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

A pretrial detainee in the custody of the Vermont Department of Corrections alleged that a corrections officer sexually abused him during a purported search for contraband. The detainee asserted that while he was participating in a medication-assisted treatment program at the correctional facility, the officer grabbed, squeezed, and twisted his genitals after checking his mouth for medication, causing injury. The detainee’s version of events was supported by his own testimony and statements from other detainees who witnessed the incident. He filed administrative grievances and was interviewed by an investigator, who ultimately found the complaint unfounded, but the detainee was cleared of any disciplinary infraction.After his release, the detainee filed suit in the United States District Court for the District of Vermont, asserting claims under the Eighth and Fourteenth Amendments as well as state law. The District Court granted summary judgment to the officer on some claims but denied summary judgment on the Fourteenth Amendment sexual abuse claim and a related state-law battery claim, concluding that the officer was not entitled to qualified immunity because a reasonable jury could find a constitutional violation based on the detainee’s account.The United States Court of Appeals for the Second Circuit reviewed only the denial of qualified immunity. The court held that, for sexual abuse claims brought by pretrial detainees under the Fourteenth Amendment, the proper standard is whether the officer’s conduct was objectively unreasonable—not whether it constituted cruel and unusual punishment under the Eighth Amendment. The court determined that, accepting the detainee’s version, the officer’s actions violated clearly established Fourteenth Amendment rights. The court affirmed the District Court’s denial of qualified immunity, dismissed the remainder of the appeal for lack of jurisdiction, and remanded for further proceedings. View "Russell v. Scott" on Justia Law

The plaintiff in this case, while serving a prison sentence, was diagnosed with a serious mental illness. After a period of stability on prescribed antipsychotic medication, his psychiatrist at a correctional facility discontinued the medication upon his refusal and assertion that he did not need it. Over the following weeks, the plaintiff’s mental health deteriorated. He became involved in an altercation with correctional staff, was placed in segregated housing (the Special Housing Unit or SHU), and subsequently subject to further disciplinary housing (“keeplock”). During this time, he experienced hallucinations and anxiety, though he did not report these symptoms to staff. Shortly after his release from custody, the plaintiff, while still suffering from psychosis, committed a violent assault on a family member.The United States District Court for the Southern District of New York granted summary judgment to the defendants, including employees of the Department of Corrections and the Office of Mental Health, finding no triable issue of fact regarding whether defendants were subjectively aware of or disregarded a serious risk to the plaintiff’s health. The District Court reasoned that, because he did not affirmatively report his hallucinations, the defendants lacked the requisite knowledge for Eighth Amendment liability.On appeal, the United States Court of Appeals for the Second Circuit held that, viewing the evidence in the light most favorable to the plaintiff, there were genuine disputes of material fact as to whether each defendant knew of a serious risk to the plaintiff’s health and whether they disregarded that risk by their actions or inaction. The Court of Appeals vacated the District Court’s grant of summary judgment on both the conditions of confinement and inadequate medical care claims under the Eighth Amendment, and remanded the case for further proceedings. View "Suarez v. Sullivan" on Justia Law

A woman was arrested by New York City police officers after they responded to a 911 call reporting an assault in progress related to a domestic dispute in Flushing, New York. Upon arrival, the officers spoke with the alleged victim’s son, who showed them injuries on his father’s arm and indicated that the woman had caused them by striking him with an umbrella. The father, standing beside his son, pointed to his injuries and demonstrated how the assault occurred. The officers photographed the injuries, and the woman was subsequently charged with assault and harassment. These charges were later dismissed.The woman then filed a lawsuit in the United States District Court for the Eastern District of New York, asserting several claims under 42 U.S.C. § 1983, including false arrest, as well as state constitutional claims. The district court granted summary judgment for the officers on all claims except for the false arrest claim. The court denied qualified immunity to the officers on this claim, finding disputed issues of material fact regarding whether there was probable cause to arrest.The United States Court of Appeals for the Second Circuit reviewed the district court’s denial of summary judgment on qualified immunity. The appellate court held that the district court erred, concluding that, when viewing the record in the light most favorable to the plaintiff, the officers had arguable probable cause to arrest based on corroborated evidence: the 911 call, physical injuries, and the victim’s demonstration of the assault. The appellate court clarified that police are not required to assess the credibility of domestic violence victims more skeptically than other witnesses simply due to the familial context. The Second Circuit reversed the district court’s order and remanded with instructions to grant summary judgment to the officers on the false arrest claim. View "Jin v. City of New York" on Justia Law

A teenage girl accused Dennis Sacaza of sexually assaulting her while on a crowded Metropolitan Transit Authority bus in Brooklyn. The incident was partially captured on video footage from the bus, which showed the complainant appearing uncomfortable and looking back at Sacaza several times, but did not definitively show any physical contact. After the complainant reported the alleged assault to her school and the police, Detective Michael Friedman conducted an investigation, including interviews, review of the bus footage, and a double-blind photo array, in which the complainant identified Sacaza twice. Sacaza was charged with several offenses, but the criminal case was ultimately dismissed on speedy trial grounds.Sacaza subsequently filed suit in the United States District Court for the Eastern District of New York, asserting claims for false arrest, malicious prosecution, and denial of the right to a fair trial under federal and state law. After discovery, the defendants moved for summary judgment, arguing Detective Friedman was entitled to qualified immunity. The district court granted summary judgment on some claims but denied it on the federal false arrest and malicious prosecution claims, finding that questions of fact existed regarding whether there was arguable probable cause to arrest and charge Sacaza, given inconsistencies in the complainant's statements and the bus video.On interlocutory appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s denial of summary judgment de novo. The court held that Detective Friedman was entitled to qualified immunity because, based on the undisputed evidence, a reasonable officer could have believed there was probable cause to arrest and charge Sacaza. The district court’s denial of summary judgment on the federal claims was reversed, and the case was remanded for entry of judgment in favor of Friedman and for further proceedings regarding the state law claims. View "Sacaza v. City of New York" on Justia Law

A former corrections officer brought suit against several supervisory employees of the New York State Department of Corrections and Community Supervision, alleging that his rights under the Equal Protection Clause were violated due to race discrimination and retaliation after he complained about such discrimination. He claimed that, while employed at Downstate Correctional Facility, he was denied requests for outside employment that were granted to white colleagues, suspended without pay in circumstances where white officers were suspended with pay, and barred from returning to work after filing discrimination and workplace violence complaints. The defendants disputed these allegations, offering alternative explanations for their actions and contesting whether Miller was similarly situated to the relevant comparators.After extensive discovery, the defendants moved for summary judgment in the United States District Court for the Southern District of New York. In addition to arguing that the summary judgment record did not reveal any material factual disputes, they asserted that, even on the pleadings, Miller failed to state a viable claim. Instead of evaluating the evidence produced during discovery, the district court considered only the sufficiency of the allegations in the complaint under Rule 12(b)(6), effectively converting the summary judgment motion into a motion to dismiss.On appeal, the United States Court of Appeals for the Second Circuit held that the district court erred procedurally by disregarding the summary judgment record and resolving the dispute solely under the pleading standard after discovery had closed. The court explained that once discovery is complete and summary judgment is sought, the correct standard requires assessment of the record evidence, not just the pleadings. The court vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion, without expressing any view on the merits of the underlying claims or the sufficiency of the evidence. View "Miller v. Lamanna" on Justia Law

A mother and the Connecticut Fair Housing Center sued a company that provides tenant screening reports, alleging that its practices contributed to the denial of a housing application for the mother’s disabled son. The apartment manager used the defendant’s screening platform to review applicants’ criminal histories, and the son’s application was denied based on a flagged shoplifting charge. The mother later had the charge dismissed. She also sought a copy of her son’s screening report from the defendant, but was told she needed to provide a power of attorney. She instead submitted documentation of her conservatorship, but the defendant rejected it as facially invalid due to a missing court seal.The United States District Court for the District of Connecticut held a bench trial. It found that the Fair Housing Act (FHA) did not apply to the defendant because it was not the decision-maker on housing applications; only the housing provider made those determinations. The district court also found the defendant’s requirement for a valid conservatorship certificate reasonable and not discriminatory toward handicapped individuals. However, the district court found the defendant liable under the Fair Credit Reporting Act (FCRA) for a period when it insisted on a power of attorney, making it impossible for the mother to obtain her son’s consumer file.On appeal, the United States Court of Appeals for the Second Circuit concluded that the Connecticut Fair Housing Center lacked standing because its diversion of resources to address the defendant’s actions did not constitute a concrete injury. The court also held that, although the FHA does not exclude certain defendants, the defendant here was not the proximate cause of the housing denial, and the mother failed to establish a prima facie case of disparate-impact discrimination. Furthermore, because she never provided a facially valid conservatorship certificate, she could not show that the defendant’s documentation requirements prevented her from obtaining the report. The court vacated, affirmed, and reversed in part, dismissing the Center’s claims, affirming no FHA liability, and reversing FCRA liability. View "CFHC v. CoreLogic Rental Prop. Sols." on Justia Law

Fourteen children who were removed from their biological parents by New York City officials are the plaintiffs in this case. After their removal, relatives sought certification to become foster or adoptive parents for these children, but their applications were denied due to criminal history or reports of child abuse or mistreatment. The children allege that New York’s certification scheme violates their substantive due process rights to family integrity and freedom from harm, and that procedural due process was violated because they were not given notice or an opportunity to challenge the denial of a relative’s application.The United States District Court for the Eastern District of New York dismissed the complaint. It ruled that the plaintiffs lacked standing, reasoning that most of the children did not have a cognizable injury since they were living with relatives, and others could not trace their separation from relatives to the defendants. The district court also found that the plaintiffs were asserting the rights of third-party relatives rather than their own, and that prudential standing barred their claims. The court did not address the procedural due process claims directly.On appeal, the United States Court of Appeals for the Second Circuit held that the plaintiffs have standing to pursue both substantive and procedural due process claims. The court found that denial of certified placement with a relative constituted a concrete and particularized injury, traceable to the defendants, and redressable by a favorable ruling. The court also determined that the plaintiffs were asserting their own rights, not those of their relatives, and rejected the district court’s prudential standing analysis. However, some claims were deemed moot: two plaintiffs are now in the care of a relative foster parent and another has aged out of foster care. Only one plaintiff has standing to challenge the adoption certification rules. The Second Circuit reversed in part, affirmed in part, and remanded the case for further proceedings. View "B.B. v. Hochul" on Justia Law

On February 1, 2018, Christopher Matusak was arrested in Scottsville, New York, after fleeing from police. Deputies from the Monroe County Sheriff’s Office, including Matthew Daminski, Stephen Murphy, and Sergeant Brian Unterborn, apprehended him using various forms of force, such as fist and knee strikes, pepper spray, and a taser, before handcuffing him. Matusak sustained injuries requiring hospitalization. He subsequently filed suit under 42 U.S.C. § 1983, alleging that the deputies violated his Fourth and Fourteenth Amendment rights by using excessive force during his arrest.The United States District Court for the Western District of New York presided over a jury trial. The jury determined that Deputy Daminski did not use excessive force, but found that Murphy and Unterborn did, awarding Matusak $200,000 in compensatory damages. However, the jury also found that, although Matusak did not actually pose a threat to officer safety, Murphy and Unterborn reasonably believed he did, and that Matusak was resisting their attempts to handcuff him. Based on the jury’s special verdicts, the district court granted judgment as a matter of law to Murphy and Unterborn, holding that they were entitled to qualified immunity because it was not clearly established that their conduct was unlawful under the circumstances.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Murphy and Unterborn were entitled to qualified immunity, reasoning that no clearly established law prohibited the use of significant force against an arrestee who was resisting and whom the officers reasonably, though mistakenly, believed posed a threat to officer safety. As it was objectively reasonable for the officers to believe their actions were lawful, the Second Circuit affirmed the district court’s judgment. View "Matusak v. Daminski" on Justia Law

C.B., a 34-year-old man with developmental and psychiatric disabilities, died while residing at the Valley Ridge Center for Intensive Treatment, a secure state-run facility operated by the New York State Office for People with Developmental Disabilities. Although C.B. was admitted voluntarily, the facility imposed substantial restrictions on his liberty, including limits on leaving the premises and accessing medical care. In the days leading up to his death from cardiomyopathy, C.B. exhibited clear symptoms of heart failure and repeatedly asked staff for help, but his pleas were allegedly ignored or inadequately addressed by his caretakers.J.M., C.B.’s mother and administrator of his estate, brought suit in the United States District Court for the Northern District of New York, alleging violations of C.B.’s substantive due process rights under 42 U.S.C. § 1983, as well as state law claims for negligence and medical malpractice. The district court granted summary judgment for the defendants on the federal claim, holding that C.B., as a voluntarily admitted resident, had no constitutional right to adequate medical care, and declined to exercise supplemental jurisdiction over the state law claims. The court also denied J.M.’s motion to amend her complaint to add a new defendant, finding lack of diligence.On appeal, the United States Court of Appeals for the Second Circuit held that C.B. was entitled to substantive due process protections regardless of his voluntary admission status. The court clarified that when the state exercises sufficient control over a resident’s life such that the individual cannot care for himself, due process guarantees apply, consistent with Youngberg v. Romeo, Society for Good Will to Retarded Children, Inc. v. Cuomo, and DeShaney v. Winnebago County Department of Social Services. The Second Circuit vacated the district court's judgment and remanded for further proceedings. View "J.M. v. Sessions" on Justia Law

Several nonprofit, faith-based organizations that provide pregnancy-related services and oppose abortion initiated an action against the New York State Attorney General. These organizations had made statements regarding abortion pill reversal (“APR”), a protocol intended to counteract the effects of medication-induced abortion. After the Attorney General commenced a civil enforcement action in New York state court against other entities (not parties to this case) for making similar APR-related statements, the plaintiffs alleged they faced a credible threat of sanctions if they continued such speech. As a result, they stopped making APR-related statements and sought declaratory and injunctive relief in federal court, arguing that the regulation of their APR-related speech violated their First and Fourteenth Amendment rights.The United States District Court for the Western District of New York addressed the Attorney General’s argument that the federal court should abstain under the Younger v. Harris doctrine due to the parallel state enforcement action. The district court found abstention unwarranted, noting the federal claims were not inextricably intertwined with the state action and would not interfere with it. On the merits, the district court determined that the plaintiffs were likely to succeed on their First Amendment claim because the APR-related speech was noncommercial, religiously and morally motivated, involved no financial benefit or remuneration, and did not directly offer APR but instead provided information and referrals. Since the Attorney General did not show the state’s restrictions would survive strict scrutiny, the district court granted a preliminary injunction.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s order. The Second Circuit held abstention under Younger was not required, as the plaintiffs’ claims were independent of the state enforcement action. The court found no abuse of discretion in the grant of the preliminary injunction, agreeing that the plaintiffs’ APR-related speech was noncommercial and protected, and the Attorney General failed to meet the strict scrutiny standard. View "Nat'l Inst. of Fam. & Life Advocs. v. James" on Justia Law