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

The plaintiff-Appellant, Kristen King, claimed that her employer, Aramark Services Inc., subjected her to a sex-based hostile work environment, discrimination, and retaliation in violation of the New York State Human Rights Law and Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed King’s claims. However, the United States Court of Appeals for the Second Circuit affirmed the lower court’s decision on the New York State Human Rights Law claims but vacated the decision on the Title VII claims.The Court of Appeals agreed with the lower court that the impact of Aramark’s alleged discriminatory acts were only incidentally felt in New York. Regarding the Title VII hostile work environment claim, the court found that King’s termination was not only a discrete act supporting a distinct claim for damages, but also part of the pattern of discriminatory conduct that comprises her hostile environment claim. The court held that because King’s termination occurred within the limitations period, the continuing violation doctrine rendered King’s hostile work environment claim timely. Therefore, the court affirmed the lower court’s dismissal of King’s New York State Human Rights Law claims but vacated the dismissal of King’s Title VII claims and remanded the case for further proceedings on those claims. View "King v. Aramark Services Inc." on Justia Law

The United States Court of Appeals for the Second Circuit heard an appeal by Christopher Callahan against a judgment by the United States District Court for the Eastern District of New York. The district court had granted summary judgment to Suffolk County Police Officer Thomas Wilson and the County of Suffolk on claims related to the death of Callahan's brother, Kevin Callahan, which Callahan argued violated excessive force regulations under 42 U.S.C. § 1983. The appellate court ruled that the district court violated the mandate rule by not conducting a new trial as earlier instructed by the appellate court. The court found that there were disputed issues of material fact regarding Wilson's entitlement to qualified immunity, thus summary judgment was not warranted. However, the appellate court affirmed the district court's denial of Callahan's motion to amend his complaint to add a state law claim for battery. The case was remanded for a new trial. View "Callahan v. County of Suffolk" on Justia Law

The United States Court of Appeals for the Second Circuit heard an appeal involving Timothy Daileader, the independent director and manager of an affiliated group of companies, collectively known as "Oaktree," which were in financial distress. Daileader was seeking coverage from his insurer, Certain Underwriters at Lloyds London Syndicate 1861 (Syndicate 1861), for his defense in litigation involving Oaktree. However, Syndicate 1861 denied Daileader’s insurance claim. Daileader subsequently sought a preliminary injunction to enforce Syndicate 1861’s duty to defend. The United States District Court for the Southern District of New York denied Daileader’s motion, and Daileader appealed.The Court of Appeals affirmed the district court's decision, finding that the district court did not abuse its discretion in denying Daileader's motion for a preliminary injunction. The court held that Daileader had not shown a clear or substantial likelihood of success on the merits of his claim. The court also found that Daileader had not made a strong showing of irreparable harm. The court concluded that the Syndicate's refusal to continue paying under its policy did not disrupt the status quo of ongoing payments between the two parties. Therefore, the court determined that Daileader's desired injunction was mandatory and not prohibitory, thus subject to a more stringent standard for relief. View "Daileader v. Certain Underwriters" on Justia Law

John D. Whitfield's application for a job as a Youth Development Specialist with the New York City Administration for Children’s Services (ACS) was rejected. Whitfield alleged that the rejection was discriminatory and violated his First and Fourteenth Amendment rights. He initially challenged the decision in New York State Supreme Court through an Article 78 proceeding, which was dismissed. He then initiated a federal court action, which was also dismissed by the District Court on res judicata grounds. The District Court determined that the state court proceeding was a “hybrid” proceeding where Whitfield could have pursued the claims he raises in the federal action.The United States Court of Appeals for the Second Circuit disagreed, concluding that the state court adjudicated the matter as a pure Article 78 proceeding, not as a hybrid. Therefore, the state court lacked the power to award Whitfield the full scope of relief he now seeks in this action, and the District Court erred by dismissing the amended complaint on res judicata grounds. The judgment of the District Court was vacated and the case was remanded for further proceedings. View "Whitfield v. City of New York" on Justia Law

In the early morning hours of September 8, 2018, Mabior Jok was standing outside a bar in Burlington, Vermont, when Joseph Corrow, an officer of the Burlington Police Department, approached the group. The details of what happened next are fiercely disputed, but it's agreed that Corrow took Jok to the ground, resulting in Jok hitting his head, losing consciousness and being taken to the hospital. Jok was charged with disorderly conduct, but the charge was later dismissed. Subsequently, Jok brought a lawsuit against Corrow and others, alleging, among other things, that Corrow used excessive force against him in violation of his Fourth Amendment rights.Corrow moved for summary judgment on several grounds, including that he was entitled to qualified immunity. The United States District Court for the District of Vermont denied the motion, concluding that there were genuine disputes of material fact and hence, summary judgment could not be granted on the basis of qualified immunity. Corrow then filed an interlocutory appeal of the denial.The United States Court of Appeals For the Second Circuit found that Corrow failed to establish appellate jurisdiction because he continued to assert disputes of fact, and no pure question of law was presented for review. The Court concluded that it did not have jurisdiction to review the denial of qualified immunity as the denial was based on the presence of disputed material facts. Therefore, the interlocutory appeal was dismissed due to lack of appellate jurisdiction. View "Jok v. City of Burlington" on Justia Law

The plaintiff-appellant, Maurice Cotton, an inmate, filed a civil rights lawsuit against corrections officials at the Green Haven Correctional Facility. He alleged that he was wrongfully denied a transfer to another prison facility and retaliated against for filing grievances related to the transfer request. Cotton sought permission to proceed in forma pauperis (IFP), which allows indigent prisoners to pay filing fees through a structured payment plan linked to their prison accounts. The district court denied Cotton's IFP request, concluding that he had accumulated "at least three" strikes under the Prison Litigation Reform Act (PLRA) due to previous lawsuit dismissals.The United States Court of Appeals for the Second Circuit vacated and remanded the district court's decision, ruling that the district court erred in its interpretation of the three previous lawsuits. According to the appellate court, not all of Cotton's previous lawsuits counted as PLRA strikes. The court further explained that a dismissal under Heck v. Humphrey does not automatically count as a PLRA strike, arguing that the key consideration is whether the dismissal is based on the merits of the case or if it was merely a matter of timing or sequencing. Therefore, the appellate court concluded that the district court incorrectly denied Cotton's request for IFP status, warranting a remand for further proceedings. View "Cotton v. New York State Office" on Justia Law

In this case, five former customers of Peregrine Financial Group, Inc., a defunct futures commission merchant, filed a class action lawsuit against various defendants, including JPMorgan Chase Bank and National Futures Association. They claimed that their investments were wiped out due to fraudulent activities by Peregrine's CEO. The United States District Court for the Southern District of New York dismissed the federal claims as time-barred and declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The main issue addressed by the Second Circuit was whether a party could compel a district court to exercise subject-matter jurisdiction on a theory of jurisdiction that the party raised untimely.The Court held that a party may not do so. The Court distinguished between objecting to a federal court's exercise of jurisdiction, which a party could do at any stage in the litigation, and invoking the district court’s jurisdiction, which can be forfeited if not raised timely. Therefore, although federal courts must ensure they have jurisdiction, there is no corresponding obligation to find and exercise jurisdiction on a basis not raised by the parties. The Court concluded that the district court was within its discretion to decline to consider the untimely raised theory of jurisdiction. View "Behrens v. JPMorgan Chase Bank, N.A." on Justia Law

In this case, Aquila Alpha LLC (Aquila) appealed against a judgment from the United States District Court for the Eastern District of New York, affirming a bankruptcy court’s decision to deny Aquila’s motion to vacate a default judgment. The default judgment was obtained by Howard M. Ehrenberg, as the liquidating trustee of several debtors, and granted the debtors the ownership of a $23.7 million mortgage purchased by Aquila.Aquila argued that the default judgment should be vacated due to lack of personal jurisdiction and misapplication of the relevant Rule 60(b) factors. Aquila posited that it was improperly included in the First Amended Complaint without leave from the bankruptcy court and was not correctly served.However, the United States Court of Appeals for the Second Circuit affirmed the judgment of the district court. The appellate court concurred with the district court that the bankruptcy court had personal jurisdiction over the parties and had correctly applied the Rule 60(b) factors to deny Aquila’s motion to vacate default.The appeals court ruled that Aquila was correctly added to the First Amended Complaint as of right pursuant to Rule 15(a). The court also concluded that Aquila was properly served. It was further determined that Aquila’s default was willful, and the district court did not abuse its discretion in declining to set aside the default judgment. View "In re Orion HealthCorp, Inc." on Justia Law

The United States Court of Appeals for the Second Circuit reviewed a decision made by the United States District Court for the Southern District of New York. The plaintiff, Do No Harm, a membership organization, filed a suit against Pfizer Inc., alleging that a Pfizer fellowship program unlawfully excluded white and Asian-American applicants on the basis of race. The plaintiff sought a preliminary injunction, which was denied by the district court. The district court dismissed the case without prejudice because Do No Harm lacked Article III standing. The court reasoned that the organization failed to identify by name a single injured member.The Court of Appeals affirmed the district court's decision. It upheld that to establish standing under Article III, an association relying on injuries to individual members must name at least one injured member. The court also held that if a plaintiff fails to establish standing in the context of a motion for a preliminary injunction, the district court must dismiss their claims without prejudice rather than allowing the case to proceed if the plaintiff alleged sufficient facts to establish standing under the less onerous standard applicable at the pleading stage. View "Do No Harm v. Pfizer Inc." on Justia Law

The case being summarized involves two subclasses of current and former tipped employees at two New York City restaurants, who filed suit against the restaurants and their owners for violations of the New York Labor Law (NYLL) and the Federal Fair Labor Standards Act (FLSA). Prior to the trial, the parties agreed to present only the NYLL claims to the jury. The defendants appealed the partial final judgment in favor of the plaintiffs, arguing that the district court abused its discretion in exercising supplemental jurisdiction over the plaintiffs’ NYLL claims.The United States Court of Appeals for the Second Circuit found that because the plaintiffs’ federal claims were never formally dismissed, and the partial final judgment did not contain a disposition as to the federal claims, the matter had to be remanded to the district court. The purpose of the remand was to allow the district court to clarify the record as to the status of the FLSA claims. The court concluded that the lack of clarity concerning the FLSA claims impaired its ability to review the defendants’ challenges, leading to questions about the validity of the district court’s judgment certifying the appeal. The mandate was issued forthwith, with jurisdiction restored to the panel without the need for a new notice of appeal if, within thirty days, either party informed the court by letter that the district court had supplemented the record to clarify the status of the FLSA claims. View "Zivkovic v. Laura Christy LLC" on Justia Law