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

A Medicaid recipient in her late 80s, suffering from serious health conditions, applied in 2019 for 24-hour at-home personal care services through New York’s Medicaid program. The state, which provides varying levels of in-home care to eligible Medicaid recipients, partners with private managed long-term care plans (MLTCPs) to assess needs and offer care plans. The plaintiff was initially offered only eight hours of daily care by all MLTCPs she applied to, though she believed she required around-the-clock assistance. Under New York’s regulations, individuals cannot immediately appeal the initial level of care offered; they must first enroll in the plan, request an increase, and only appeal if that request is denied. The plaintiff followed this process and ultimately received 24-hour care after subsequent assessments, but with a delay and a gap in retroactive reimbursement for services.The United States District Court for the Southern District of New York granted summary judgment to the defendants—the State's Health Commissioner and the MLTCP—holding that the plaintiff did not have a cognizable property interest in a particular level of care, and therefore no due process rights were implicated. The court also denied class certification. The plaintiff appealed these decisions.The United States Court of Appeals for the Second Circuit reviewed the case de novo. The Second Circuit disagreed with the District Court’s conclusion regarding the existence of a property interest. It held that New York’s laws, regulations, and practices substantially restrict discretion in determining eligibility for 24-hour personal care services, thereby creating a property interest for qualifying Medicaid recipients and triggering due process protections. However, the court determined that New York’s current appeals procedures, though delayed, are constitutionally adequate because the delay is modest, expedited procedures exist for urgent cases, and the overall private interests at stake are sufficiently protected. On this alternative ground, the Second Circuit affirmed the District Court’s grant of summary judgment to the defendants. View "Bellin v. McDonald" on Justia Law

The case involves allegations by two relators, acting on behalf of the United States, that Amazon.com, Inc. and Amazon.com Services, LLC facilitated and conspired with foreign manufacturers to submit false records to the U.S. government. The relators claimed that these manufacturers, who sold fur products via Amazon’s platform, provided false information on Customs Declarations to avoid paying mandatory tariffs and inspection fees on imported fur products. According to the complaint, Amazon was not the importer of record, but the relators alleged that Amazon either knew or should have known about the fraudulent conduct due to discrepancies in documentation and the absence of required forms, and that Amazon nonetheless continued to market, store, and deliver the products.The United States District Court for the Southern District of New York reviewed the relators’ second amended complaint under Federal Rule of Civil Procedure 12(b)(6). The court dismissed the claims, concluding that the relators failed to adequately allege that Amazon had the requisite knowledge or causation necessary for liability under 31 U.S.C. § 3729(a)(1)(G) (the “reverse false claims” provision of the False Claims Act), and failed to plead the essential elements of a conspiracy claim under § 3729(a)(1)(C), including an agreement to violate the statute and overt acts in furtherance of such a conspiracy.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal. The Second Circuit held that the relators did not plausibly allege that Amazon had actual knowledge, deliberate ignorance, or reckless disregard regarding the foreign manufacturers’ false claims, as required by the statute. The court also determined the relators had not alleged facts showing an agreement or overt act necessary to support a conspiracy claim. Thus, the district court’s judgment dismissing the complaint in its entirety was affirmed. View "United States of America v. Amazon.com, Inc." on Justia Law

A licensed medical doctor in New York was charged with unlawfully distributing controlled substances, specifically opioids, to multiple patients between 2014 and 2015. Evidence at trial showed the doctor continued prescribing large quantities of oxycodone and hydrocodone even after learning that patients were addicted, diverting medications, or abusing other substances. The doctor was repeatedly warned by insurers, pharmacies, and the state medical society about overprescribing.The United States District Court for the Eastern District of New York presided over the case. After a jury trial, the doctor was convicted on thirty-two counts of unlawful distribution of controlled substances in violation of 21 U.S.C. § 841. Following the Supreme Court’s decision in Ruan v. United States, the defendant argued the jury instructions were erroneous and sought acquittal or a new trial, but the district court denied these motions.On appeal, the United States Court of Appeals for the Second Circuit addressed three main issues: whether the district court’s jury instructions improperly used an objective rather than subjective standard of intent, whether expert testimony and evidence about New York’s medical standards were improperly admitted, and whether the defendant received ineffective assistance of counsel. The Second Circuit agreed the jury instruction on intent was erroneous under the new Ruan standard but held the error was harmless given overwhelming evidence of the defendant’s subjective intent. The court also found the evidentiary rulings proper, as the expert testimony assisted the jury without usurping its function. The ineffective assistance claim was deemed more appropriate for collateral review and not addressed on direct appeal. The Second Circuit affirmed the district court’s judgment. View "United States v. Parasmo" on Justia Law

A father, K.W., lost custody of his newborn son, K.A., when New York City’s Administration for Children’s Services removed the infant from his care without a court order, citing concerns about the mother’s history of neglect toward her other children. At the time, K.W. had not been accused of any abuse or neglect, and K.A. had been living with him since birth. The following day, the agency obtained a family court order for continued removal, but the petition did not cite any wrongdoing by K.W. and omitted key facts about his involvement as K.A.’s caretaker. As a result, K.W. was denied custody and granted only limited visitation for nearly three years, despite no allegations of unfitness. Both K.W. and K.A. suffered emotional harm from the prolonged separation.The United States District Court for the Southern District of New York granted a motion to dismiss all of the plaintiffs’ claims, ruling that they had not successfully stated a claim and that the defendant caseworker was entitled to qualified immunity. The district court also dismissed the claims against the Children’s Aid Society and its caseworker.On appeal, the United States Court of Appeals for the Second Circuit found that the plaintiffs stated viable claims on behalf of K.A. for unlawful seizure under the Fourth Amendment and for violation of procedural due process under the Fourteenth Amendment. The court concluded that qualified immunity did not protect the individual caseworker, Moody, for these claims. However, the court affirmed dismissal of K.W.’s individual procedural due process claim as time-barred, and upheld dismissal of all claims against the Children’s Aid Society and its caseworker. The Second Circuit reversed in part, affirmed in part, and remanded the surviving claims for further proceedings. View "K.W. v. The City of New York" on Justia Law

The plaintiffs challenged two provisions of New York’s Concealed Carry Improvement Act (CCIA): one that criminalizes carrying firearms on private property open to the public unless the owner has explicitly permitted it (the Private Property Provision), and another that prohibits firearm possession in “sensitive locations,” specifically public parks (the Public Parks Provision). Plaintiffs argued that these provisions violate the Second and Fourteenth Amendments. The Private Property Provision was challenged as applied to places open to the public, while the Public Parks Provision was subject to a facial challenge, with plaintiffs later attempting, unsuccessfully, to add an as-applied challenge concerning rural parks.The United States District Court for the Western District of New York permanently enjoined the State from enforcing the Private Property Provision as applied to private property open to the public, finding it unconstitutional because it was not consistent with the nation’s historical tradition of firearms regulation. The district court, however, granted summary judgment to the State on the Public Parks Provision, concluding that it was facially constitutional since historical analogues supported restrictions on firearms in public parks. The district court declined to consider plaintiffs’ as-applied challenge to the parks provision, ruling that this argument had not been properly raised.The United States Court of Appeals for the Second Circuit reviewed both appeals. It affirmed the permanent injunction against the Private Property Provision, holding that the State failed to show that the restriction is consistent with the historical tradition of regulating firearms, as required by New York State Rifle & Pistol Association, Inc. v. Bruen. The court also affirmed the judgment in favor of the State on the Public Parks Provision, finding it constitutional as applied to urban parks, and declined to consider the as-applied challenge regarding rural parks since it had not been raised below. View "Christian v. James" on Justia Law

Union Plaintiffs, comprised of two labor organizations, challenged the federal government's termination of approximately $400 million in funding to Columbia University and its demand for significant reforms at the institution. Columbia University was not a party in the lawsuit. The plaintiffs sought injunctive relief to restore funding, prevent enforcement of the government’s reform demands, protect future grants and contracts, and recover damages.The United States District Court for the Southern District of New York denied the plaintiffs’ motion for a preliminary injunction and dismissed the case for lack of standing. After this dismissal, the plaintiffs appealed to the United States Court of Appeals for the Second Circuit. While the appeal was pending, Columbia and the government reached an agreement whereby most of the disputed funding was restored and Columbia agreed to implement certain reforms. Following this, the plaintiffs withdrew their requests for prospective equitable relief and damages, citing changed circumstances.The United States Court of Appeals for the Second Circuit reviewed a joint motion from both parties to dismiss the appeal, vacate the district court’s order, and remand with instructions to dismiss the case as moot. The court held that the case was moot for reasons not fairly attributable to the plaintiffs and granted the joint motion in full. The court dismissed the appeal as moot, vacated the district court’s order, and remanded with instructions to dismiss the case as moot, emphasizing that vacatur was appropriate due to circumstances beyond the plaintiffs’ control and the agreement between the parties. View "Am. Ass'n of Univ. Professors v. Department of Justice" on Justia Law

A Puerto Rican international banking entity, which operated under an offshore charter and was regulated by Puerto Rico’s Office of the Commissioner of Financial Institutions, maintained a master account with the Federal Reserve Bank of New York. In 2019, following a federal investigation into potential anti-money laundering violations involving a Venezuelan client, the entity’s offices were raided and its account was temporarily suspended. After the investigation concluded with a fine and compliance improvements, the account was restored under stricter risk-mitigation terms. However, in 2022 and 2023, the Federal Reserve Bank determined the entity had not met required compliance standards and ultimately terminated the master account, citing serious risk concerns related to money laundering and deficiencies in compliance programs.The entity sued in the United States District Court for the Southern District of New York, seeking to compel reinstatement of its account and damages. It claimed a statutory entitlement to a master account under the Federal Reserve Act, as amended by the Monetary Control Act, and brought claims under the Administrative Procedure Act, Mandamus Act, Declaratory Judgment Act, the Fifth Amendment, and New York contract law, among others. The district court denied preliminary relief and dismissed all claims, holding that the relevant statutes did not create a nondiscretionary entitlement to a master account and finding failures in both standing and the plausibility of the claims.The United States Court of Appeals for the Second Circuit affirmed. It held that the Federal Reserve Act does not grant depository institutions a statutory or nondiscretionary right to a master account; instead, regional Reserve Banks retain discretion over account access. The court further found that the plaintiff lacked standing to sue the Federal Reserve Board of Governors, failed to plausibly allege contract or constitutional claims, and that amendment of the complaint would be futile. The district court’s judgment was affirmed in all respects. View "Banco San Juan Internacional, Inc. v. Fed. Rsrv. Bank of N.Y., Bd. of Governors of the Fed. Rsrv." on Justia Law

A junior mortgage holder sought to quiet title against a senior mortgage on a Brooklyn property, arguing that the senior mortgage had become unenforceable under New York’s six-year statute of limitations. The senior mortgage had been accelerated by the filing of a foreclosure action in 2007, which was later discontinued without prejudice. The junior mortgage was subsequently assigned to the plaintiff, who argued that the limitations period had expired, thus barring any further foreclosure by the senior lienholder. The validity of the original 2007 foreclosure action, specifically whether it properly accelerated the debt, was disputed.The United States District Court for the Eastern District of New York denied both parties’ motions for summary judgment, citing a disputed issue of material fact regarding the standing of the entity that initiated the 2007 foreclosure. Shortly after this ruling, New York enacted the Foreclosure Abuse Prevention Act (FAPA), which, among other provisions, bars the defense that a prior acceleration was invalid in quiet title actions unless a court previously expressly determined invalidity. The district court, upon reconsideration, held FAPA applied retroactively and did not violate constitutional due process protections, and granted summary judgment to the junior mortgage holder.On appeal, the United States Court of Appeals for the Second Circuit certified questions to the New York Court of Appeals, which held that FAPA applies retroactively and that such application does not violate the New York Constitution’s due process guarantees. The Second Circuit then addressed whether retroactive application of FAPA violates substantive or procedural due process, the Contracts Clause, or the Takings Clause under the U.S. Constitution. The Second Circuit held that FAPA’s retroactive application does not violate any of these federal constitutional provisions and affirmed the district court’s judgment. View "Article 13 LLC v. LaSalle NationalBank Ass'n" on Justia Law

Federal authorities investigated a man after discovering that his co-defendant, who had been involved in two separate shooting incidents, had purchased a firearm for him. The defendant was charged with illegal receipt of a trafficked firearm based on this transaction. He pleaded guilty to that charge and was released pending sentencing, but while on bail, he was alleged to have participated in an assault and attempted robbery at a gas station, leading to the revocation of his bail.The United States District Court for the District of Connecticut held a sentencing hearing, during which it imposed a sentence of 30 months’ imprisonment—substantially above the advisory Sentencing Guidelines range of 12 to 18 months. The district court based its decision in part on the defendant’s alleged uncharged conduct while on bail and on the violent conduct of the co-defendant, specifically the two shootings. The district court reasoned that these incidents provided relevant context for the nature and circumstances of the defendant’s offense, even though there was no evidence that the defendant participated in or was aware of the co-defendant’s shootings, and no finding was made regarding the reliability or proof of the uncharged conduct by the defendant.On appeal, the United States Court of Appeals for the Second Circuit held that the district court plainly erred by considering the co-defendant’s prior violent activities in sentencing the defendant. The Second Circuit found there was no basis to attribute the co-defendant’s shootings to the defendant under any sentencing factor, as they were not part of a joint undertaking or conspiracy and were not shown to be relevant to the defendant’s conduct. The court vacated the sentence and remanded for a full resentencing, instructing the district court not to consider the co-defendant’s unrelated violent acts and clarifying the process for addressing any alleged uncharged conduct by the defendant. View "United States v. Dralle" on Justia Law

The case involves an individual who, in January 2020, sold fentanyl-laced heroin to an undercover police detective using his phone to arrange the sales. That same month, he shot someone in the knee and, after his arrest, was found with crack cocaine, heroin, and marijuana. He was indicted on five counts, including possession of ammunition after a felony conviction and drug-related offenses. He ultimately pled guilty to the ammunition charge under a plea agreement that included an express waiver of appeal for sentences within a specified range.The United States District Court for the Southern District of New York sentenced him to 105 months’ imprisonment and three years of supervised release, imposing several special conditions. Three of those conditions—electronic device searches upon reasonable suspicion, mandatory community service when unemployed, and participation in an outpatient mental health counseling program—were challenged by the defendant. In a prior appeal, the United States Court of Appeals for the Second Circuit vacated these three conditions due to insufficient explanation and remanded for further proceedings. On remand, the District Court elaborated on the reasons for imposing the conditions and reimposed them with some modifications.In the current appeal, the United States Court of Appeals for the Second Circuit reviewed the procedural and substantive reasonableness of these special conditions. The court held that the District Court did not abuse its discretion when imposing the challenged conditions, as they were sufficiently individualized and reasonably related to the relevant sentencing factors. The court also held that the defendant’s challenge to his term of imprisonment was barred by the appeal waiver in the plea agreement. Accordingly, the Second Circuit affirmed the judgment of the District Court. View "United States v. Jimenez" on Justia Law