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

In 2016, James E. Moore, Jr., also known as Kevin Thompson, filed a lawsuit under 42 U.S.C. § 1983 against corrections officer Troy Booth and four other officers at Fishkill Correctional Facility, alleging excessive force. The officers, represented by the New York State Attorney General, claimed Thompson failed to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA). In 2020, the Attorney General withdrew as Booth's counsel due to his non-participation. Booth subsequently failed to appear for a deposition and a pre-motion conference, leading the district court to strike his answer as a sanction. The district court dismissed the claims against the other officers for failure to exhaust administrative remedies but granted a default judgment against Booth, awarding $50,000 in damages.The United States District Court for the Southern District of New York dismissed the claims against the four other officers on the grounds that Thompson had not exhausted administrative remedies. However, it granted a default judgment against Booth because his answer, which included the exhaustion defense, had been struck due to his non-participation.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court abused its discretion by granting a default judgment against Booth while dismissing the claims against the other officers on the merits. The appellate court held that, according to the principle set forth in Frow v. De La Vega, once the district court determined that Thompson could not maintain his claims against the litigating defendants due to failure to exhaust administrative remedies, it should have dismissed the claims against Booth for the same reason. The Second Circuit vacated the default judgment and remanded the case to the district court with instructions to enter a judgment in favor of Booth. View "Thompson v. Booth" on Justia Law

In August 2021, New York City’s Department of Education mandated COVID-19 vaccinations for all staff and contractors working in school settings. This mandate was updated over time, including a religious exemption process. The plaintiffs, New York City public sector employees, challenged the constitutionality of the mandate and the exemption process, both facially and as applied.The Southern District of New York denied a preliminary injunction and dismissed the consolidated amended complaint on the merits. The Eastern District of New York also denied a similar preliminary injunction motion. The plaintiffs appealed these decisions, leading to a consolidated review by the United States Court of Appeals for the Second Circuit.The Second Circuit affirmed in part and dismissed in part the denials of preliminary injunctions, affirmed the dismissal of the facial challenges, and affirmed in part while vacating and remanding in part the dismissal of the as-applied challenges. The court found that the request to rescind the vaccine mandate was moot due to its official rescission and denied the request for reinstatement and backpay, as the plaintiffs could not show irreparable harm post-termination. The court upheld the dismissal of the facial challenges, finding no evidence that the Citywide Panel process preferred certain religions or was infected with religious animus. However, the court vacated and remanded the as-applied challenges for plaintiffs Natasha Solon and Heather Clark, who plausibly alleged that their religious accommodation requests were improperly denied. View "New Yorkers for Religious Liberty v. City of New York" on Justia Law

In 1986, Carré Sutton, a minor, moved to New York City to work as a model for Elite Models Management. Elite executive Trudi Tapscott sent Sutton to Paris to live with another Elite executive, Gérald Marie, who allegedly raped her. Sutton's claims, which would typically be time-barred, were revived under New York’s Child Victims Act (CVA), which temporarily revived claims based on the sexual abuse of minors.The United States District Court for the Southern District of New York dismissed Sutton’s claims, concluding that the CVA did not apply because the abuse occurred outside New York. Additionally, the court dismissed the claims against Marie for lack of personal jurisdiction, noting that Sutton had not established the court's jurisdiction over Marie, who resides in Spain.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that the district court erred in its interpretation of the CVA, noting that subsequent state-court decisions clarified that the CVA revives claims arising from out-of-state abuse if the victim was a New York resident at the time. The appellate court also determined that Sutton plausibly alleged she was a New York resident when the abuse occurred. Furthermore, the court held that the district court erred in sua sponte dismissing the claims against Marie for lack of personal jurisdiction without providing Sutton an opportunity to establish jurisdiction.The Second Circuit reversed the district court’s judgment dismissing Sutton’s claims as time-barred, vacated the judgment regarding personal jurisdiction over Marie, and remanded the case for further proceedings. View "Sutton v. Tapscott" on Justia Law

Keith Schiebel, a veteran agriculture educator, brought an educational program called the "Mobile Maple Experience" to the Schoharie Central School District (SCSD) campus. Following the event, a student's mother reported that Schiebel made her daughter feel uncomfortable, leading to a Title IX investigation. Schiebel was accused of reaching around the student and touching her breast and buttocks while retrieving supplies. Schiebel denied recalling the incident but speculated that he might have reached around a student to get something. The Title IX coordinator, Kristin DuGuay, found the allegations credible and determined that Schiebel had committed sexual harassment, resulting in a five-year ban of the Mobile Maple Experience from the SCSD campus.The United States District Court for the Northern District of New York dismissed Schiebel's Title IX claim, stating that while he plausibly alleged an erroneous finding, he did not plausibly allege that sex-based bias was a motivating factor. The court declined to exercise supplemental jurisdiction over Schiebel's state law claims.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Schiebel plausibly alleged that SCSD violated Title IX. The court found that the investigation was so deficient as to constitute a sham and that the decision was inexplicable. Additionally, the court noted that the Title IX coordinator exhibited sex-based bias against Schiebel. The Second Circuit reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Schiebel v. Schoharie Cent. Sch. Dist." on Justia Law

Three practicing Muslim men alleged that federal agents asked them to serve as informants in Muslim communities. When they refused, the agents placed or retained them on the "No Fly List" and suggested they could be removed from the list if they agreed to work as informants. The plaintiffs sought damages under the Religious Freedom Restoration Act (RFRA), claiming that their religious beliefs precluded them from serving as informants and that the agents substantially burdened their exercise of religion by conditioning their removal from the No Fly List on actions that violated those beliefs.The United States District Court for the Southern District of New York dismissed the complaint on qualified immunity grounds, concluding that the agents were entitled to qualified immunity because there was no clearly established right not to be pressured to inform on members of one's religious community through the coercive or retaliatory use of the No Fly List.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court held that the agents were entitled to qualified immunity because a reasonable person in their position would not have understood that their conduct implicated the plaintiffs' religious beliefs. The court noted that the plaintiffs did not disclose their religious objections to the agents, and there were no facts plausibly supporting the conclusion that the agents knew the plaintiffs' objections were grounded in their religious beliefs. Therefore, the agents were entitled to qualified immunity from damages in their personal capacities. View "Tanvir v. Tanzin" on Justia Law

The State of New York, through its Attorney General, sued the Niagara-Wheatfield Central School District, alleging that school officials failed to address repeated complaints of student-on-student sexual assault, harassment, and gender-based violence and bullying. The complaint detailed incidents involving four students who suffered from such misconduct and claimed that the school district ignored at least thirty similar incidents. The State argued that the school district's inaction affected not only the victims but also the broader school community, creating an unsafe environment.The United States District Court for the Western District of New York dismissed the case, concluding that the State lacked parens patriae standing. The court reasoned that the incidents were factually distinct and did not demonstrate a broader policy or practice of discrimination by the school district. Without such a policy or practice, the court held that the State could not show that the school district's conduct affected a substantial segment of the population, which is required for parens patriae standing.The United States Court of Appeals for the Second Circuit reviewed the case and reversed the district court's decision. The appellate court held that showing an injurious policy or practice is not necessary to satisfy the substantial-segment prong of the parens patriae standard. The court concluded that the State of New York had met its burden of pleading parens patriae standing at this stage of the litigation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "New York v. Niagara-Wheatfield Central School District" on Justia Law

Joe Baltas, a Connecticut state prisoner, was transferred to the Virginia Department of Corrections (VADOC) under the Interstate Corrections Compact. While at Red Onion State Prison (ROSP) in Virginia, Baltas alleges he was threatened by VADOC officials for filing a grievance and was later attacked by inmates, resulting in his placement in restrictive housing. He also claims that Connecticut Department of Corrections (CTDOC) officials failed to review his administrative segregation (Ad Seg) status as required, violating his due process rights under the Fourteenth Amendment. Additionally, he alleges violations of his First, Sixth, and Eighth Amendment rights due to his treatment at ROSP.The United States District Court for the District of Connecticut granted summary judgment in favor of the Defendants. The court found that CTDOC had adequately reviewed Baltas’s Ad Seg classification and dismissed his due process claim. It also dismissed his First, Sixth, and Eighth Amendment claims, concluding that Baltas failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the District Court’s ruling that CTDOC’s periodic reviews of Baltas’s Ad Seg classification satisfied due process requirements. However, it found that a genuine dispute of fact existed regarding whether VADOC’s administrative remedies were available to Baltas, making summary judgment inappropriate for his First, Sixth, and Eighth Amendment claims. The court vacated the summary judgment on these claims and remanded the case for further proceedings. The court also affirmed the dismissal of Baltas’s remaining claims in a concurrently issued summary order. View "Baltas v. Maiga" on Justia Law

A former public school principal in Brooklyn, New York, brought a lawsuit against the New York City Department of Education (DOE) and its former chancellor, alleging retaliation after she complained about racially segregated sports teams at her school. The principal claimed that the DOE's investigation into her was a retaliatory action for her complaints about race discrimination affecting her students.The United States District Court for the Southern District of New York dismissed the principal's Title VI claim, reasoning that her challenge was related to an employment practice and that the primary objective of the federal funds received by the DOE was not to provide employment. The court also denied her motion for leave to amend her complaint, even after reconsidering its initial decision.The United States Court of Appeals for the Second Circuit reviewed the case and held that the principal's retaliation claim was not an action "with respect to any employment practice" under Title VI because her underlying protected activity was unrelated to the DOE’s employment practices. The court concluded that Title VI does provide a private right of action for retaliation claims when the retaliation is for opposing non-employment-related race discrimination. The court affirmed the dismissal of the claim against the former chancellor but vacated the dismissal of the Title VI claim against the DOE and remanded the case for further proceedings. View "Bloomberg v. N.Y.C. Department of Education" on Justia Law

A coalition of organizations and individuals, led by the Chinese American Citizens Alliance of Greater New York, filed a lawsuit against New York City's Mayor and Department of Education Chancellor. They challenged the revised admissions policy for the Discovery Program in the Specialized High Schools (SHSs), alleging it was intended to discriminate against Asian-American applicants by reducing their admission rates. The plaintiffs argued that the new policy, which included an Economic Need Index (ENI) criterion, negatively impacted Asian-American students.The United States District Court for the Southern District of New York granted summary judgment in favor of the City. The court concluded that the plaintiffs failed to demonstrate an aggregate disparate impact on Asian-American students, as required under Village of Arlington Heights v. Metropolitan Housing Development Corp. The court held that without showing a group-wide effect, the plaintiffs could not establish the necessary discriminatory effect for an equal protection claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court assumed, for the purpose of the appeal, that the plaintiffs could prove the policy changes were made with discriminatory intent. The court concluded that the district court erred in requiring an aggregate disparate impact to establish discriminatory effect. Instead, the court held that if discriminatory intent is proven, a negative effect on individual Asian-American students would suffice to trigger strict scrutiny review. The court found that the exclusion of economically disadvantaged Asian-American students from certain middle schools due to the new ENI criterion constituted a sufficient discriminatory effect. Consequently, the Second Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. View "Chinese Am. Citizens All. of Greater N.Y. v. Adams" on Justia Law

In 2007, Mohamed Musaid was arrested for the murder of a relative and confessed to the crime. However, his trial was delayed for over eight years due to repeated findings of incompetence to stand trial, attributed to his long history of mental illness. Musaid was found incompetent on ten occasions and competent on five, with his competency dependent on his compliance with antipsychotic medication. Each time he was found competent and transferred to Rikers Island, he would refuse medication and regress to incompetence.The trial court eventually allowed Musaid's trial to proceed nearly ten months after a final finding of competency, without re-evaluating his mental state. During the trial, Musaid exhibited erratic behavior, raising questions about his competency. Despite this, the trial court did not conduct a further inquiry into his mental state. Musaid was convicted and sentenced to 25 years to life for second-degree murder and five years for criminal possession of a weapon.Musaid appealed, arguing that the trial court's failure to reassess his competency before trial violated his due process rights. The Appellate Division affirmed the conviction, stating there was no indication that Musaid was unable to understand the proceedings or assist in his defense. Musaid then sought habeas corpus relief in the United States District Court for the Southern District of New York, which was denied.The United States Court of Appeals for the Second Circuit reviewed the case and found that the trial court's failure to conduct a minimal inquiry into Musaid's competency just before trial was objectively unreasonable, given his history of mental illness and the time elapsed since the last competency evaluation. The court reversed the district court's decision and remanded with instructions to grant a conditional writ of habeas corpus, allowing the state courts to determine whether it is possible to reconstruct Musaid's competency at the time of trial based on evidence proximate to the trial. View "Musaid v. Kirkpatrick" on Justia Law