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

Articles Posted in Civil Rights
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Plaintiff, a New York inmate, filed a 42 U.S.C. 1983 suit alleging that all employees of the DOCCS violated his constitutional rights under the First and Eighth Amendments when they sexually assaulted him and retaliated against him for filing grievances. The district court granted summary judgment to defendants in part based on its conclusion that plaintiff failed to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA).The Second Circuit held that where, as here, an inmate follows the steps prescribed by the DOCCS Inmate Grievance Procedure but prison officials do not respond to the inmate's final appeal within the time allotted under the regulations, he has exhausted administrative remedies under the PLRA. The court held that plaintiff raised a triable issue of fact as to his retaliation claim against Defendant Hoffman but not as to his retaliation claim against Defendant Iarusso. The court also held that the district court erred in granting summary judgment on plaintiff's Eighth Amendment claim against Defendant Dahlke where plaintiff alleged facts sufficient to survive summary judgment as to whether his rights were violated during Dahlke's pat and frisk. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Hayes v. Dahkle" on Justia Law

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The Libertarian Party of Connecticut and two of its affiliated candidates filed suit alleging that the State violated their First and Fourteenth Amendment rights by requiring candidates for office to collect signatures from electors before appearing on the general election ballot. The district court denied the motion for a preliminary injunction on the ground that plaintiffs failed to demonstrate a clear or substantial likelihood of success on the merits.Applying the Anderson-Burdick framework, the Second Circuit affirmed the district court's judgment and concluded that Connecticut's laws do not impose a severe burden on plaintiffs' rights and the State's interest in requiring candidates for office to demonstrate some support before appearing on the ballot justified those laws. The district court did not abuse its discretion in concluding that Connecticut's laws impose only a reasonable, nondiscriminatory burden. In this case, the petitioning period ran for 218 days and the evidence demonstrates that petitioning was possible even under the challenging conditions in the State of Connecticut. Furthermore, the Supreme Court has repeatedly held that the State has the undoubted right to require candidates to make a preliminary showing of substantial support in order to qualify for a place on the ballot, and the signature requirements are an appropriate means of vindicating the State's interest. View "Libertarian Party of Connecticut v. Lamont" on Justia Law

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After plaintiff was shot in the stomach by Officer Miller in the course of Miller's execution of a no-knock search warrant, plaintiff filed suit alleging that he was the victim of negligence on the part of both Miller and other police personnel involved in the planning of the raid.The Second Circuit concluded that there was no error in the district court’s denial of plaintiff’s motion to overturn the jury verdict in favor of Miller; in regard to the City's motion, the district court erred in granting judgment as a matter of law on the basis of New York's bar on claims for "negligent investigation," because that rule does not apply to plaintiff's claim; and plaintiff's evidence was sufficient to support a jury finding that the City, through its employees, violated acceptable police practice, so that discretionary immunity did not apply, and those violations caused his injury.However, the court found conflicting guidance from the New York Court of Appeals as to whether the district court correctly held that plaintiff's claim was barred by New York's "special duty" rule. Therefore, the court certified the following question to the New York Court of Appeals: Does the "special duty" requirement—that, to sustain liability in negligence against a municipality, the plaintiff must show that the duty breached is greater than that owed to the public generally—apply to claims of injury inflicted through municipal negligence, or does it apply only when the municipality's negligence lies in its failure to protect the plaintiff from an injury inflicted other than by a municipal employee? View "Ferreira v. City of Binghamton" on Justia Law

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Plaintiff filed suit under the Racketeer Influenced and Corrupt Organizations Act (RICO) and 42 U.S.C. 1983, alleging that the individual defendants conspired against him in arbitration and judicial proceedings arising out of an employee compensation dispute.The Second Circuit affirmed the district court's dismissal of plaintiff's complaint based on failure to state a claim and declined to address the applicability of the Rooker-Feldman doctrine to his claims. In this case, plaintiff's claims against Justice Farneti are barred by absolute judicial immunity; plaintiff's allegations of a corrupt agreement, which rest on rank speculation, are inadequate to support his conspiracy claims under RICO and section 1983; and plaintiff's allegations that the private defendants made false statements in their various filings and in the course of testifying in the arbitration and Article 75 proceedings cannot support a claim of a substantive RICO violation. Furthermore, the court stated that it may assume hypothetical statutory jurisdiction in order to resolve this appeal on the merits because the Rooker-Feldman doctrine does not implicate Article III jurisdiction. The court explained that doing so is particularly appropriate in this case, where the jurisdictional issue is both novel and arguably complex, while plaintiff's claims are plainly meritless. View "Butcher v. Wendt" on Justia Law

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The Second Circuit affirmed the district court's dismissal of plaintiffs' Title VII disparate impact class action against their would-be employer. Plaintiffs, African-American men who were hired at a technology services provider before their offers of employment were revoked because of past criminal convictions, cited national statistics showing that African Americans are arrested and incarcerated at higher rates than whites relative to their share of the national population.The court held that plaintiffs have set forth no allegations plausibly suggesting that the company's hiring policy has a disparate impact on African Americans within the relevant hiring pool. The court stated that, while national statistics may be used to advance a disparate impact claim if there is reason to believe that the general population is representative of the qualified applicant pool subject to the challenged policy, plaintiffs' complaint suggests that the jobs they applied for required substantial educational and technical credentials, and plaintiffs have provided no basis on which to presume that their proffered statistics are representative of the applicant pool in question. View "Mandala v. NTT Data, Inc." on Justia Law

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D.S., a child with a disability who receives special education services under the Individuals with Disabilities Education Act (IDEA), appealed the district court's denial of his motion for summary judgment and grant of the Board's motion for summary judgment. After the child's parents disagreed with the functional behavioral assessment (FBA) that his school conducted, they sought an independent educational evaluation (IEE) at public expense.The Second Circuit held that an FBA is not an evaluation as that term is employed in the relevant IDEA provisions and that a parent's dissatisfaction with an FBA does not entitle them to a publicly funded IEE. In regard to the parents' disagreement with the child's 2014 reevaluation, the court held that parents need not file a due process complaint under the IDEA to disagree with an evaluation and that the statute of limitations does not apply here. Rather, the court held that the IDEA's cyclical evaluation process establishes the operative time frame in which a parent may disagree with an evaluation and obtain an IEE at public expense. Accordingly, the court vacated the judgment, reversed the district court's decision, and remanded for further proceedings. View "D.S. v. Trumbull Board of Education" on Justia Law

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After Plaintiffs Moya and Ruiz applied to become naturalized citizens of the United States and the government denied their requests for disability exemptions from the civics and English testing requirements, they filed suit in federal court claiming that the naturalization process is unlawful.The Second Circuit affirmed the district court's dismissal of plaintiffs' claims, holding that the Immigration and Nationality Act (INA) does not allow Moya and Ruiz to seek judicial review of their denial of their applications until after completion of the available administrative review procedures, and thus Moya and Ruiz did not exhaust their administrative remedies. The court also held that the district court correctly found that the other plaintiff in this appeal, YMPJ, had Article III standing to sue, but did not fall within the zone of interests of the INA, the Administrative Procedure Act, or the Due Process Clause. Therefore, YMPJ, a non-profit organization that assists applicants for naturalization, could not bring a cause of action on its own behalf. View "Moya v. United States Department of Homeland Security" on Justia Law

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Plaintiff appealed the district court's order adopting the Magistrate Judge's sua sponte order administratively closing plaintiff's civil rights suit against defendants and denying his motion to reconsider. The district court concluded that, because plaintiff had been deported to the Dominican Republic, plaintiff would be unavailable in the United States for depositions, further medical examinations, and trial testimony, and the case should be closed.The Second Circuit held that an administrative closure in such circumstances is a last resort that is appropriate only when all other alternatives are virtually impossible or so impractical as to significantly interfere with the operations of the district court or impose an unreasonable burden on the party opposing the plaintiff's claim. In this case, the court held that numerous alternatives to the issues identified by the district court exist, and none seems virtually impossible or so impractical as to significantly interfere with the operations of the district court or impose an unreasonable burden on the party opposing plaintiff's claim. Accordingly, the court vacated the district court's order and remanded for further proceedings. View "Rodriguez v. Gusman" on Justia Law

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The Second Circuit affirmed the district court's grant of defendants' motion for summary judgment on plaintiff's claims under the Free Exercise Clause of the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA). Plaintiff alleged that prison officials violated his rights by interfering with his observance of Ramadan during a five-day prison lockdown and by transferring him to a special housing unit where he was unable to participate in group prayer.The court held that plaintiff's Free Exercise claims fail because defendants are entitled to qualified immunity where there was no clearly established law requiring the accommodation of inmates' religious practices during a prison lockdown. Furthermore, federal law does not provide any clearly established right of an inmate confined to the SHU to attend group prayer, and New York law actually prohibits it. The court also held that plaintiff's RLUIPA claims are moot because he was transferred from the Auburn Correctional Facility. Finally, the district court properly admitted certain hearsay and character evidence during the trial on his retaliation claim. View "Booker v. Graham" on Justia Law

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After plaintiff was acquitted for disorderly conduct, resisting arrest, and harassment, he filed suit under 42 U.S.C. 1983, alleging claims of excessive force, false arrest, and malicious prosecution. Two officers moved for summary judgment based on qualified immunity, but the district court denied the motion.The Second Circuit dismissed the officers' appeal based on lack of appellate jurisdiction, holding that the district court did not err as a matter of law when it concluded that there is a genuine dispute of material fact as to whether one of the officers gave verbal commands to disperse prior to his arresting plaintiff and thus had probable cause for the arrest. The court also held that it is properly up to the jury, not a court of appeals, to determine whether to believe testimony supporting plaintiff's claim that there was no such command from the officer. View "Franco v. City of Syracuse" on Justia Law