and time of his initial hearing, as required by 8 U.S.C. § 1229(a). The BIA denied the motion, reasoning that Penaranda had forfeited any objection based on the time-and-place requirement by failing to raise it in a timely manner.The Second Circuit reviewed both cases together. The court reaffirmed its decision in Banegas Gomez v. Barr that the time-and-place requirement is a non-jurisdictional rule and held that the BIA did not abuse its discretion in concluding that Penaranda forfeited his objection. Therefore, the court denied that petition.In his first petition, Penaranda challenged the immigration judge’s finding that he gave false testimony for the purpose of obtaining an immigration benefit, which led to the conclusion that he failed to establish good moral character and was therefore ineligible for the requested relief. The Second Circuit found that it lacked jurisdiction to review Penaranda’s petition insofar as it contested whether and why he testified falsely, as these are unreviewable questions of fact under 8 U.S.C. § 1252(a)(2)(B)(i). Penaranda also argued that the immigration judge held him to a higher burden of proof than required. The court found that this argument, while a question of law, failed on the merits. Accordingly, the court dismissed in part and denied in part Penaranda’s first petition. View "Penaranda Arevalo v. Bondi" on Justia Law

The case involves the U.S. Centers for Medicare & Medicaid Services (CMS) approving the New York State Department of Health’s (NYSDOH) application to distribute $361.25 million to certain managed care organizations. These organizations were to direct the funds to the top one-third of revenue-generating licensed home care services agencies (LHCSAs) in New York’s four rate regions, provided they agreed to use the funding in a specified manner. The plaintiffs, who are LHCSAs that did not meet the revenue threshold, argued that the approval was unlawful under federal law and regulations because the class of eligible agencies was improperly defined and the application was not assessed for actuarial soundness before approval.The district court dismissed the amended complaint against the State Appellees for failing to adequately allege a cause of action under Ex parte Young and granted summary judgment to the Federal Appellees. The court concluded that the approval of the State’s application did not violate the Administrative Procedure Act (APA) and denied the plaintiffs’ motion to admit extra-record evidence.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court’s decision. The court held that CMS’s approval of NYSDOH’s application complied with federal law. It found that the provider class was properly defined under 42 C.F.R. § 438.6(c)(2)(ii)(B) and that CMS was not required to assess actuarial soundness during the pre-approval process. The court also concluded that CMS did not act arbitrarily or capriciously in approving the application and that the district court did not abuse its discretion in excluding the extra-record evidence. Consequently, the Second Circuit affirmed the judgment of the district court. View "Safe Haven Home Care, Inc. v. United States Department of Health and Human" on Justia Law

Shuqiang Tian, a native and citizen of China, sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in the United States. Tian claimed persecution by the Chinese government due to his opposition to the government's forcible demolition policy, which involved demolishing villagers' homes without just compensation. Tian testified that he protested against the demolition, was arrested, beaten, and threatened by the police, and ultimately forced to accept inadequate compensation under duress.An Immigration Judge (IJ) denied Tian's claims, concluding that his prosecution for blocking a road and agitating in a government office did not amount to persecution. The IJ found no sufficient nexus between Tian's political opinion and the harm he suffered. The IJ also summarily denied Tian's CAT claim, stating that he had not demonstrated a likelihood of torture upon return to China. The Board of Immigration Appeals (BIA) affirmed the IJ's decision, agreeing that Tian failed to show past persecution or a well-founded fear of future persecution based on a protected ground, and that he did not meet the burden for CAT protection.The United States Court of Appeals for the Second Circuit reviewed the case and found that the agency's analysis was legally deficient. The court noted that the IJ and BIA failed to consider material evidence and the context of Tian's protests, which indicated that his persecution was linked to his political opinion. The court also found that the agency did not adequately address the possibility that Tian's arrests were pretextual and failed to provide a reasoned basis for denying his CAT claim. Consequently, the Second Circuit granted Tian's petition, vacated the BIA's decision, and remanded the case for reconsideration. View "Tian v. Bondi" on Justia Law