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

Articles Posted in Civil Rights
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Plaintiff appealed the district court's dismissal of his claims alleging that he was wrongfully detained by local authorities pursuant to a federal immigration detainer. The Second Circuit held that the district court erred as to plaintiff's false arrest and false imprisonment claim against the government, because no reasonable officer would have issued the detainer under the circumstances without conducting an inquiry. Furthermore, the complaint alleged facts from which a reasonable inquiry would have revealed that plaintiff was a citizen who could not have been subject to an immigration detainer. The court also held that the district court erred as to plaintiff's official policy claim against the city, because the complaint plausibly alleged that but for the detainer, plaintiff would have been released, and that the city confined him not for his failure to post bail but because of the detainer. Furthermore, the complaint plausibly alleged that the city refused to release plaintiff because of its policy, the city would have seen that plaintiff was not subject to an immigration detainer if it had checked, and the city policy caused plaintiff's deprivation of rights. Finally, the court held that the district court properly dismissed the remaining claims. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Hernandez v. United States" on Justia Law

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After plaintiff was terminated from his position as a substitute teacher, he filed suit against defendants under 42 U.S.C. 1983, alleging in relevant part procedural due process and stigma‐plus claims related to the termination of his employment. Plaintiff was terminated from his position after defendants instituted an investigation into sexual misconduct claims, but ultimately concluded that there were no grounds for an investigation. The Second Circuit held, with respect to plaintiff's due process claim, that he failed to establish a clearly established right to the meaningful opportunity to utilize his teaching license. The court also held that plaintiff failed to demonstrate that defendantsʹ conduct was sufficiently stigmatizing under clearly established law so as to give rise to a "stigma‐plusʺ claim. Therefore, the court held that defendants were entitled to qualified immunity and the district court erred by denying summary judgment as to both claims. The court remanded with instruction. View "Mudge v. Zugalla" on Justia Law

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Plaintiff filed suit against CCJ and several employees, alleging the denial of his right to free exercise of religion in violation of the First Amendment, deliberate indifference to his medical needs in violation of the Eighth Amendment, and violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA). The district court granted summary judgment to all defendants on all counts. The Second Circuit held that plaintiff introduced sufficient evidence to create a genuine dispute of material fact as to the free exercise and retaliation claim. The court held that a reasonable jury could find that plaintiff was served significantly more than 10 meals containing pork, which was not in compliance with his religious diet. Furthermore, the district court also erred in concluding that 10 noncompliant meals was not a substantial burden. The court also held that a genuine dispute exists as to facts underlying the alleged retaliation against plaintiff. However, plaintiff may proceed on his claims against only those defendants who were personally involved in each violation. Accordingly, the court vacated in part, affirmed in part, and remanded. View "Brandon v. Kinter" on Justia Law

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Plaintiff, a registered sex offender, filed a 42 U.S.C. 1983 action alleging that visits by the county and Parents for Megan's Law (PFML) constituted unreasonable seizures in violation of the Fourth Amendment. The Second Circuit affirmed the district court's grant of summary judgment for defendants. The court assumed without deciding that the visits were the product of state action and constituted seizures under the Fourth Amendment, but held that they were reasonable under the special needs doctrine. View "Jones v. County of Suffolk" on Justia Law

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The Second Circuit reversed the district court's denial of a petition for writ of habeas corpus under 28 U.S.C. 2254. The court held that the trial court's exclusion of three defense witnesses violated petitioner's constitutional right to present a complete defense. Therefore, the court remanded with instructions to the district court to issue the writ. View "Scrimo v. Lee" on Justia Law

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The Second Circuit vacated the district court's dismissal on summary judgment of plaintiff's claim that a hospital violated section 504 the Rehabilitation Act by failing to provide her with an ASL interpreter. At issue was whether and when hospital staff members may be considered to be acting as officials or policymakers of the hospital so that their conduct may be attributed to the hospital and thereby establish plaintiff's right to damages on the ground that the defendant institution was deliberately indifferent to a violation of the Act. The court held that material issues of fact preclude summary judgment where the record contains evidence that the hospital staff at issue had knowledge of the deprivation of plaintiff's right to an interpreter, had the power to cure that violation, and failed to cure it View "Biondo v. Kaleida Health" on Justia Law

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The Second Circuit affirmed the district court's award of summary judgment to defendants on plaintiff's state law claims of sex discrimination, retaliation, and hostile work environment. The court held that summary judgment was correctly entered in favor of AutoZone on plaintiff's Connecticut claims of discriminatory discharge based on sex, retaliatory discharge for reporting sexual harassment, and a sex hostile work environment because plaintiff failed to adduce sufficient evidence from which a reasonable jury could resolve any of these claims in her favor; the district court correctly concluded that plaintiff's own deposition testimony could not raise a genuine issue of fact as to AutoZone's having notice of plaintiff's sexual harassment by a co‐worker before August 2014 because that testimony was unequivocally contradicted by her own earlier sworn and written statements, and she failed plausibly to explain the numerous contradictions; and the district court correctly concluded that plaintiff failed to raise a genuine issue of fact as to the harassing co‐worker being a supervisor, which was required for AutoZone to be strictly vicariously liable for any ensuing hostile work environment. View "Bentley v. AutoZoners, LLC" on Justia Law

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Where a university takes an adverse employment action against an employee, in response to allegations of sexual misconduct, following a clearly irregular investigative or adjudicative process, amid criticism for reacting inadequately to allegations of sexual misconduct by members of one sex, these circumstances support a prima facie case of sex discrimination. When contesting an inference of bias based on procedural irregularity, an employer cannot justify its abandonment of promised procedural protections by recharacterizing specific accusations in more generic terms. Where a student files a complaint against a university employee, the student is motivated, at least in part, by invidious discrimination, the student intends that the employee suffer an adverse employment action as a result, and the university negligently or recklessly punishes the employee as a proximate result of that complaint, the university may be liable under Title VII of the Civil Rights Act of 1964. The Second Circuit vacated the district court's dismissal of plaintiff's complaint against Hofstra under Title VII and the New York State Human Rights Law, alleging that Hofstra discriminated against him because of his sex when it fired him in response to allegedly malicious allegations of sexual harassment. The court held that the district court's decision conflicted with circuit precedent in Doe v. Columbia University, 831 F.3d 46 (2d Cir. 2016), and relied on improper factual findings. In this case, the complaint alleged circumstances that provide at least a minimal support for an inference of discriminatory intent. On remand, the court noted that the district court should consider Hofstra's potential liability under a cat's paw theory. View "Menaker v. Hofstra University" on Justia Law

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The parties dispute the district court's award of attorney's fees to plaintiff in an action successfully claiming a violation of the Religious Land Use and Institutionalized Persons Act. The Second Circuit affirmed and held that plaintiff was entitled to attorney's fees as a prevailing party; plaintiff may not obtain fees for the administrative proceedings for failure to identify "the discrete portion of the work product from the administrative proceedings" for which fees might have been awarded, North Carolina Dep't of Transportation v. Crest Street Community Council, Inc., 479 U.S. 6, 15 (1986); and the 50 percent reduction was appropriate. View "Chabad Lubavitch of Litchfield County, Inc. v. Litchfield Historic District Commission" on Justia Law

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Defendants, athletics officials at Binghampton, appealed the district court's denial in part of their motion for summary judgment based on qualified immunity. The Second Circuit held that the district court erroneously conflated the distinct Title VII and 42 U.S.C. 1983 standards for both vicarious liability and causation. The court clarified the differences between discrimination claims brought under Title VII and those brought under section 1983. The court held that section 1983 claims for discrimination in public employment require plaintiffs to establish that the defendant's discriminatory intent was a "but‐for" cause of the adverse employment action; section 1983 claims for discrimination in public employment cannot be based on a respondeat superior or "cat's paw" theory to establish a defendant's liability; and defendants were entitled to qualified immunity because, even when interpreted in the light most favorable to plaintiff, the record cannot support the conclusion that they violated her "clearly established" constitutional rights. Accordingly, the court reversed the district court's order in regard to the section 1983 claims against defendants, entered judgment for defendants, and remanded for further proceedings. View "Naumovski v. Norris" on Justia Law