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

The United States Court of Appeals for the Second Circuit addressed a dispute involving the Triborough Bridge and Tunnel Authority (TBTA) and several plaintiffs who had been fined for failing to pay tolls at TBTA crossings. The plaintiffs claimed that the fines were unconstitutional under the Eight Amendment’s Excessive Fines Clause and that TBTA was unjustly enriched under New York law. The court considered the case on appeal from the United States District Court for the Southern District of New York, which had granted summary judgment in favor of TBTA. The Court of Appeals affirmed the lower court's decision.The plaintiffs had failed to pay their tolls for various reasons, such as receiving bills at old addresses or having malfunctioning transponders. They then received substantial fines, which they eventually paid at reduced amounts. The main issue was whether these fines were excessive in relation to the seriousness of the offenses. The court applied the four-factor test from United States v. Bajakajian, which considers the nature of the offense, whether the defendant fits into the class of persons the law was designed for, the maximum potential sentence and fine, and the harm caused by the defendant's conduct.The court found that the fines were not excessive. It pointed out that the plaintiffs' violations were not willful or fraudulent, and that the fines were in line with those for similar offenses in other states. The court also noted that the fines helped TBTA prevent the harms it would suffer if people did not pay their tolls.Regarding the unjust enrichment claim, the court concluded that the plaintiffs had not shown that it was inequitable for TBTA to retain the fines. The plaintiffs' non-payment of tolls had violated TBTA regulations, and it was not inequitable for such violations to result in fines. Therefore, the court affirmed the lower court's grant of summary judgment in favor of TBTA on the unjust enrichment claims as well. View "Reese v. Triborough Bridge and Tunnel Authority" on Justia Law

In this case, the plaintiff, William Loomis, a truck driver who was injured in a car accident in New York, sought recovery from his employer's insurance company, ACE American Insurance Company, for his remaining damages after the underinsured driver's insurer paid out their policy limit. Loomis claimed that ACE failed to comply with both New York and Indiana laws requiring an insurer to provide underinsured motorist coverage.The United States Court of Appeals for the Second Circuit had to determine whether New York's laws requiring insurers to offer optional supplemental uninsured/underinsured motorist coverage could make an insurer liable when it fails to offer this coverage, and whether Indiana law requires an insurer to provide underinsured motorist coverage when the insured suffers damages in excess of the tortfeasor’s policy limit and has no other underinsured motorist coverage to cover damages up to a certain limit.The court concluded that under New York law, Loomis was not entitled to relief. While insurers are required to offer supplemental uninsured/underinsured motorist coverage in New York, this coverage is optional. Even if ACE violated New York law by failing to offer this coverage, Loomis's claim seeking to reform the insurance contract to include this coverage was not supported by New York law. Therefore, the court affirmed the lower court's grant of summary judgment on this claim.In terms of the claim under Indiana law, the court could not confidently predict how the Indiana Supreme Court would interpret the relevant statute, and therefore, certified questions to the Indiana Supreme Court. View "Loomis v. ACE American Insurance Company" on Justia Law

The United States Court of Appeals for the Second Circuit has decided an appeal from The Resource Group International Limited, TRG Pakistan Limited, Mohammed Khaishgi, and Hasnain Aslam against Muhammad Ziaullah Khan Chishti. The appellants sought to avoid arbitration proceedings initiated by the appellee, arguing that a later-executed release agreement superseded the arbitration agreement in the original Stock Purchase Agreement. The appellants also sought a preliminary injunction to halt the ongoing arbitration, but the District Court denied their request, asserting that they failed to show a likelihood of success on their claims and that they would suffer irreparable harm without the injunction.On appeal, the Circuit Court held that it had jurisdiction over the case, finding that the parties had chosen New York law to govern the arbitration proceedings, thereby bypassing the restrictions on appellate review under the Federal Arbitration Act. The court also held that the District Court had relied on an erroneous view of the law in concluding that the appellants failed to show a likelihood of success on the merits of their claims and that they would suffer irreparable harm. The court found that the release agreement, which contained a forum selection clause, superseded the Stock Purchase Agreement's arbitration clause. The court also clarified that being forced to arbitrate a non-arbitrable claim could constitute irreparable harm, particularly where attorneys' fees and arbitration costs could not adequately compensate the harm.As a result, the court vacated the District Court's decision and remanded the case for further proceedings. View "The Resource Group International Limited v. Chishti" on Justia Law

Plaintiff Joseph Kasiotis filed a class action lawsuit on behalf of himself and other similarly situated New York consumers against the New York Black Car Operators’ Injury Compensation Fund, Inc. (the “Fund”). The lawsuit alleged that the Fund improperly collected a surcharge on noncash tips paid by passengers to drivers providing livery or “black car” services from January 2000 until February 1, 2021. The United States District Court for the Southern District of New York ruled in favor of Kasiotis and the class, granting summary judgment on the unjust enrichment claim. On appeal, the United States Court of Appeals for the Second Circuit held that the Fund was statutorily permitted to collect a surcharge on noncash tips. The court's ruling was based on Article 6-F of the New York Executive Law, which unambiguously authorizes the Fund to impose a surcharge on noncash tips paid in connection with covered black car services. As such, the Second Circuit Court reversed the district court's order granting summary judgment in favor of Kasiotis and the class, and remanded the case with instructions to dismiss the unjust enrichment claim. View "Kasiotis v. N.Y. Black Car Operators' Inj. Comp. Fund, Inc." on Justia Law

In the case of Veronica-May Clark, an incarcerated transgender woman, against corrections officers who allegedly sexually assaulted her, the United States Court of Appeals for the Second Circuit affirmed the decision of the United States District Court for the District of Connecticut. The District Court had dismissed Clark's case as untimely, denying her claim for equitable tolling of the statute of limitations due to the effects of the abuse. The Court of Appeals found that the District Court did not err in holding an evidentiary hearing to resolve Clark’s equitable tolling claim and did not make any factual findings that infringed the Seventh Amendment. The court also found no abuse of discretion in the District Court's determination that Clark had failed to demonstrate circumstances that would warrant equitable tolling. In effect, the court ruled that Clark had not sufficiently proven that her trauma and fear of retaliation prevented her from filing the lawsuit within the required time frame. View "Clark v. Hanley" on Justia Law

The United States Court of Appeals for the Second Circuit dismissed an interlocutory appeal from the City of New Haven and three of its police officers (collectively, "the City"), who sought to challenge the district court's denial of their motion for summary judgment on the claims of Solomon Maye. Maye alleged that the City violated his constitutional rights by evicting him from his place of business. The district court had denied the City's motion for summary judgment, which was based on the defense of qualified immunity, because the motion was filed more than six months after the court's deadline for dispositive motions. The Court of Appeals held that a district court's denial of a motion for summary judgment as untimely is not a "denial of a claim of qualified immunity" that turns on an issue of law and is thus not subject to immediate appeal under the collateral order doctrine. Consequently, the Court of Appeals found no jurisdiction to hear the City's interlocutory appeal and dismissed it. View "Maye v. City of New Haven" on Justia Law

In this case, the United States Court of Appeals for the Second Circuit heard an appeal from Ezrasons, Inc., a company engaged in the garment trade, against The Travelers Indemnity Company. Ezrasons suffered a loss of insured goods exceeding $600,000 due to a fire at a warehouse owned by Chamad Warehouse, Inc., in Marion, North Carolina. Travelers paid $250,000, but declined to pay more, asserting that the policy's coverage was limited to $250,000 because the warehouse where the goods were destroyed was not an "Approved Location" under the policy. The district court ruled in favor of Travelers, finding that the warehouse was unambiguously not an "Approved Location" under the policy.On appeal, the Second Circuit Court found that the policy was ambiguous as to whether the warehouse where the destruction occurred was an "Approved Location." It further held that the district court erroneously excluded admissible evidence by which Ezrasons sought to prove that the warehouse was an "Approved Location." As the extrinsic evidence did not provide a basis for favoring either possible meaning of "Approved Location," the ambiguity should be resolved in favor of Ezrasons under New York law. Accordingly, the judgment was vacated and the case remanded with instructions to enter judgment in favor of Ezrasons. View "Ezrasons, Inc. v. Travelers Indemnity Co." on Justia Law

In 2011, Veronica-May Clark, an incarcerated transgender woman, was repeatedly sexually assaulted by corrections officer Thomas Hanley. More than seven years after the abuse, Clark filed a lawsuit against Hanley and other officers, alleging violations of her Eighth Amendment rights and seeking equitable tolling of the statute of limitations due to the traumatic effects of the abuse. After holding an evidentiary hearing on the issue of equitable tolling, the United States District Court for the District of Connecticut (Meyer, J.) denied Clark's claim for equitable tolling and dismissed her case as untimely. Clark appealed, claiming that the court improperly conducted factfinding at the pleading stage and violated her Seventh Amendment rights. The United States Court of Appeals for the Second Circuit affirmed the district court's ruling, finding that the court properly resolved Clark's equitable tolling claim and did not infringe her Seventh Amendment rights. View "Clark v. Hanley" on Justia Law

In a defamation lawsuit brought by E. Jean Carroll against former President Donald Trump, the United States Court of Appeals for the Second Circuit ruled that presidential immunity can be waived and that Trump had waived his presidential immunity by failing to raise it as an affirmative defense in his original response to Carroll's complaint. Carroll sued Trump for defamation after he publicly denied her accusation of sexual assault in the mid-1990s. The court affirmed the lower court's decision to deny Trump's motion for summary judgment and his request to amend his answer to include presidential immunity as a defense. The court also upheld the lower court's decision to strike Trump's presidential immunity defense from his answer to Carroll's amended complaint. The case was remanded back to the lower court for further proceedings. View "Carroll v. Trump" on Justia Law

In this case, a joint venture between Watershed Ventures, LLC and Patrick M. McGrath failed, leading to bankruptcy and litigation. McGrath and two investment vehicles he controlled sought coverage from Watershed's insurer, Scottsdale Insurance Company, under a directors and officers liability policy. Scottsdale denied coverage and sought a declaratory judgment as to its coverage obligations. McGrath countered with claims against Scottsdale and third-party claims against Watershed. The district court issued two summary judgment decisions. The first ruled that McGrath is an insured under the policy, while the second dismissed one of McGrath's counterclaims. The parties agreed to a "Stipulated Conditional Final Judgment Subject to Reservation of Rights of Appeal," which would become void if either of the district court’s two summary judgment rulings were partly vacated or reversed on appeal. The parties appealed, but the U.S. Court of Appeals for the Second Circuit dismissed both Scottsdale's appeal and McGrath's cross-appeal for lack of appellate jurisdiction, concluding that the Stipulated Conditional Final Judgment was not a "final decision" under 28 U.S.C. § 1291. The court reasoned that the Stipulated Conditional Final Judgment did not resolve all claims of all parties, was not entered under Federal Rule of Civil Procedure 54(b), and did not finally resolve whether Scottsdale breached its duty to defend under the policy. View "Scottsdale Ins. Co. v. McGrath" on Justia Law