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

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The case involves defendants Dennis A. Bradley, Jr., and Jessica Martinez, who were charged with wire fraud and conspiracy to commit wire fraud in relation to Bradley’s 2018 campaign for Connecticut state senator. The government obtained two videos from videographers hired by Bradley, one 13-minute video and a 28-minute video, both of which were recorded at an event where Bradley announced his campaign. The government only became aware of the existence of the 28-minute video a week before the trial and promptly provided it to the defendants. Bradley moved to preclude the 28-minute video, arguing that the government had violated Rule 16(a)(1)(E) by not obtaining and producing the video earlier.The United States District Court for the District of Connecticut granted Bradley's motion, ruling that the government had violated its disclosure obligations by not obtaining and producing the 28-minute video at an earlier date. The government appealed this decision, arguing that it did not have the video in its possession, custody, or control until the eve of the trial.The United States Court of Appeals for the Second Circuit reversed the district court's order. The court held that neither Rule 16(a)(1)(E) nor the Connecticut District Court’s Standing Order imposed a requirement on the government to discover and turn over to a criminal defendant evidence that the government did not have in its physical possession, custody, or control, or that it did not have a duty to obtain from a third party. The case was remanded for further proceedings consistent with this opinion. View "United States v. Bradley" on Justia Law

Posted in: Criminal Law
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Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law

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The case involves Amazon.com Services LLC and the National Labor Relations Board (NLRB). The NLRB alleged that Amazon committed an unfair labor practice by discharging an employee for engaging in protected concerted activity. While the charge was pending before the Board, the Board sought temporary injunctive relief, including the employee’s reinstatement. The district court found "reasonable cause" to believe Amazon committed an unfair labor practice in terminating the employee. However, it concluded that ordering Amazon to cease and desist from committing certain violations of the Act was "just and proper," but that ordering Amazon to reinstate the employee was not.The district court's decision was appealed to the United States Court of Appeals for the Second Circuit. The appellate court found that the district court did not adequately explain why the cease-and-desist order was just and proper, particularly in light of its conclusion that the employee’s reinstatement was not. Therefore, the injunction was vacated in part. The court noted that the district court's lack of explanation for granting the cease-and-desist order, coupled with its explicit, undisputed findings in rejecting the request to order the employee's reinstatement, cast serious doubt on the propriety of the cease-and-desist order. View "Poor v. Amazon.com Services LLC" on Justia Law

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The case involves the United States government's appeal against a decision by the United States District Court for the Southern District of New York. The lower court had granted federal prisoner Joe Fernandez's motion for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A), reducing his sentence to time served and ordering his release. The court based its decision on two grounds: Fernandez's possible innocence due to the questionable credibility of the government's key witness, and the fact that Fernandez received a far longer sentence than his co-defendants.The government argued on appeal that the district court had abused its discretion. It contended that potential innocence is never a permissible "extraordinary and compelling reason" for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A), and that Fernandez's sentencing disparity is not an "extraordinary and compelling reason" for a sentence reduction in this case.The United States Court of Appeals for the Second Circuit agreed with the government's arguments. It held that a compassionate release motion is not the proper vehicle for litigating the issues Fernandez raised, irrespective of whether his mandatory life sentence is unjust. The court reversed the judgment of the district court. View "United States v. Fernandez" on Justia Law

Posted in: Criminal Law
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The case involves Travis Woods, a wheelchair user, who sued the Central New York Regional Transportation Authority and its subsidiary Centro of Oneida, Inc. (collectively, "Centro"), which operate the public bus service in Oneida County. Woods claimed that Centro violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act by failing to provide wheelchair-accessible bus stops. He argued that the district court erred in granting summary judgment to Centro on his claims.The United States District Court for the Northern District of New York granted summary judgment to Centro, dismissing Woods's complaint. The court found that Centro's paratransit service and its flexible pick-up and drop-off policy were reasonable accommodations providing meaningful access to Centro’s bus service.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court found that Woods's claims under sections 12147 and 12148 of the ADA failed as a matter of law. The court concluded that Woods had not shown that the altered portions of Centro’s bus stops were inaccessible or that Centro’s bus service was not readily accessible to individuals with disabilities. The court also found that Woods had not established that any modifications to Centro’s policies, practices, or procedures were necessary to avoid discrimination or to provide program access. Therefore, the court affirmed the judgment of the district court. View "Woods v. Centro of Oneida, Inc." on Justia Law

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Link Motion Inc., a Chinese company incorporated in the Cayman Islands, filed a legal malpractice action against the law firm DLA Piper LLP (US) and one of its attorneys in the New York State Supreme Court. The case was related to a previous lawsuit filed by a shareholder of Link Motion, Wayne Baliga, in which DLA Piper represented Link Motion. The law firm removed the case to the United States District Court for the Southern District of New York, which dismissed Link Motion's complaint as time-barred and denied its motion to remand the case back to state court.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court lacked federal jurisdiction. The court found that the federal law standing question identified by the district court as embedded in Link Motion's malpractice claim did not fall within the narrow category of "disputed and substantial" questions of federal law permitting the exercise of federal jurisdiction over a state law claim. Therefore, the court vacated the district court's decision and remanded the case back to the state court. View "Link Motion Inc. v. DLA Piper LLP" on Justia Law

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Brandon Washington pleaded guilty to possession with intent to distribute cocaine base. At sentencing, the district court added a point to Washington's criminal history score for a prior state-court conviction for harassment, which was related to the sale of controlled substances from the same house involved in the current case. Washington appealed, arguing that the district court incorrectly determined his criminal history category under the United States Sentencing Guidelines by improperly assessing a criminal history point for the prior harassment conviction.The district court had determined that the harassment conviction was similar to the current offense of possession with intent to distribute, and thus, under section 4A1.2(c)(1)(B) of the Guidelines, a one-point increase to Washington’s total criminal history points was warranted. Washington was then sentenced to sixty months’ imprisonment, followed by six years’ supervised release.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The appellate court agreed with the district court that Washington’s harassment conviction and his current offense were similar under section 4A1.2(c)(1)(B) of the Guidelines. Both offenses arose from the same conduct – the sale of controlled substances – and both offenses were committed at the same house. Therefore, the district court did not err in adding the extra criminal history point. The court also dismissed Washington's other arguments regarding the calculation of his criminal history score. View "United States v. Washington" on Justia Law

Posted in: Criminal Law
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The case involves Roman Sharikov, an employee of Philips Medical Systems MR, Inc., who was terminated after refusing to comply with the company's COVID-19 health and safety policies, including a vaccination mandate. Sharikov alleged that Philips discriminated against him because it regarded him as having a disability or a record of a disability and retaliated against him after he objected to the measures.The United States District Court for the Northern District of New York dismissed Sharikov's claims, stating that he failed to state a claim upon which relief could be granted. The court found that Philips' company-wide COVID safety and vaccine policies did not infringe on Sharikov's rights under the Americans with Disabilities Act (ADA). The court also concluded that Sharikov failed to plead a plausible retaliation claim because the company-wide policies that he failed to comply with, resulting in the termination of his employment, were in place before he began his alleged protected activity.On appeal, the United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The court agreed that Philips' company-wide COVID-19 health and safety measures did not discriminate against Sharikov under the ADA. The court also found that Sharikov failed to establish a causal connection between his protected activity and his termination, thus failing to state a plausible retaliation claim. View "Sharikov v. Philips Medical Systems MR, Inc." on Justia Law

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The case revolves around Aleksandra Malgorzata Stankiewicz, a lawful permanent resident of the United States, who was convicted in 2003 for violating a New Jersey statute that criminalizes distributing a controlled substance on or near school property. In 2018, removal proceedings were initiated against her, with the immigration judge and the Board of Immigration Appeals (BIA) concluding that her conviction was an aggravated felony, making her both removable and ineligible to apply for cancellation of removal.The BIA dismissed Stankiewicz's appeal, maintaining its reasoning that her conviction was an aggravated felony. Stankiewicz then petitioned the United States Court of Appeals for the Second Circuit for review of the BIA's decision.The Second Circuit Court of Appeals held that Stankiewicz's conviction under the New Jersey statute is not an "aggravated felony" under federal law. The court applied the "categorical approach," comparing the state law to any federal controlled substance offense that is a felony subject to a prison sentence greater than one year. The court found that neither of the parties' proposed federal analogs categorically matches the New Jersey statute. The court therefore granted Stankiewicz's petition for review, vacated the agency’s ruling, and remanded the case to the BIA for further proceedings. View "Stankiewicz v. Garland" on Justia Law

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This case involves two legal permanent residents, Carol Williams Black and Keisy G.M., who were detained by the U.S. government for several months without a bond hearing under the authority of 8 U.S.C. § 1226(c), pending the conclusion of their separate removal proceedings. Black and G.M. each sought habeas relief, asserting that their prolonged detentions without any bond hearing violated their Fifth Amendment rights to due process. The district court granted Black's petition and he was released, while G.M.'s petition was denied.In the United States Court of Appeals for the Second Circuit, the court concluded that the constitutional guarantee of due process precludes a noncitizen’s unreasonably prolonged detention under section 1226(c) without a bond hearing. The court affirmed the district court’s judgment granting habeas relief to Black, concluding that the district court properly required the government to show the necessity of his continued detention by clear and convincing evidence. As to G.M., the court concluded that his detention had become unreasonably prolonged and reversed the district court’s judgment denying habeas relief. View "Black v. Decker" on Justia Law