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

In this case, Denise Kemp, a manager at Regeneron Pharmaceuticals, Inc., worked remotely in June 2016 to care for her child with a serious medical condition. Regeneron then restricted her remote work to one day per week and required her to use intermittent leave under the Family and Medical Leave Act (FMLA) for additional time away. Kemp sued Regeneron, alleging interference with her FMLA rights, and discrimination, retaliation, and constructive discharge under the New York State Human Rights Law (NYSHRL).The United States District Court for the Southern District of New York dismissed Kemp’s FMLA claim, reasoning that Regeneron had not denied her FMLA benefits and that the claim was time-barred. The court also dismissed her NYSHRL claims on the merits.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that an employer can violate the FMLA by interfering with an employee’s use of FMLA benefits, even if the benefits are ultimately granted. However, the court affirmed the dismissal of Kemp’s FMLA claim as time-barred, finding no evidence of a willful violation by Regeneron to extend the statute of limitations. The court also affirmed the dismissal of Kemp’s NYSHRL claims for discrimination and retaliation as time-barred, noting that Kemp was informed of the adverse actions before the relevant date. Lastly, the court upheld the dismissal of Kemp’s constructive discharge claim, concluding that her working conditions were not intolerable enough to compel resignation.The Second Circuit affirmed the District Court’s judgment, dismissing all of Kemp’s claims. View "Kemp v. Regeneron Pharm., Inc." on Justia Law

Robert Guthrie, a former employee of Rainbow Fencing Inc. (RFI), filed a lawsuit seeking unpaid wages and statutory damages for RFI's failure to provide wage notices and wage statements as required by New York law. Guthrie worked as a welder for RFI from 2014 to 2021 and claimed he was not paid for overtime hours. The district court entered a default judgment for the unpaid wages but dismissed Guthrie's claim for statutory damages, ruling that he lacked standing because he did not allege an injury-in-fact resulting from the failure to provide the required notices and statements.The United States District Court for the Eastern District of New York initially reviewed the case. The court granted a default judgment for Guthrie's unpaid wages but dismissed his claim for statutory damages due to lack of standing. The court concluded that Guthrie did not allege a concrete injury-in-fact caused by the absence of wage notices and statements, which is necessary to meet the case-or-controversy requirement of Article III.The United States Court of Appeals for the Second Circuit reviewed the case on appeal. The court affirmed the district court's decision, agreeing that Guthrie lacked standing to pursue statutory damages. The appellate court held that a plaintiff must allege a concrete injury-in-fact resulting from the statutory violation to have standing. Guthrie's general claims about potential harms did not suffice, as he failed to link these potential harms to any actual injury he experienced. Therefore, the court concluded that Guthrie did not meet the requirements for Article III standing and affirmed the dismissal of his claim for statutory damages. View "Guthrie v. Rainbow Fencing Inc." on Justia Law

Sarah Palin filed a defamation lawsuit against The New York Times and its former Opinion Editor, James Bennet, alleging that an editorial falsely linked her political action committee's map to the 2011 shooting of Congresswoman Gabrielle Giffords. The editorial claimed a "clear" and "direct" link between the map and the shooting, which Palin argued was defamatory.Initially, the United States District Court for the Southern District of New York dismissed Palin's complaint under Federal Rule of Civil Procedure 12(b)(6). The Second Circuit Court of Appeals reinstated the case in 2019, finding that Palin had plausibly stated a defamation claim. The case proceeded to trial, where the jury deliberated but the district court dismissed the case again under Federal Rule of Civil Procedure 50, ruling that Palin had not proven actual malice by clear and convincing evidence. Despite this, the jury returned a verdict finding the defendants "not liable."The United States Court of Appeals for the Second Circuit reviewed the case and found that the district court's Rule 50 ruling improperly intruded on the jury's role by making credibility determinations and weighing evidence. The appellate court noted several trial errors, including the exclusion of relevant evidence, an inaccurate jury instruction, and jurors learning of the district court's Rule 50 dismissal during deliberations. These issues undermined the reliability of the jury's verdict.The Second Circuit vacated the district court's Rule 50 judgment and the jury's verdict, remanding the case for a new trial. The appellate court emphasized the importance of the jury's role in determining credibility and weighing evidence, and found that the errors at trial necessitated a retrial. View "Palin v. New York Times Co." on Justia Law

Plaintiffs Moses Lugo and Cheryl Seaton, who use motorized wheelchairs, sued the City of Troy, New York, under the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973 (RA). They alleged that the city failed to maintain accessible pedestrian pathways. After discovery, Plaintiffs moved for summary judgment, while the City of Troy moved to dismiss the complaint for lack of standing or, alternatively, for summary judgment. The district court dismissed the complaint, finding the factual allegations insufficient to establish standing, without considering the full summary-judgment record.The United States District Court for the Northern District of New York dismissed the complaint based on the pleadings, concluding that the allegations were too generic to establish standing for city-wide remedies and that the specific obstacles mentioned had been remedied, thus mooting those claims. The court did not evaluate whether the evidence from discovery could establish standing.The United States Court of Appeals for the Second Circuit reviewed the case. The appellate court found that the district court erred by resolving the standing issue based solely on the pleadings rather than the full summary-judgment record. The appellate court held that the district court should have considered the evidence developed during discovery to determine whether Plaintiffs had standing. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings, instructing the lower court to evaluate the standing issue based on the complete evidentiary record and to determine if summary judgment is warranted or if Plaintiffs should be allowed to amend their complaint. View "Lugo v. The City of Troy, New York" on Justia Law

In the early 1990s, the Republic of Argentina issued collateralized bonds as part of a sovereign-debt-relief plan. Argentina retained reversionary interests in the collateral, which would revert to Argentina if the bonds were fully paid. However, Argentina defaulted on the bonds in 2001. Two decades later, holders of other defaulted Argentine bonds sought to attach these reversionary interests to satisfy judgments from Argentina’s default. They argued that the reversionary interests were used for commercial activity in the U.S., thus falling under an exception to the Foreign Sovereign Immunities Act (FSIA).The United States District Court for the Southern District of New York granted the attachment of the reversionary interests. During the appeal, the bonds matured, and the district court ordered the turnover of the reversionary interests to the bondholders. Argentina appealed both the attachment and turnover orders, leading to a consolidated appeal.The United States Court of Appeals for the Second Circuit affirmed the district court’s orders. The court held that Argentina’s reversionary interests were not protected by the FSIA because Argentina used them in commercial activity in the U.S. The court also found Argentina’s arguments against the turnover under New York law to be meritless. Additionally, the court ordered the parties to resubmit their briefs and appendices with narrow redactions, as the reasons for sealing the case were no longer compelling. The court denied the motion to supplement the record and granted the motion to limit the scope of sealing. View "Attestor Master Value Fund LP v. Republic of Argentina" on Justia Law

Andrew Delaney, a lawyer acting pro se, filed a Chapter 7 bankruptcy petition in the Eastern District of New York, listing $1,110 in assets and $44,434 in liabilities. He later sought to dismiss his petition, arguing that he was not a debtor as defined by 11 U.S.C. § 109(a) and that venue was improper. The bankruptcy court denied his motion, stating that dismissal would not be in the interest of all parties, particularly his creditors, and that the trustee had made progress in achieving a modest settlement.Delaney appealed the bankruptcy court's denial to the United States District Court for the Eastern District of New York. The district court dismissed his appeal for lack of appellate jurisdiction, concluding that the denial of a motion to dismiss a bankruptcy petition is not a final order that can be appealed as of right under 28 U.S.C. § 158(a)(1). The district court also treated Delaney's notice of appeal as a motion for leave to appeal under 28 U.S.C. § 158(a)(3) and denied it.The United States Court of Appeals for the Second Circuit reviewed the case and determined that it too lacked jurisdiction over Delaney’s appeal. The court held that the bankruptcy court's order denying Delaney's motion to dismiss was nonfinal because it did not finally dispose of any discrete disputes within the larger bankruptcy case. Consequently, the district court's dismissal of the appeal left significant further proceedings in the bankruptcy court. As a result, the Second Circuit dismissed Delaney’s appeal for lack of appellate jurisdiction. View "Delaney v. Messer" on Justia Law

The case involves a contract dispute between Kenneth E. Salamone and RUFSTR Racing, LLC (Plaintiffs) and Douglas Marine Corporation (Defendant). Plaintiffs contracted with Douglas Marine to purchase a custom-made race boat and trailer for $542,117, making payments totaling $501,500. Douglas Marine failed to deliver the boat on time, leading Plaintiffs to cancel the contract. Douglas Marine sold the boat and engines for $375,000 but only remitted $50,000 to Plaintiffs. Plaintiffs sued for breach of contract, seeking damages.The United States District Court for the Northern District of New York held a jury trial, which found in favor of Plaintiffs, awarding them $131,171 in damages. Plaintiffs moved to alter the judgment under Fed. R. Civ. P. 59(e), arguing the jury's calculation was fundamentally erroneous and should be increased to $451,500. The district court agreed, ruling that the jury's verdict constituted a fundamental error and increased the damages to $451,500. Douglas Marine appealed, arguing the district court erred in increasing the damages and in not instructing the jury on a mitigation-of-damages defense. They also challenged the court's personal jurisdiction.The United States Court of Appeals for the Second Circuit reviewed the case. It found merit in Douglas Marine's argument that the district court improperly increased the damages award, ruling that the jury's verdict did not constitute fundamental error. The appellate court reversed the amended judgment to the extent it increased the damages and remanded the case for entry of a second amended judgment consistent with the jury's original award of $131,171. The court affirmed the district court's denial of Douglas Marine's post-judgment motion to dismiss for lack of personal jurisdiction. View "Salamone v. Douglas Marine Corp." on Justia Law

Plaintiffs Marco Destin, Inc., 1000 Highway 98 East Corp., E&T, Inc., and Panama Surf & Sport, Inc. (collectively, “Marco Destin”) filed a lawsuit against agents of L&L Wings, Inc. (“L&L”), alleging that a 2011 stipulated judgment in a trademark action was obtained through fraud. Marco Destin claimed that L&L had fraudulently procured a trademark registration from the USPTO, which was used to secure the judgment. They sought to vacate the 2011 judgment under Federal Rule of Civil Procedure 60(d)(3) and requested sanctions and damages.The United States District Court for the Southern District of New York dismissed the action for failure to state a claim. The court found that Marco Destin had a reasonable opportunity to uncover the alleged fraud during the initial litigation. Specifically, the court noted that the License Agreement between the parties indicated that other entities might have paramount rights to the "Wings" trademark, suggesting that Marco Destin could have discovered the fraud with due diligence.The United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal for abuse of discretion. The appellate court confirmed that the district court acted within its discretion in declining to vacate the 2011 stipulated judgment. The court emphasized that Marco Destin had a reasonable opportunity to uncover the alleged fraud during the initial litigation and that equitable relief under Rule 60(d)(3) requires a showing of due diligence. The appellate court found no abuse of discretion in the district court’s conclusion that Marco Destin could have discovered the fraud through proper diligence.The Second Circuit affirmed the judgment of the district court, upholding the dismissal of Marco Destin’s claims. View "Marco Destin, Inc. v. Levy" on Justia Law

In 2019, Tamika Miller filed a qui tam action under the False Claims Act (FCA) against Citibank, alleging that the bank violated 2015 consent orders by hiding failures in its management of third-party risks to avoid paying regulatory fines. Miller claimed that Citibank altered audit reports to downplay compliance violations, thereby avoiding penalties. The United States declined to intervene in June 2020. In October 2020, Citibank entered into a new consent order with the Office of the Comptroller of the Currency (OCC) and paid a $400 million civil penalty. Miller sought a share of this penalty, arguing it was an alternate remedy for her qui tam claim.The United States District Court for the Southern District of New York granted Citibank's motion to dismiss Miller's complaint for failure to state a claim and denied her motion for a share of the $400 million penalty. The court found that Miller failed to allege an "obligation" to pay the government as required by the FCA and did not meet the particularity requirement of Federal Rule of Civil Procedure 9(b). The court also denied Miller's request for leave to amend her complaint, concluding that the deficiencies could not be cured by amendment.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court held that Miller failed to state a reverse false claim because she did not allege an established duty for Citibank to pay the government. The court also found that Miller's complaint did not meet the particularity requirement of Rule 9(b) as it failed to identify specific false statements or reports. Consequently, Miller was not entitled to a share of the $400 million penalty, and the district court did not err in denying her leave to amend her complaint. View "Miller v. United States, Citibank, N.A." on Justia Law

The United States Senate Select Committee on Intelligence generated a report on the Detention and Interrogation Program conducted by the CIA after September 11th. The Committee transmitted the report to various federal agencies. Douglas Cox submitted FOIA requests to these agencies for their copies of the report. The agencies denied the requests, arguing that the report is a congressional record, not an agency record, and thus not subject to FOIA disclosure.The United States District Court for the Eastern District of New York granted summary judgment in favor of the agencies, agreeing that the report is a congressional record not subject to FOIA. The court also denied Cox’s request for discovery.The United States Court of Appeals for the Second Circuit reviewed the case. The court applied the test from Behar v. United States Department of Homeland Security, which asks whether the non-covered entity (Congress) manifested a clear intent to control the documents. The court found that the Committee had a clear intent to control the report at the time of its creation, as evidenced by a June 2, 2009, letter. The court concluded that the Committee’s subsequent actions did not vitiate this intent. Therefore, the report remains a congressional record not subject to FOIA. The court also held that the district court did not abuse its discretion in denying discovery, as Cox failed to show bad faith or provide evidence that the exemptions claimed by the agencies were improper. The Second Circuit affirmed the district court’s judgment. View "Cox v. Dep't of Justice" on Justia Law