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

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

In the case before the United States Court of Appeals for the Second Circuit, Ateres Bais Yaakov Academy of Rockland (ABY) sued the Town of Clarkstown, George Hoehmann, CUPON Inc., and Citizens United to Protect Our Neighborhoods of Greater Nanuet Inc. ABY, a religious educational institution, planned to purchase property in Clarkstown, New York, to establish an Orthodox Jewish school. It alleged that the Defendants manipulated an ostensibly neutral building permit application and zoning appeals process to block this construction. The district court dismissed the complaint for lack of subject matter jurisdiction, concluding that ABY's religious discrimination and civil rights claims were not ripe as it had not received a final decision from the town’s Zoning Board of Appeals (ZBA) and that the lost-contract injury underpinning ABY’s tortious interference claim was not traceable to the Town Defendants.In this appeal, the Second Circuit disagreed with the district court. The Second Circuit found that the ZBA's refusal to adjudicate ABY's appeal of its permit application constituted a final decision for ripeness purposes. The court also determined that ABY had plausibly alleged a causal connection between the Town Defendants’ actions and the injuries resulting from ABY's lost contract with Grace Church. Therefore, the Second Circuit reversed the district court's judgment and remanded the case for further proceedings. View "Ateres Bais Yaakov Academy of Rockland v. Town of Clarkstoawn" on Justia Law

In a class action suit brought by George Mandala and Charles Barnett against NTT Data, Inc., the plaintiffs argued that NTT's policy of not hiring individuals with a felony conviction disproportionately impacted Black applicants, constituting disparate impact discrimination under Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed the plaintiffs' complaint, and that decision was affirmed by the United States Court of Appeals for the Second Circuit. The plaintiffs then filed a motion to vacate the dismissal judgment and sought leave to file a first amended complaint, which the district court denied as untimely under Federal Rule of Civil Procedure 60(b)(1).On appeal, the Second Circuit reversed the district court's decision, holding that the plaintiffs' motion should have been evaluated under Rule 60(b)(6) rather than Rule 60(b)(1). Rule 60(b)(6) allows for relief from a judgment under "extraordinary circumstances," which the court found to be present in this case. The court reasoned that the plaintiffs had not previously had a chance to amend their complaint, and that their decision to stand by their initial complaint was not unreasonable given that its sufficiency had been a point of dispute. Additionally, the court found that the proposed amendments to the complaint were not futile. Consequently, the Second Circuit ordered the case to be remanded to the district court for further proceedings consistent with its opinion. View "Mandala v. NTT Data, Inc." on Justia Law

In a consolidated case before the United States Court of Appeals for the Second Circuit, plaintiffs Ivan Antonyuk, Corey Johnson, Alfred Terrille, Joseph Mann, Leslie Leman, Lawrence Sloane, Jimmie Hardaway Jr., Larry A. Boyd, Firearms Policy Coalition Inc., Second Amendment Foundation Inc., Brett Christian, Micheal Spencer, and His Tabernacle Family Church Inc., sought to challenge certain provisions of New York's Concealed Carry Improvement Act ("CCIA"). The CCIA regulates the public carriage of firearms and includes licensing requirements and prohibitions on carrying firearms in "sensitive" and "restricted" locations. The plaintiffs argued that the provisions violated their First and Second Amendment rights.The court affirmed the preliminary injunction against the enforcement of certain provisions of the CCIA, but vacated the injunction in other respects. Specifically, the court upheld district court's injunctions with respect to the social media disclosure requirement, the application of restricted locations provision to private property open to the general public, and the application of the same provision to Pastor Spencer, the Tabernacle Family Church, its members, or their agents and licensees.However, the court vacated the injunctions in all other respects, concluding that either the district court lacked jurisdiction or that the challenged laws do not violate the Constitution on their face. The court rejected the plaintiffs' challenges to the CCIA's licensing requirements and sensitive locations provisions, holding that the laws did not infringe on the plaintiffs' Second Amendment rights.The court also held that the CCIA's restricted locations provision, which makes it a crime to possess firearms in a "restricted location", did not violate the plaintiffs' First and Second Amendment rights. Instead, the court found the provision to be a reasonable regulation consistent with the Second Amendment's protection of the right to keep and bear arms.The court's decision affirms in part, vacates in part, and remands the case for further proceedings. View "Antonyuk v. Chiumento" on Justia Law