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

Mohsen Mahdawi, a Lawful Permanent Resident and undergraduate student at Columbia University, was arrested during his naturalization interview in Vermont. He was detained and served with a Notice to Appear, indicating that the U.S. Secretary of State had determined he was removable under the Immigration and Nationality Act. Mahdawi filed a habeas petition, claiming his arrest and detention were in retaliation for his advocacy on the war in Gaza, violating his First and Fifth Amendment rights. The district court issued a temporary restraining order (TRO) preventing his removal from Vermont and later granted his release on bail, finding he was neither a flight risk nor a danger to the community.The United States District Court for the District of Vermont initially granted Mahdawi’s emergency motion for a TRO and later extended it. The court also granted his motion for release on bail pending the resolution of his habeas petition. The government sought an emergency stay of these orders, arguing that the district court lacked jurisdiction over Mahdawi’s habeas petition and the authority to order his release.The United States Court of Appeals for the Second Circuit reviewed the case and denied the government’s motion for a stay. The court found that the government was unlikely to succeed on its arguments that the district court lacked jurisdiction over Mahdawi’s habeas petition and the authority to order his release. The court also concluded that the government had not demonstrated irreparable injury and that the balance of equities tipped in favor of denying the stay. Consequently, the government’s motion for a stay and request for a writ of mandamus were both denied. View "Mahdawi v. Trump" on Justia Law

A Turkish graduate student, Rümeysa Öztürk, was lawfully residing in Massachusetts on a student visa when she was arrested by plainclothes officers without warning on March 25, 2025. She was transported across state lines and eventually detained in Louisiana. Her counsel, unaware of her location, filed a habeas petition in the District of Massachusetts, alleging her arrest was based on an op-ed she co-authored. The petition was transferred to the District of Vermont after it was revealed she had been in Vermont during transit.The District of Vermont set a schedule for a bail hearing and to resolve the constitutional claims in the habeas petition. The court ordered the government to transfer Öztürk from Louisiana to Vermont to aid in these proceedings. The government appealed this order, seeking an emergency stay of the transfer.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the government failed to justify a stay. It determined that the District of Vermont was the proper venue for the habeas petition since Öztürk was in Vermont when the petition was filed. The court also found that the government was unlikely to succeed on its arguments that jurisdiction-stripping provisions of the Immigration and Nationality Act deprived the district court of jurisdiction over Öztürk’s detention challenge. Additionally, the court held that the government did not demonstrate irreparable injury absent a stay and that the balance of equities favored Öztürk.The Second Circuit denied the government’s motion for a stay, denied the request for a writ of mandamus, and vacated the administrative stay. The court ordered the government to comply with the district court’s transfer order within one week. View "Öztürk v. Hyde" on Justia Law

The plaintiff, Detrina Solomon, a subscriber to a digital video streaming service operated by Flipps Media, Inc. (doing business as FITE), alleged that her rights under the Video Privacy Protection Act (VPPA) were violated when FITE disclosed her streaming history to Facebook (now Meta Platforms, Inc.). The disclosed information included the titles and URLs of the videos she watched and her Facebook ID (FID), which is linked to her Facebook profile.The United States District Court for the Eastern District of New York dismissed Solomon's complaint under Rule 12(b)(6) of the Federal Rules of Civil Procedure, concluding that she failed to plausibly allege that FITE disclosed her personally identifiable information as defined by the VPPA. The district court also denied her leave to amend the complaint, noting that she had multiple opportunities to propose amendments but did not do so.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court adopted the "ordinary person" standard, which holds that personally identifiable information under the VPPA includes information that would allow an ordinary person to identify a consumer's video-watching habits. The court concluded that the information disclosed by FITE, consisting of video titles and FIDs, did not meet this standard because an ordinary person would not be able to use this information to identify Solomon's video-watching habits without additional effort or technological expertise.The court also found no abuse of discretion in the district court's denial of leave to amend, as Solomon's request was made only in a footnote and lacked any proposed amendments to address the deficiencies in her complaint. Thus, the judgment of the district court was affirmed. View "Solomon v. Flipps Media, Inc." on Justia Law

AMTAX Holdings 227, LLC ("AMTAX") filed a lawsuit against CohnReznick LLP ("CohnReznick") in federal court, alleging breach of fiduciary duty, professional negligence, unjust enrichment, and fraud. The dispute arose from CohnReznick's calculation of a purchase price for a property under a right of first refusal agreement, which AMTAX claimed excluded exit taxes required by Section 42 of the Internal Revenue Code. AMTAX argued that this exclusion violated the agreement and federal law.The United States District Court for the Southern District of New York dismissed AMTAX's complaint for lack of subject matter jurisdiction. The court applied the Grable-Gunn test to determine whether the state-law claims presented a substantial federal issue that would warrant federal jurisdiction. The district court concluded that AMTAX's claims did not meet the criteria for federal question jurisdiction, as they did not necessarily raise a substantial federal issue and allowing federal jurisdiction would disrupt the federal-state balance.The United States Court of Appeals for the Second Circuit reviewed the district court's decision de novo. The appellate court agreed with the lower court's application of the Grable-Gunn test, finding that AMTAX's claims were primarily based on contract interpretation rather than federal tax law. The court held that the federal issue was not substantial enough to warrant federal jurisdiction and that exercising jurisdiction would disrupt the balance of state and federal judicial responsibilities. Consequently, the Second Circuit affirmed the district court's dismissal of the case for lack of subject matter jurisdiction. View "AMTAX Holdings 227, LLC v. CohnReznick LLP" on Justia Law

Hamilton Reserve Bank, the beneficial owner of $250,490,000 in Sri Lankan government bonds, sued the Democratic Socialist Republic of Sri Lanka in the United States District Court for the Southern District of New York after Sri Lanka defaulted on the bonds. Over a year later, Jesse Guzman, Ultimate Concrete LLC, and Intercoastal Finance Ltd. sought to intervene, claiming Hamilton defrauded them by using their deposited funds to purchase the bonds and then refusing to allow them to withdraw their money.The district court denied the motion to intervene, holding that it lacked jurisdiction over the intervenors' claims. The court found that the claims did not derive from a "common nucleus of operative fact" with Hamilton's breach of contract claim against Sri Lanka, as required for supplemental jurisdiction under 28 U.S.C. § 1367(a).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 applied the correct "common nucleus of operative fact" standard for evaluating supplemental jurisdiction under Section 1367(a). The court concluded that the intervenors' claims, which involved a banking dispute with Hamilton, did not share substantial factual overlap with Hamilton's breach of contract claim against Sri Lanka. Therefore, the district court correctly determined it lacked jurisdiction over the intervenors' claims and denied their motion to intervene. View "Hamilton Reserve Bank v. Sri Lanka" on Justia Law

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

In 2020, Article 13 LLC filed a quiet title action against LaSalle National Bank Association (now U.S. Bank) to discharge a mortgage as time-barred, arguing that the statute of limitations had expired since a foreclosure action was commenced in 2007. U.S. Bank contended that the statute of limitations had not expired because the 2007 foreclosure action was invalid to accelerate the mortgage debt. The district court found a disputed issue of material fact regarding the validity of the 2007 foreclosure action and denied both parties' motions for summary judgment.Following the district court's ruling, New York enacted the Foreclosure Abuse Prevention Act (FAPA), which bars the defense of the invalidity of prior accelerations of mortgages in quiet title actions. Article 13 LLC moved for reconsideration, and the district court applied FAPA retroactively, granting summary judgment in favor of Article 13 LLC. U.S. Bank appealed, arguing that FAPA should not be applied retroactively and that such retroactivity would be unconstitutional under both the New York and U.S. Constitutions.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the questions of FAPA's retroactivity and its constitutionality under the New York Constitution were novel and essential to the resolution of the appeal. Consequently, the Second Circuit certified two questions to the New York Court of Appeals: whether Section 7 of FAPA applies to foreclosure actions commenced before the statute's enactment, and whether FAPA's retroactive application violates substantive and procedural due process under the New York Constitution. The Second Circuit deferred its resolution of the appeal pending the New York Court of Appeals' response. View "Article 13 LLC v. Lasalle Nat'l Bank Ass'n" on Justia Law

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

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