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

Eight Black homeowners in New York City sued a lending institution and affiliated entities, alleging that the lender violated federal, state, and city antidiscrimination laws. They claimed the lender made mortgage refinancing loans with high default interest rates to Black and Latino individuals in poor neighborhoods who had no income, no assets, and low credit scores but high equity in their homes, and then foreclosed on the loans when the individuals defaulted. The United States District Court for the Eastern District of New York entered a final judgment awarding four homeowners $722,044 in compensatory damages and four others nominal damages.The lender appealed, arguing that the district court erred in three ways: by finding the homeowners' claims timely under the doctrine of equitable tolling and the discovery rule of accrual, in its instructions to the jury on disparate impact and disparate treatment theories of discrimination, and in holding that a release-of-claims provision in a loan modification agreement signed by two homeowners was unenforceable as a matter of law.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the district court did not abuse its discretion in holding that the homeowners' claims were timely under the doctrine of equitable tolling. The court also found no error in the district court's instructions to the jury on disparate impact and disparate treatment theories of discrimination. Finally, the court agreed that the release-of-claims provision in the loan modification agreement was unenforceable as a matter of law. Accordingly, the Second Circuit affirmed the judgment of the district court. View "Saint-Jean v. Emigrant Mortg. Co., Inc." on Justia Law

Richard Hoffer filed a lawsuit against the City of Yonkers, the City of Yonkers Police Department, and several individual police officers under 42 U.S.C. § 1983, claiming that the officers used excessive force during his arrest. The case went to trial, and the jury returned a verdict in favor of the officers. Hoffer appealed the district court's decision, specifically challenging the court's denial of his request for an adverse inference instruction due to a missing video of him being tased.The United States District Court for the Southern District of New York presided over the initial trial. Hoffer requested an adverse inference instruction based on the missing video, arguing that the video was crucial evidence. The district court denied this request, finding insufficient evidence to prove that the video was intentionally destroyed to deprive Hoffer of its use in litigation. The jury ultimately found in favor of the officers, and Hoffer's subsequent motion to set aside the verdict was also denied.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that to impose sanctions under Federal Rule of Civil Procedure 37(e)(2), it must be proven by a preponderance of the evidence that a party acted with an "intent to deprive" another party of the lost information. The court clarified that the lesser "culpable state of mind" standard, which includes negligence, does not apply to Rule 37(e)(2) sanctions. Applying this standard, the Second Circuit concluded that the district court did not err in denying Hoffer's request for an adverse inference instruction and affirmed the judgment of the district court. View "Hoffer v. Tellone" on Justia Law

Robert Sylvester Kelly, also known as R. Kelly, was convicted in the United States District Court for the Eastern District of New York of racketeering and Mann Act violations. The evidence presented at trial showed that Kelly, with the help of his associates, exploited his fame to lure and abuse young girls and women over a period of twenty-five years. Kelly isolated his victims, controlled their lives, and subjected them to verbal, physical, and sexual abuse.The district court sentenced Kelly to 360 months' imprisonment for racketeering and additional concurrent sentences for the Mann Act violations. Kelly was also fined and ordered to pay restitution to two victims. Kelly appealed his convictions, challenging the sufficiency of the evidence, the constitutionality of the state laws underlying his federal convictions, the empaneling of certain jurors, ineffective assistance of counsel, and the district court's evidentiary rulings and restitution orders.The United States Court of Appeals for the Second Circuit reviewed Kelly's appeal. The court found that there was sufficient evidence to support Kelly's convictions, including the underlying state and federal violations. The court also held that the New York state law was constitutional as applied to Kelly and that Kelly's challenges to the California state law were untimely. The court found no evidence of juror bias or ineffective assistance of counsel during voir dire. The court also upheld the district court's evidentiary rulings and restitution orders, finding no abuse of discretion.The Second Circuit affirmed the judgment of the district court, concluding that Kelly's arguments on appeal were without merit. View "United States v. Kelly" on Justia Law

John Doe, an individual with a serious mental illness, sued James V. McDonald, M.D., New York’s Commissioner of Health, and other defendants, seeking declaratory and injunctive relief under the Americans with Disabilities Act, the Rehabilitation Act, the Fair Housing Act, and Article 78 of the New York Civil Practice Law and Rules. Doe alleged that New York State regulations discriminated against him by preventing his readmission to Oceanview Manor Home for Adults, a Transitional Adult Home (TAH) where he previously resided. After filing the suit, the State allowed Doe to return to Oceanview, amended the regulations to permit readmission of former TAH residents with serious mental illness, and removed Oceanview’s classification as a TAH.The United States District Court for the Northern District of New York denied the State’s motion for summary judgment, which argued that Doe lacked standing. The district court granted the State leave to file an interlocutory appeal. On appeal, the State contended that the district court erred in finding standing because Doe lacked a concrete plan to leave and seek readmission to Oceanview.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the State’s jurisdictional challenge should be assessed as a question of mootness, not standing, because it addressed events occurring after Doe filed the suit. The court found that Doe’s suit was moot because the State had allowed Doe to return to Oceanview, amended the regulations, and removed Oceanview’s TAH classification. Consequently, there was no reasonable expectation that the alleged violation would recur.The Second Circuit dismissed the appeal, vacated the district court’s order, and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. View "Doe v. McDonald" on Justia Law

Plaintiff Robert Pearson Jr. was held at the Orange County Correctional Facility for a parole violation. He alleged that corrections officers beat him in his cell, tampered with his food, sprayed chemicals in his eye, causing pain and impaired vision, and denied him medical care. Pearson filed a pro se amended complaint under 42 U.S.C. § 1983 against Sergeant Gessner and Officers Morris, Halstead, and Broeckel.The United States District Court for the Southern District of New York dismissed Pearson's complaint for failure to state a claim under Fed. R. Civ. P. 12(b)(6). The court considered materials outside the amended complaint, including a video and an Inmate Misbehavior Report, which it deemed integral to the complaint. The court found that the use of pepper spray by Gessner was not objectively unreasonable and that Pearson failed to state a claim for denial of medical care, as he was taken to the infirmary and refused treatment.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed that the district court erred in considering materials outside the amended complaint, specifically the Misbehavior Report and the video, which were not relied upon by Pearson in drafting his complaint. The appellate court vacated the judgment in part, remanding for further proceedings on the excessive force claims. The court affirmed the dismissal of the claims regarding denial of medical assistance, as the amended complaint itself indicated that Pearson was taken to the medical facility.The appellate court instructed that Pearson should be allowed to file a second amended complaint to clarify which defendants were responsible for the alleged acts of excessive force. The judgment was affirmed in part, vacated in part, and remanded for further proceedings. View "Pearson v. Gesner" on Justia Law

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

Clint Edwards, a pretrial detainee in a Westchester County Department of Corrections (WCDOC) jail, filed a lawsuit under 42 U.S.C. § 1983, alleging violations of his Fourteenth Amendment rights. Edwards claimed that Correction Officer Christopher Arocho failed to protect him and incited other inmates to attack him. He also alleged that several WCDOC officials subjected him to unsanitary and unhealthy conditions in administrative segregation and that his placement in administrative segregation without notice or a hearing violated his procedural due process rights.The United States District Court for the Southern District of New York dismissed Edwards’s conditions of confinement and procedural due process claims for failure to state a claim. The court also granted summary judgment in favor of Arocho on the failure to protect claim, determining that Edwards had not exhausted 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 and concluded that Edwards had adequately stated claims for conditions of confinement and procedural due process violations under the Fourteenth Amendment. The court also found that Edwards raised a factual dispute regarding whether he exhausted his administrative remedies, which precluded summary judgment on the failure to protect claim. The court vacated the District Court’s judgment and remanded the case for further proceedings. View "Edwards v. Arocho" on Justia Law

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