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

Fourteen children who were removed from their biological parents by New York City officials are the plaintiffs in this case. After their removal, relatives sought certification to become foster or adoptive parents for these children, but their applications were denied due to criminal history or reports of child abuse or mistreatment. The children allege that New York’s certification scheme violates their substantive due process rights to family integrity and freedom from harm, and that procedural due process was violated because they were not given notice or an opportunity to challenge the denial of a relative’s application.The United States District Court for the Eastern District of New York dismissed the complaint. It ruled that the plaintiffs lacked standing, reasoning that most of the children did not have a cognizable injury since they were living with relatives, and others could not trace their separation from relatives to the defendants. The district court also found that the plaintiffs were asserting the rights of third-party relatives rather than their own, and that prudential standing barred their claims. The court did not address the procedural due process claims directly.On appeal, the United States Court of Appeals for the Second Circuit held that the plaintiffs have standing to pursue both substantive and procedural due process claims. The court found that denial of certified placement with a relative constituted a concrete and particularized injury, traceable to the defendants, and redressable by a favorable ruling. The court also determined that the plaintiffs were asserting their own rights, not those of their relatives, and rejected the district court’s prudential standing analysis. However, some claims were deemed moot: two plaintiffs are now in the care of a relative foster parent and another has aged out of foster care. Only one plaintiff has standing to challenge the adoption certification rules. The Second Circuit reversed in part, affirmed in part, and remanded the case for further proceedings. View "B.B. v. Hochul" on Justia Law

On February 1, 2018, Christopher Matusak was arrested in Scottsville, New York, after fleeing from police. Deputies from the Monroe County Sheriff’s Office, including Matthew Daminski, Stephen Murphy, and Sergeant Brian Unterborn, apprehended him using various forms of force, such as fist and knee strikes, pepper spray, and a taser, before handcuffing him. Matusak sustained injuries requiring hospitalization. He subsequently filed suit under 42 U.S.C. § 1983, alleging that the deputies violated his Fourth and Fourteenth Amendment rights by using excessive force during his arrest.The United States District Court for the Western District of New York presided over a jury trial. The jury determined that Deputy Daminski did not use excessive force, but found that Murphy and Unterborn did, awarding Matusak $200,000 in compensatory damages. However, the jury also found that, although Matusak did not actually pose a threat to officer safety, Murphy and Unterborn reasonably believed he did, and that Matusak was resisting their attempts to handcuff him. Based on the jury’s special verdicts, the district court granted judgment as a matter of law to Murphy and Unterborn, holding that they were entitled to qualified immunity because it was not clearly established that their conduct was unlawful under the circumstances.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Murphy and Unterborn were entitled to qualified immunity, reasoning that no clearly established law prohibited the use of significant force against an arrestee who was resisting and whom the officers reasonably, though mistakenly, believed posed a threat to officer safety. As it was objectively reasonable for the officers to believe their actions were lawful, the Second Circuit affirmed the district court’s judgment. View "Matusak v. Daminski" on Justia Law

The defendant pleaded guilty to traveling with the intent to engage in illicit sexual conduct, specifically traveling from Vermont to New York to have sexual intercourse with someone he believed to be a 15-year-old girl. The case involved extensive online communications, with the defendant sending explicit images and discussing plans that included showing pornography to the minor. At sentencing, the district court imposed fifteen years of supervised release with various standard and special conditions, some of which were not explicitly discussed or justified at the sentencing hearing.Following his conviction in the United States District Court for the Northern District of New York, the defendant appealed four discretionary conditions of supervised release. Two of these conditions (providing financial information to probation and submitting to suspicion-based searches), were added as “standard conditions” under a local standing order (General Order #23), but were not discussed in the presentence report or at the hearing. The remaining two challenged conditions prohibited access to adult pornography and imposed strict internet monitoring, including a provision allowing probation to limit the defendant to one internet-capable device.The United States Court of Appeals for the Second Circuit found that the district court erred by imposing the financial disclosure and suspicion-based search conditions without making an individualized assessment or providing reasons for their necessity, as required for special conditions of supervised release. These conditions were therefore vacated. The court affirmed the prohibitions on access to pornography and the general internet monitoring condition, but struck the provision allowing the probation office to limit the defendant to a single device, as this constituted an improper delegation of judicial authority. The case was remanded to the District of Vermont, which now has jurisdiction, for further proceedings consistent with this opinion. View "United States v. McAdam" on Justia Law

During the early months of the COVID-19 pandemic, an individual orchestrated a scheme to acquire large quantities of personal protective equipment (PPE), specifically masks, using investor funds. The purpose was to resell these materials at a markup, capitalizing on shortages and increased demand. The defendant managed the financial transactions, facilitated agreements with buyers (including an undercover FBI agent), and arranged for proceeds to be distributed among the participants.The United States District Court for the Eastern District of New York presided over the jury trial, where the defendant was convicted of conspiring to violate the Defense Production Act by accumulating designated scarce materials for resale above prevailing market prices. The defendant objected to the jury instruction defining "accumulate," arguing it should mean "to gather, collect, or accrue over a period of time," and moved to dismiss the charges on grounds of statutory vagueness, but the Magistrate Judge denied these motions. Upon appeal, the District Judge affirmed the conviction, holding that the statute was unambiguous and that "accumulate" did not require a temporal element.On further appeal, the United States Court of Appeals for the Second Circuit considered whether the term "accumulate" as used in Section 4512 of the Defense Production Act requires the government to prove that accumulation occurred over a period of time or involved withholding materials from the market. The court held that "accumulate" must be interpreted in accordance with its ordinary meaning—“to gather, collect, or accrue”—and does not require a prolonged period or withholding. The statutory text was found unambiguous, and the court rejected the defendant’s proposed interpretation and vagueness challenge. Accordingly, the Second Circuit affirmed the District Court’s judgment of conviction. View "United States v. Bulloch" on Justia Law

The individual in this case is a litigant who had previously been subject to a filing sanction by the United States Court of Appeals for the Second Circuit. The sanction required that, before submitting any future appeal or other proceedings in that court, the individual must first obtain leave of the court to file such materials. The current matter involved the individual’s attempt to initiate further proceedings related to a case involving a municipality.Previously, the United States District Court for the Western District of New York had been involved in the underlying litigation. Following actions in that court, the matter was appealed to the United States Court of Appeals for the Second Circuit. Subsequently, the Second Circuit imposed a leave-to-file sanction on the individual due to his filing history. After this sanction was imposed, the individual attempted to file a motion to recall the mandate in his ongoing case without first obtaining leave from the court, as required by the sanction order.Upon review, the United States Court of Appeals for the Second Circuit clarified that its prior leave-to-file sanction applies broadly. This includes not only new cases but also filings in ongoing and previously filed cases. The court denied the individual’s motion for leave to file and found the motion to recall the mandate moot. The main holding is that a litigant subject to a leave-to-file sanction must obtain permission from the court before submitting any new filings in any case, including those initiated before the sanction was imposed. View "Lettieri v. Town of Colesville" on Justia Law

Customs officers at JFK Airport conducted a random search of an aircraft arriving from Jamaica and discovered ten packages of cocaine hidden in the avionics compartment. After removing the drugs, officers replaced them with four “sham bricks,” one containing a transponder to signal movement. Paul Belloisi, an aircraft mechanic, drove to the plane in a maintenance vehicle, entered the avionics compartment, triggered the transponder, and exited empty-handed. Evidence at trial showed Belloisi was not assigned to the plane, possessed a jacket lined with slits likely for smuggling small items, and had suspicious communications with an individual named “Lester.” Belloisi claimed he was attempting to fix the air conditioning, but other testimony contradicted this account.The United States District Court for the Eastern District of New York presided over Belloisi’s jury trial, where he was convicted of conspiracy to possess a controlled substance with intent to distribute, conspiracy to import a controlled substance, and importation of a controlled substance. The trial court denied his post-trial motion for judgment of acquittal and sentenced him to 108 months in prison. Belloisi appealed, contending the evidence was insufficient to show he knew the smuggled items were controlled substances rather than other contraband.The United States Court of Appeals for the Second Circuit reviewed the case under the standard that a conviction must be supported by evidence sufficient for a rational juror to find each element beyond a reasonable doubt. The Second Circuit held that the government failed to prove that Belloisi possessed knowledge that the items in the compartment were controlled substances, rather than other contraband. Accordingly, the court reversed the convictions and remanded the case for entry of a judgment of acquittal. View "United States v. Belloisi" on Justia Law

A businessman from Kazakhstan alleged that he was wrongfully detained and psychologically coerced by the country’s National Security Committee into signing unfavorable business agreements, including waivers of legal claims and a forced transfer of valuable company shares. The business at issue, CAPEC, operated in Kazakhstan’s energy sector and held significant assets, some of which were allegedly misappropriated by fellow shareholders and transferred through U.S. financial institutions. The plaintiff claimed these actions harmed him economically, including the loss of potential U.S.-based legal claims.Following unsuccessful litigation in Kazakhstan, the plaintiff initiated suit in the United States District Court for the Eastern District of New York, seeking to invalidate the coerced agreements and recover damages under the Racketeer Influenced and Corrupt Organizations Act (RICO), the Alien Tort Statute, and other state and federal laws. The district court dismissed the complaint for lack of subject-matter jurisdiction, finding that the plaintiff, as a permanent resident alien, could not establish diversity jurisdiction against foreign defendants, that the alleged torts occurred outside the U.S., and that the plaintiff failed to allege a domestic injury required for civil RICO claims. The court denied leave to amend, determining that any amendment would be futile.The United States Court of Appeals for the Second Circuit reviewed the matter de novo, affirming the district court’s judgment. The Second Circuit held that claims against the National Security Committee were barred by the Foreign Sovereign Immunities Act, as its conduct was sovereign rather than commercial. For the individual defendants, the court found that the plaintiff failed to allege a domestic injury under RICO, as the harm and racketeering activity occurred primarily in Kazakhstan. The court further concluded that amendment of the complaint would have been futile. The judgment was affirmed. View "Yerkyn v. Yakovlevich" on Justia Law

Getty Images Holdings, Inc. became a publicly traded company after merging with CC Neuberger Principal Holdings II, a special purpose acquisition company. Alta Partners, LLC and CRCM Institutional Master Fund (BVI) Ltd., along with CRCM SPAC Opportunity Fund LP, acquired warrants to purchase Getty stock. The warrants’ exercise was governed by a warrant agreement requiring both an effective registration statement and a current prospectus for the underlying shares. After the merger, Getty filed two relevant registration statements: a Form S-4 and a Form S-1. Alta and CRCM attempted to exercise their warrants in August 2022, when Getty’s stock price was significantly higher than the warrant strike price, but Getty refused, claiming the contractual conditions for exercise were unmet.The United States District Court for the Southern District of New York reviewed breach of contract claims brought by Alta and CRCM. The court granted summary judgment for the plaintiffs, finding as a matter of law that the conditions of the warrant agreement had been satisfied. Specifically, it held the Form S-4 was an effective registration statement for the warrant shares and the accompanying prospectus was current at the time the plaintiffs attempted to exercise their warrants. The court awarded damages based on the stock price at the time of the breach but limited Alta’s recovery, denying damages for warrants purchased after Getty’s refusal to honor the redemption.The United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. It held that Getty breached the warrant agreement because the required registration statement and prospectus conditions were met on the relevant dates. The court concluded that damages should be calculated using the market price of the shares at the time of breach and upheld the limitation on Alta’s damages for post-breach warrant purchases. The affirmance applies to all aspects of the district court’s rulings challenged on appeal. View "Alta Partners, LLC v. Getty Images Holdings, Inc." on Justia Law

Federal law enforcement agents investigated the defendant after he sold crack cocaine to a confidential informant in three controlled buys in Suffolk County, New York. Based on these transactions, agents executed a search warrant at his residence and seized drugs, firearms, packaging materials, and cash. The defendant pleaded guilty in the United States District Court for the Eastern District of New York to possession with intent to distribute cocaine and cocaine base, and possession of firearms in connection with drug trafficking.At sentencing, the district court considered the defendant’s background and criminal history and imposed a sentence of 120 months’ imprisonment, followed by five years of supervised release. The court orally pronounced certain mandatory and special conditions of supervised release, but did not recite or specifically incorporate by reference the full set of standard conditions recommended by the U.S. Sentencing Guidelines or the Probation Department. The written judgment included thirteen standard conditions and several special conditions, some of which expanded on or added new requirements not mentioned orally.Nearly three years after judgment, the defendant filed a pro se notice of appeal. Although the appeal was untimely under Federal Rule of Appellate Procedure 4(b), the government did not timely raise the issue, and the United States Court of Appeals for the Second Circuit determined the objection was forfeited. The court reviewed the merits of the appeal and held that the district court erred by imposing the standard conditions and certain special conditions without proper oral pronouncement or clear judicial determination. The Second Circuit remanded the case with instructions to vacate the thirteen standard conditions and three special conditions (mental health treatment, substance abuse treatment, and search condition), allowing the district court to conduct further proceedings and potentially reimpose these conditions in compliance with procedural requirements. The judgment was otherwise affirmed. View "United States v. Harris" on Justia Law

The defendant was born and raised in Lebanon and was recruited into Hizballah, a designated foreign terrorist organization, in 1996. He received various forms of military-type training, including weapons, explosives, and surveillance, and participated in operations against Israeli targets. After moving to the United States in 2000, he continued his involvement with Hizballah by traveling back to Lebanon for further training and assignments. In 2004 and 2005, he received advanced explosives and surveillance training, including field exercises and site surveillance in Istanbul and New York City, where he documented potential targets for Hizballah. His activities with Hizballah ceased in spring 2005.The United States District Court for the Southern District of New York indicted the defendant in 2019 on multiple counts, including receiving military-type training from Hizballah (Count Three). After a jury trial, he was found guilty on Count Three and two other counts, and sentenced to ten years’ imprisonment for Count Three, with a sentencing enhancement under the United States Sentencing Guidelines for terrorism-related offenses. Neither the parties nor the district court recognized that the relevant statute (18 U.S.C. § 2339D) was enacted in December 2004, or that certain enhancements and waivers only applied to post-March 2006 conduct.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that although the district court erred by not instructing the jury to consider only post-enactment conduct, there was no reasonable probability the jury would have acquitted due to substantial evidence of post-enactment conduct. The court also concluded that the retroactive application of the statute of limitations waiver was permissible because the original limitation period had not expired. However, the court vacated the sentence, finding plain error in the application of the terrorism enhancement and remanded for resentencing. The convictions were affirmed, but the sentence was vacated and remanded. View "United States v. Saab" on Justia Law