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

Two plaintiffs, one individual and one advocacy organization, filed suit against a ridesharing company, alleging discrimination against persons with mobility-related disabilities. They claimed the company violated the Americans with Disabilities Act (ADA) and New York State Human Rights Law (NYSHRL) by failing to make wheelchair accessible vehicles (WAVs)—that accommodate fixed-frame wheelchairs—available in all regions it operates, instead of only nine cities. The plaintiffs proposed several modifications to the company’s policies and practices to increase WAV availability in Westchester County, New York, and sought class certification for affected residents and visitors.The United States District Court for the Southern District of New York held a bench trial. After reviewing the evidence, the court found that the plaintiffs failed to demonstrate either that the rideshare platform’s limited menu constituted a barrier to WAV access or that their proposed modifications would effectively or reasonably achieve WAV transportation in the relevant regions. The court also determined that the evidence did not show the proposed modifications were likely to be effective, and that the defendant’s proof established the modifications would not be reasonable. As a result, the district court dismissed the plaintiffs’ claims.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s findings for clear error and considered plaintiffs’ arguments regarding evidentiary burdens and the effectiveness of proposed modifications. The Second Circuit concluded that plaintiffs bore the burden of persuasion as to effectiveness, and only a light burden of production as to reasonableness. The appellate court found no error in the district court’s application of these standards and affirmed the judgment, holding that the plaintiffs failed to show their proposed modifications would effectively provide WAV service in Westchester County. View "Lowell v. Lyft, Inc." on Justia Law

An elderly patient, after contracting COVID-19, received remote medical treatment from an out-of-state physician who prescribed multiple medications, including prednisone. Prednisone is known to carry a risk of peptic ulcer disease, especially in older individuals, and the physician did not prescribe mitigating medication to counteract these side effects. The patient subsequently developed a perforated ulcer and died from organ failure. The estate brought suit against the physician for negligence, lack of informed consent, and violation of the Connecticut Unfair Trade Practices Act (CUTPA).The estate initially filed the action in Connecticut Superior Court, and the physician removed it to the United States District Court for the District of Connecticut. The physician moved to dismiss, arguing immunity under the Public Readiness and Emergency Preparedness Act (PREP Act) and contending the CUTPA claim was not viable. The District Court dismissed the CUTPA claim but denied the motion to dismiss the negligence and informed consent claims, concluding PREP Act immunity did not apply.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the physician qualified for PREP Act immunity because he was a licensed health professional who prescribed a covered countermeasure (prednisone) for COVID-19, and the prescription had a causal relationship with the patient’s death. The court also held that the CUTPA claim was impermissible because it was based on alleged professional negligence rather than business or entrepreneurial conduct. The Second Circuit affirmed the dismissal of the CUTPA claim, reversed the District Court’s denial of PREP Act immunity, and remanded for further proceedings. View "Waters v. Kory" on Justia Law

The defendant pled guilty to conspiring to traffic firearms after law enforcement in Bridgeport, Connecticut, discovered evidence linking him to the illegal purchase and distribution of about twenty guns. The investigation began when he arrived at a hospital with a gunshot wound, and further inquiry revealed multiple firearm purchases, sales to prohibited persons, and the use of tools to obliterate serial numbers. Messages found on his phone confirmed his awareness that his actions were unlawful and indicated attempts to cover up his conduct.The United States District Court for the District of Connecticut adopted the Presentence Report’s Guidelines range of 51 to 63 months but sentenced the defendant to 84 months’ imprisonment, an upward variance. The court justified this by referencing the seriousness of the offense, the number of firearms involved, the obliteration of serial numbers, the defendant’s knowledge that buyers were prohibited persons, and his failure to assist law enforcement in recovering the trafficked firearms.On appeal, the United States Court of Appeals for the Second Circuit reviewed the procedural and substantive reasonableness of the sentence. The appellate court held that the district court committed procedural error by increasing the sentence based, in substantial part, on the defendant’s refusal to cooperate with law enforcement, which is impermissible. Additionally, the district court erred by imposing an upward variance based on factors already included in the Guidelines calculation, without explaining why those factors warranted greater weight in this case, as required by United States v. Sindima. The Second Circuit found these errors to be plain and determined that they affected the fairness of the proceedings.Accordingly, the Second Circuit vacated the sentence and remanded the case for resentencing before a different district judge, to ensure the appearance of justice is preserved. View "United States v. Bagley" on Justia Law

The defendant was convicted in 2009 by a jury of four drug offenses involving crack cocaine, including conspiracy and possession with intent to distribute. The offenses involved quantities that, at the time, triggered severe mandatory minimum sentences under federal law. The defendant also had two prior New York State drug convictions, which increased his sentencing exposure. He was originally sentenced to life imprisonment and life terms of supervised release.After his conviction and sentence were affirmed by the United States Court of Appeals for the Second Circuit and certiorari was denied by the Supreme Court, the defendant sought relief under the First Step Act of 2018. The district court for the Northern District of New York first denied his motion for a reduced sentence but, following the Supreme Court’s decision in Concepcion v. United States and a remand from the Second Circuit, the district court resentenced him to time served and eight years of supervised release. The district court believed it had discretion to reduce the mandatory minimum supervised release term based on nonretroactive changes to the law and the Sentencing Guidelines.On appeal, the United States Court of Appeals for the Second Circuit reviewed whether the district court could impose a supervised release term below the eight-year statutory minimum set by 21 U.S.C. § 841(b)(1)(B) when resentencing under § 404(b) of the First Step Act. The court held that Congress made clear that changes to the mandatory minimums in § 401 of the First Step Act do not apply retroactively except in narrow circumstances not present here. The Supreme Court’s decision in Concepcion does not permit district courts to disregard applicable statutory mandatory minimums. Accordingly, the Second Circuit affirmed the district court’s judgment imposing an eight-year supervised release term. View "United States v. VanHoesen" on Justia Law

Cory Martin was charged with murder-for-hire, conspiracy to commit murder-for-hire, fraud, and identity theft after he killed Brandy Odom in April 2018. Martin’s then-girlfriend, Adelle Anderson, had taken out life insurance policies on Odom and promised Martin the proceeds upon Odom’s death. Following the murder, Anderson attempted to collect on the fraudulent policies but was unsuccessful. Law enforcement discovered Odom’s remains, secured Anderson’s cooperation, and prosecuted Martin based in large part on Anderson’s testimony.The case was heard in the United States District Court for the Eastern District of New York. At trial, Martin argued Anderson was the mastermind and that he was uninvolved, but the jury rejected this, finding Martin guilty on all counts. Anderson, having cooperated, pleaded guilty in a separate proceeding and received probation due to her history of abuse and other mitigating factors. Martin was sentenced to life imprisonment for the murder-for-hire offenses, along with additional sentences for the fraud and identity theft charges. He appealed, challenging the sufficiency of the evidence, the adequacy of the jury instructions, the inclusion of an aiding-and-abetting instruction, and alleging spillover prejudice affecting his other convictions.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 evidence was sufficient to support the murder-for-hire convictions under 18 U.S.C. § 1958, clarifying that the statute’s “consideration” requirement does not demand a formal employment relationship but rather a reciprocal inducement—an exchange of the murder for a promise of pecuniary value. The Second Circuit also found the jury instructions were proper, the aiding-and-abetting instruction was justified, and no impermissible spillover prejudice had occurred. The district court’s judgment was affirmed in all respects. View "United States v. Martin" on Justia Law

The case centers on whether John A. Sarcone III lawfully served as Acting U.S. Attorney for the Northern District of New York. After the departure of the Senate-confirmed U.S. Attorney, Sarcone was appointed as Interim U.S. Attorney for 120 days under 28 U.S.C. § 546. When his term expired, the district court did not appoint a permanent replacement, leaving the office vacant. The Department of Justice then reassigned the prior First Assistant to another role and designated Sarcone as the new First Assistant (FAUSA), claiming this made him Acting U.S. Attorney under the Federal Vacancies Reform Act of 1998 (FVRA). Sarcone subsequently issued two grand jury subpoenas to the New York State Attorney General’s Office regarding investigations into the National Rifle Association and Donald J. Trump.The United States District Court for the Northern District of New York granted the New York Attorney General’s motion to quash the subpoenas, holding that Sarcone had not lawfully become Acting U.S. Attorney under the FVRA since he was not the First Assistant at the time the vacancy arose. The court also found that the Attorney General’s general delegation of all U.S. Attorney duties to Sarcone was an impermissible circumvention of the FVRA. The court disqualified Sarcone from further involvement in the investigations.The United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The court held that the FVRA only permits automatic succession by a First Assistant who is already in office when the vacancy arises. It further held that a general delegation of all duties is not a lawful means to install an acting official, as it would undermine the FVRA’s exclusivity provision. Because the government did not substantively contest Sarcone’s disqualification on appeal, the court treated that issue as forfeited and affirmed the district court’s order. View "In re Grand Jury Subpoenas to the Office of the New York State Attorney General" on Justia Law

A parent of a teenager with developmental and physical disabilities challenged the adequacy of the educational services provided by a public school district under the Individuals with Disabilities Education Act (IDEA). The school district prepared an individualized education plan (IEP) for the child, but the parent disagreed and placed the child in a private school specializing in services for students with special needs. The parent filed administrative complaints for three consecutive school years (2022–23, 2023–24, and 2024–25), alleging the school district failed to provide a free appropriate public education (FAPE). The administrative process involved hearings before an Impartial Hearing Officer (IHO) and appeals to a State Review Officer (SRO), resulting in varied outcomes regarding whether the district must reimburse or directly fund the private placement.The litigation moved to the United States District Court for the Southern District of New York after the parent filed an amended complaint seeking enforcement of administrative decisions and a preliminary injunction compelling the district to fund the private placement. The district court dismissed the complaint, finding the parent had failed to exhaust administrative remedies under the IDEA for the 2023–24 and 2024–25 school years and had not plausibly alleged an exception to this requirement, such as a violation of the IDEA’s stay-put provision. The court also denied the motion for a preliminary injunction as moot.On appeal, the United States Court of Appeals for the Second Circuit held it had jurisdiction because the parent disclaimed any intent to amend the complaint. The appellate court affirmed the district court’s dismissal regarding the 2023–24 school year, finding no plausible allegation that the stay-put provision was violated and agreeing that administrative remedies were not exhausted. With respect to the 2024–25 school year, the court dismissed the appeal as moot because the parent had already obtained all requested relief through subsequent administrative proceedings and because the school year had ended. View "Juca v. Banks" on Justia Law

A Swedish government agency managing a public pension fund initiated a consolidated class action for securities fraud under Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5. The claims were brought against a third-party auditor and several former executives of a New York-based, federally insured commercial bank, which collapsed in 2023 after significant losses tied to a shift into cryptocurrency banking. The plaintiff alleged that the auditor and executives made false statements regarding the bank’s liquidity and risk management, leading to artificial inflation of the bank’s stock price and subsequent investor losses when the bank failed.After the bank’s collapse, the Federal Deposit Insurance Corporation (FDIC) was appointed as receiver. The FDIC intervened in the case and moved to dismiss, arguing that, under the Succession Clause of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA), it had succeeded to all rights of the bank’s stockholders regarding the institution and its assets, thus “owning” the securities fraud claims. The United States District Court for the Eastern District of New York agreed and dismissed the complaint for lack of prudential standing, concluding that the claims had transferred to the FDIC and that the plaintiff had not exhausted required administrative remedies.On appeal, the United States Court of Appeals for the Second Circuit reviewed the statutory interpretation of the Succession Clause. The court held that the Clause does not transfer to the FDIC individual securities fraud claims brought under Section 10(b) and Rule 10b-5, as these are not rights held by stockholders in their capacity as such, but rather as purchasers of securities. Additionally, the court found that administrative exhaustion was not required, as the claims were not against the failed bank or the FDIC as receiver. The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings. View "Fonden v. FDIC" on Justia Law

A native of Hong Kong and citizen of China, the petitioner was admitted to the United States as a lawful permanent resident in 1979. He was later convicted in federal court of conspiracy to import heroin, but received a waiver of deportation. Subsequently, he pleaded guilty in New Jersey Superior Court to theft by deception, a disorderly persons offense, and was fined $200. He also pleaded guilty in New York Supreme Court to forgery in the second degree, receiving probation and a fine. The Department of Homeland Security initiated removal proceedings, asserting that he was removable for having been convicted of two crimes involving moral turpitude not arising from a single scheme.An Immigration Judge denied his motion to terminate proceedings, finding both state offenses constituted crimes involving moral turpitude and that the New Jersey theft by deception offense qualified as a “conviction” under the Immigration and Nationality Act. The Board of Immigration Appeals (“BIA”) affirmed, and after various remands to address specific issues—including whether the New York offense categorically qualified as a crime involving moral turpitude—the BIA again dismissed his appeal. The petitioner sought review in the United States Court of Appeals for the Second Circuit, which initially denied relief by deferring to the BIA’s interpretation under Chevron U.S.A. Inc. v. Natural Resources Defense Council. The Supreme Court then vacated that judgment and remanded for reconsideration in light of Loper Bright Enterprises v. Raimondo, which held courts must independently interpret statutes without deferring to agency interpretations.On remand, the United States Court of Appeals for the Second Circuit held that a “conviction” under 8 U.S.C. § 1101(a)(48)(A) requires a formal judgment of guilt resulting from a criminal proceeding with minimum constitutional protections and culminating in a criminal sentence. Applying this standard, the court found the petitioner’s New Jersey offense met these criteria and denied his petition for review. View "Wong v. Blanche" on Justia Law

A defendant, while on federal supervised release for a prior child pornography conviction, was found in possession of an unauthorized smartphone, which led authorities to discover significant amounts of child pornography, including images and videos depicting two minor brothers whom he had sexually abused over several months. The ensuing investigation and trial revealed repeated sexual exploitation of both boys. The defendant was indicted on four federal charges: two counts of sexual exploitation of a child, one count of receipt of child pornography, and one count of committing a felony while a registered sex offender. The indictment also cited a prior 2010 New York state conviction for first-degree criminal sexual act by forcible compulsion involving a 14-year-old boy.The United States District Court for the Northern District of New York conducted a jury trial, which resulted in guilty verdicts on all counts. The jury specifically found, with respect to the sexual exploitation charges, that the defendant had a prior sex conviction involving a minor. At sentencing, the district court imposed mandatory life sentences on the two exploitation counts under 18 U.S.C. § 3559(e)(1), a 40-year sentence for receipt of child pornography, and a consecutive 10-year sentence for committing a felony while a registered sex offender. The district court stated that, even absent the statutory life mandate, it would have imposed a sentence of 150 years.On appeal to the United States Court of Appeals for the Second Circuit, the defendant challenged only the imposition of the mandatory life sentences, arguing that his New York conviction did not categorically qualify as a “prior sex conviction in which a minor was the victim” under § 3559(e)(1). The Second Circuit held that the minor-victim requirement is circumstance-specific and was satisfied here. It further held that the New York statute was a categorical match to a “Federal sex offense” under the federal statute. The court affirmed the challenged judgment. View "United States v. Valder" on Justia Law