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

Manoucheka Francois, a train conductor for Metro-North Commuter Railroad Company, was injured in a car crash while being transported by a taxi hired by her employer. The taxi driver, Michael Cellante, had consumed four to five shots of alcohol before picking her up. As a result, the taxi crashed, and Francois sustained injuries.Francois sued Metro-North under the Federal Employers’ Liability Act (FELA), alleging both direct liability for negligently hiring the impaired taxi driver and vicarious liability for the driver’s negligence. The United States District Court for the Southern District of New York granted summary judgment in favor of Metro-North on both theories. The court found no evidence that Metro-North could have foreseen the driver’s intoxication, thus negating direct liability. It also concluded that the driver’s act of drinking removed him from the scope of his agency, precluding vicarious liability.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court’s decision regarding direct liability, agreeing that Metro-North had no reason to foresee the driver’s intoxication. However, the court vacated the summary judgment on vicarious liability. It held that whether the driver acted within the scope of his agency while driving Francois, despite being impaired, presented a triable issue of fact. The court emphasized that in FELA cases, plaintiffs enjoy a relaxed burden of proof, and issues of agency and foreseeability should generally be decided by a jury.The Second Circuit thus affirmed the district court’s ruling on direct liability, vacated the ruling on vicarious liability, and remanded the case for further proceedings. View "Francois v. Metro-North Commuter Railroad Co." on Justia Law

The case revolves around Brad Packer, a shareholder of 1-800-Flowers.com, Inc. (FLWS), who alleged that Raging Capital Management, LLC, Raging Capital Master Fund, Ltd., and William C. Martin (collectively, the Appellees) violated Section 16(b) of the Securities Exchange Act of 1934. This section requires owners of more than 10% of a company's stock to disgorge profits made from buying and selling the company's stock within a six-month window. Packer claimed that the Appellees, as 10% beneficial owners of FLWS, engaged in such "short-swing" trading and failed to disgorge their profits. After FLWS declined to sue the Appellees, Packer filed a shareholder derivative suit on behalf of FLWS.The United States District Court for the Eastern District of New York dismissed Packer's suit, reasoning that he lacked constitutional standing because he did not allege a concrete injury. The District Court concluded that the Supreme Court's decision in TransUnion LLC v. Ramirez, which elaborated on the "concrete injury" requirement of constitutional standing, abrogated the Second Circuit's previous decision in Donoghue v. Bulldog Investors General Partnership. In Donoghue, the Second Circuit held that a violation of Section 16(b) inflicts an injury that confers constitutional standing.The United States Court of Appeals for the Second Circuit disagreed with the District Court's interpretation. The Appeals Court held that TransUnion did not abrogate Donoghue, and the District Court erred in holding that it did. The Appeals Court emphasized that a District Court must follow controlling precedent, even if it believes that the precedent may eventually be overturned. The Appeals Court found that nothing in TransUnion undermines Donoghue, and thus, the District Court erred in dismissing Packer's Section 16(b) suit. The Appeals Court reversed the District Court's judgment and remanded the case for further proceedings. View "Packer v. Raging Capital Management, LLC" on Justia Law

Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law

The case involves Amazon.com Services LLC and the National Labor Relations Board (NLRB). The NLRB alleged that Amazon committed an unfair labor practice by discharging an employee for engaging in protected concerted activity. While the charge was pending before the Board, the Board sought temporary injunctive relief, including the employee’s reinstatement. The district court found "reasonable cause" to believe Amazon committed an unfair labor practice in terminating the employee. However, it concluded that ordering Amazon to cease and desist from committing certain violations of the Act was "just and proper," but that ordering Amazon to reinstate the employee was not.The district court's decision was appealed to the United States Court of Appeals for the Second Circuit. The appellate court found that the district court did not adequately explain why the cease-and-desist order was just and proper, particularly in light of its conclusion that the employee’s reinstatement was not. Therefore, the injunction was vacated in part. The court noted that the district court's lack of explanation for granting the cease-and-desist order, coupled with its explicit, undisputed findings in rejecting the request to order the employee's reinstatement, cast serious doubt on the propriety of the cease-and-desist order. View "Poor v. Amazon.com Services LLC" on Justia Law

Link Motion Inc., a Chinese company incorporated in the Cayman Islands, filed a legal malpractice action against the law firm DLA Piper LLP (US) and one of its attorneys in the New York State Supreme Court. The case was related to a previous lawsuit filed by a shareholder of Link Motion, Wayne Baliga, in which DLA Piper represented Link Motion. The law firm removed the case to the United States District Court for the Southern District of New York, which dismissed Link Motion's complaint as time-barred and denied its motion to remand the case back to state court.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court lacked federal jurisdiction. The court found that the federal law standing question identified by the district court as embedded in Link Motion's malpractice claim did not fall within the narrow category of "disputed and substantial" questions of federal law permitting the exercise of federal jurisdiction over a state law claim. Therefore, the court vacated the district court's decision and remanded the case back to the state court. View "Link Motion Inc. v. DLA Piper LLP" on Justia Law

The Trustees of the New York State Nurses Association Pension Plan (the Trustees) and White Oak Global Advisors, LLC (White Oak) entered into an investment management agreement, which included an arbitration clause. The Trustees later brought several fiduciary duty claims against White Oak under the Employee Retirement Income Security Act (ERISA), which were resolved through arbitration. The arbitrator issued an award in favor of the Trustees, which the Trustees sought to confirm in the United States District Court for the Southern District of New York.White Oak appealed the confirmation, arguing that the district court lacked jurisdiction and that the court erroneously interpreted the award. The United States Court of Appeals for the Second Circuit affirmed the district court's jurisdiction, finding that the Trustees' petition to confirm the award was cognizable under ERISA § 502(a)(3). The court also affirmed the district court's interpretation of the award regarding the disgorgement of pre-award interest and the "Day One" fees. However, the court vacated and remanded the district court's confirmation of the disgorgement of White Oak's "profits," finding the award too ambiguous to enforce. The court also vacated and remanded the district court's order for White Oak to pay the Trustees' attorneys' fees and costs, finding the district court's findings insufficiently specific. View "Trustees of the NYSNAPP v. White Oak Glob. Adv." on Justia Law

The case involves a Ukrainian couple, Yasamin Karimi and Roman Tereshchenko, who divorced and disputed custody of their two children. Following Russia's invasion of Ukraine, Tereshchenko agreed to Karimi removing the children from Ukraine for safety reasons, but requested that she bring them to him in Dubai. Instead, Karimi took the children to undisclosed locations, including the United States. Tereshchenko filed a petition under the Hague Convention on the Civil Aspects of International Child Abduction for the return of the children. The District Court granted Tereshchenko’s petition and ordered the children returned to him in France, where he was currently residing.Karimi appealed the decision, challenging the District Court's jurisdiction and arguing that Tereshchenko had consented to the children's removal. The United States Court of Appeals for the Second Circuit affirmed the District Court's jurisdiction and rejected Karimi's argument that Tereshchenko had consented to the children's removal. The Court of Appeals also found that the District Court had erred in determining that the children would not be exposed to a grave risk of harm if they were returned to western Ukraine. However, the Court of Appeals concluded that the District Court was permitted to order the return of the children to Tereshchenko in a third country, France, as a temporary measure due to the grave risk of harm in Ukraine. The case was remanded to the District Court to modify the order to maintain the Ukrainian courts’ authority over an ultimate custody determination. View "Tereshchenko v. Karimi" on Justia Law

The case involves a dispute over the antitrust implications of a settlement agreement between Forest Laboratories, a brand manufacturer of the high-blood pressure drug Bystolic, and seven manufacturers of generic versions of Bystolic. The settlement agreement was reached after Forest Laboratories initiated patent-infringement litigation against the generic manufacturers. As part of the settlement, Forest Laboratories entered into separate business transactions with each generic manufacturer, paying them for goods and services.The plaintiffs, purchasers of Bystolic and its generic equivalents, filed a lawsuit against Forest Laboratories and the generic manufacturers, alleging that the payments constituted unlawful “reverse” settlement payments intended to delay the market entry of generic Bystolic. The plaintiffs' claims were dismissed twice by the United States District Court for the Southern District of New York for failure to state a claim.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court found that the plaintiffs failed to plausibly allege that any of Forest’s payments were unjustified or unexplained, instead of constituting fair value for goods and services obtained as a result of arms-length dealings. The court also held that the district court’s application of the pleading law was appropriate. The court concluded that the plaintiffs did not plausibly allege that Forest’s payments were a pretext for nefarious anticompetitive motives rather than payments that constituted fair value for goods and services obtained as a result of arms-length dealings. View "In re Bystolic Antitrust Litigation" on Justia Law

This case involves Commerzbank AG, a German bank, and U.S. Bank, N.A., an American bank. Commerzbank sued U.S. Bank, alleging that it had failed to fulfill its duties as a trustee for residential mortgage-backed securities (RMBS) that Commerzbank had purchased. The case revolved around three main issues: whether Commerzbank could bring claims related to trusts with "No Action Clauses"; whether Commerzbank's claims related to certificates held through German entities were timely; and whether Commerzbank could bring claims related to certificates it had sold to third parties.The district court had previously dismissed Commerzbank's claims related to trusts with No Action Clauses, granted judgment in favor of U.S. Bank on the timeliness of Commerzbank's claims related to the German certificates, and denied Commerzbank's claims related to the sold certificates. Commerzbank appealed these decisions.The United States Court of Appeals for the Second Circuit affirmed the district court's decisions on the timeliness of the German certificate claims and the denial of the sold certificate claims. However, it vacated the district court's dismissal of Commerzbank's claims related to trusts with No Action Clauses and remanded the case for further proceedings. The court found that Commerzbank's failure to make pre-suit demands on parties other than trustees could be excused in certain circumstances where these parties are sufficiently conflicted. View "Commerzbank AG v. U.S. Bank, N.A." on Justia Law

The case involves Jane Doe, who sued the Franklin Square Union Free School District on behalf of herself and her minor daughter, Sarah Doe. The lawsuit was filed after the school district refused to grant Sarah an exemption from a school mask mandate implemented in response to the COVID-19 pandemic. Jane Doe argued that the school district violated the Due Process Clause of the Fourteenth Amendment and her claims under the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act.The United States District Court for the Eastern District of New York dismissed Jane Doe's constitutional claim, concluding that the school district's conduct survived rational basis review. The court also dismissed her federal statutory claims for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA).On appeal, the United States Court of Appeals for the Second Circuit concluded that the school district did not violate Jane Doe or Sarah’s constitutional rights by denying their request for an accommodation. However, the court agreed with Jane Doe that she was not required to satisfy the exhaustion requirement of the IDEA and held that the district court erred in dismissing Jane Doe’s ADA and § 504 claims. The court affirmed in part and reversed in part the judgment of the district court and remanded the case for further proceedings. View "Doe v. Franklin Square Union Free Sch. Dist." on Justia Law