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

A former dancer at two adult entertainment clubs in Manhattan filed a class charge with the Equal Employment Opportunity Commission (EEOC), alleging pervasive sexual harassment and a hostile work environment affecting herself and other female dancers. She claimed that the clubs’ policies and practices fostered this environment, including being forced to change in open areas monitored by video and being pressured to engage in sexual acts with customers. After receiving the charge, the EEOC requested information from the clubs, including employee “pedigree” data such as names, demographics, and employment details. The clubs objected, arguing the requests were irrelevant and burdensome, but the EEOC issued subpoenas for the information.The United States District Court for the Southern District of New York granted the EEOC’s petition to enforce the subpoenas, finding the requested information relevant to the investigation and not unduly burdensome for the clubs to produce. The clubs appealed and, while the appeal was pending, the EEOC issued a right-to-sue letter to the charging party, who then filed a class action lawsuit in the same district court. The clubs argued that the EEOC lost its authority to investigate and enforce subpoenas once the right-to-sue letter was issued and the lawsuit commenced.The United States Court of Appeals for the Second Circuit held that the EEOC retains its statutory authority to investigate charges and enforce subpoenas even after issuing a right-to-sue letter and after the charging party files a lawsuit. The court also found that the employee information sought was relevant to the underlying charge and that the clubs had not shown compliance would be unduly burdensome. The Second Circuit therefore affirmed the district court’s order enforcing the subpoenas. View "EEOC v. AAM Holding Corp." on Justia Law

The plaintiff was stopped by New York State Troopers in Oneida County, New York, on September 4, 2017, after a report of erratic driving. During the stop, Trooper Colton claimed the plaintiff failed field sobriety tests and later registered a high blood alcohol content on a breathalyzer. The plaintiff disputed these findings, alleging the tests were improperly administered and that he passed them. He was arrested and charged with a felony for aggravated unlicensed operation of a motor vehicle, multiple DWI-related misdemeanors, and a traffic infraction. The felony charge was later amended to a misdemeanor before a suppression hearing, after which the city court suppressed evidence due to concerns about Trooper Colton’s credibility. The plaintiff ultimately pled guilty to the traffic infraction, and the remaining DWI-related charges were dismissed.The United States District Court for the Northern District of New York dismissed the plaintiff’s federal lawsuit under 42 U.S.C. § 1983, which alleged false arrest, malicious prosecution, and fabrication of evidence. The district court found that the guilty plea to the traffic infraction established probable cause for the arrest, defeating the false arrest claim. It also held that the plaintiff could not show favorable termination for the malicious prosecution claim because the DWI-related charges were dismissed as part of a plea agreement. The fabrication of evidence claim was dismissed as conclusory and contradicted by Trooper Colton’s testimony.The United States Court of Appeals for the Second Circuit affirmed the dismissal of the false arrest claim and the malicious prosecution claim as to the DWI-related charges dismissed in the plea agreement, holding that a guilty plea to one charge bars a malicious prosecution claim for other charges dismissed as part of the same plea. However, the court vacated the dismissal of the malicious prosecution claim as to the terminated felony charge, finding it plausibly terminated favorably because its dismissal was not clearly part of the plea. The court also reinstated the fabrication of evidence claim, concluding the plaintiff had sufficiently alleged intentional fabrication. The case was remanded for further proceedings on these claims. View "Carruthers v. Colton" on Justia Law

Ferdinand E. Marcos, former President of the Philippines, deposited approximately $2 million in a New York Merrill Lynch account in 1972, which grew to over $40 million. These funds, known as the Arelma Assets, were proceeds of Marcos’s criminal activities. After Marcos’s ouster, multiple parties—including the Republic of the Philippines, a class of nearly 10,000 human rights victims, and the estate of Roger Roxas (from whom Marcos had stolen treasure)—asserted competing claims to these assets. The Republic obtained a forfeiture judgment from a Philippine court and requested the U.S. Attorney General to enforce it under 28 U.S.C. § 2467.The United States District Court for the Southern District of New York reviewed the enforcement application. The court rejected the class’s affirmative defenses, which included arguments based on statute of limitations, subject matter jurisdiction, lack of notice, and fraud. The court also found that Roxas lacked Article III standing because she failed to show a sufficient interest in the Arelma Assets, and denied her leave to amend her answer. The court entered judgment for the Government, allowing the assets to be returned to the Republic of the Philippines.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the class failed to create a genuine dispute of material fact as to any of its affirmative defenses and that Roxas lacked standing to participate as a respondent. The court also upheld the denial of intervention by Golden Budha Corporation, finding its interests adequately represented and lacking standing. The main holding is that the Government’s application to enforce the Philippine forfeiture judgment was timely and proper, and that neither the class nor Roxas could block enforcement or claim the assets. View "In re: Enforcement of Philippine Forfeiture Judgment" on Justia Law

Two New York residents applied for concealed carry firearm licenses under the state’s licensing laws. Their applications were reviewed by a county court judge acting as a statutory licensing officer, who denied both applications. The judge found that one applicant’s criminal arrest history and failure to disclose it demonstrated a lack of maturity and responsibility, while the other applicant’s criminal history, including a youthful-offender adjudication for robbery, similarly indicated he was not qualified for a license.After their applications were denied, the applicants filed a lawsuit in the United States District Court for the Northern District of New York. They sued the judge in both his individual and official capacities under 42 U.S.C. § 1983, alleging violations of their Second and Fourteenth Amendment rights. The district court dismissed the claims against the judge in his individual capacity, holding that absolute judicial immunity applied because the judge was acting in a judicial role. The court also dismissed the official-capacity claims for injunctive and declaratory relief, finding that Article III’s case-or-controversy requirement and § 1983’s limitations barred such claims against a judge acting in this capacity.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The Second Circuit held that judges deciding firearms license applications under New York law act in a judicial capacity and are therefore entitled to absolute immunity from individual-capacity suits for damages. The court further held that Article III’s case-or-controversy requirement bars claims for injunctive and declaratory relief against state court judges in their official capacity when they act as neutral adjudicators without a personal or institutional stake in the challenged law. The judgment of the district court was affirmed. View "Kellogg v. Nichols" on Justia Law

Brian Flores, a current NFL coach, brought a putative class action against the National Football League and several of its member clubs, including the Denver Broncos, New York Giants, and Houston Texans, alleging racial discrimination under federal, state, and local law. Flores’s claims stemmed from his interviews and employment experiences with these teams, during which he alleged discriminatory hiring practices. His employment contracts with various NFL teams incorporated the NFL Constitution, which contains a broad arbitration provision granting the NFL Commissioner authority to arbitrate disputes between coaches and member clubs.The United States District Court for the Southern District of New York reviewed the defendants’ motion to compel arbitration based on Flores’s employment agreements. The District Court granted the motion for claims against the Miami Dolphins, Arizona Cardinals, and Tennessee Titans, but denied it for Flores’s claims against the Broncos, Giants, Texans, and related claims against the NFL. The court found the NFL Constitution’s arbitration provision illusory and unenforceable under Massachusetts law, as it allowed unilateral modification by the NFL and lacked a signed agreement in one instance. The District Court also denied the defendants’ motion for reconsideration.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court’s orders. The Second Circuit held that the NFL Constitution’s arbitration provision, which vested unilateral substantive and procedural authority in the NFL Commissioner, did not qualify for protection under the Federal Arbitration Act and was unenforceable because it failed to guarantee Flores the ability to vindicate his statutory claims in an impartial arbitral forum. The court also affirmed the denial of the motion for reconsideration, concluding there was no abuse of discretion. View "Flores v. N.Y. Football Giants" on Justia Law

Several individuals with developmental disabilities, along with Disability Rights New York (DRNY), an advocacy organization, alleged that New York State agencies responsible for services to people with developmental disabilities caused them to remain in restrictive institutional settings for extended periods, despite being eligible for community-based residential placements. The individual plaintiffs claimed they waited from nine months to six years for such placements, resulting in physical and psychological harm. DRNY, as the state’s designated Protection and Advocacy System, joined the suit, asserting authority to represent the interests of individuals with disabilities under federal law.The United States District Court for the Southern District of New York first addressed the defendants’ motion to dismiss DRNY’s claims for lack of standing, agreeing that DRNY had not suffered an injury in fact and rejecting its argument that federal statutes conferred “congressionally authorized representational standing.” The district court also dismissed the individual plaintiffs’ claims as moot, based on pre-motion letters from the defendants indicating that all individual plaintiffs had since been moved out of institutional facilities. Additionally, the court denied a motion by other individuals seeking to intervene as plaintiffs, finding the motion untimely.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal of DRNY’s claims, holding that DRNY lacked standing because it had not suffered a concrete injury and that Congress could not override Article III’s standing requirements by statute. The Second Circuit also affirmed the denial of the motion to intervene, finding no abuse of discretion in the district court’s timeliness determination. However, the Second Circuit vacated the dismissal of the individual plaintiffs’ claims as moot, holding that the district court erred by dismissing those claims based solely on pre-motion letters without full briefing or a hearing. The case was remanded for further proceedings on the individual plaintiffs’ claims. View "A.H. v. N.Y. State Dep't of Health" on Justia Law

Angel Diaz, a prisoner in the custody of the New York State Department of Corrections and Community Supervision (DOCCS), filed a pro se petition for a writ of habeas corpus in the Southern District of New York. Diaz argued that due to the COVID-19 pandemic, the State could not provide him with constitutional conditions of confinement at any of its facilities, necessitating his release. He claimed that his high blood pressure and morbid obesity put him at severe risk of serious harm or death from COVID-19 and that DOCCS had no plan to protect medically vulnerable inmates like himself.The District Court referred the case to a magistrate judge, who recommended denying the petition on the grounds that Diaz's claim was not cognizable in habeas and should be brought under 42 U.S.C. § 1983 instead. The District Court adopted this recommendation, holding that Diaz's complaints about the conditions of his confinement did not challenge the validity or duration of his confinement. Diaz's request for a certificate of appealability was initially denied by the District Court but later granted by the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit reviewed the case and held that Diaz's claim was indeed cognizable under habeas corpus because he alleged violations of the Constitution that would require his release from all available facilities. However, the court found that Diaz failed to provide sufficient factual support to make his claim plausible. As a result, the Second Circuit affirmed the District Court's decision to dismiss the petition. View "Diaz v. Kopp" on Justia Law

Samantha Long, a former Clerk of the Town Justice Court for the Town of New Lebanon, filed a lawsuit against the Town of New Lebanon and Jessica Byrne, a former Town Justice. Long alleged that she was unlawfully terminated in retaliation for cooperating with an investigation by the New York State Commission on Judicial Conduct into Byrne’s suspected judicial misconduct. Long claimed that she provided specific case files to the Commission and refused to discuss the investigation with Byrne, which led to her termination. She argued that her termination violated her First Amendment rights and her rights under New York State Civil Service Law § 75-b.The United States District Court for the Northern District of New York dismissed Long’s claims. The court concluded that Long’s actions were not protected by the First Amendment because they were part of her official duties as Court Clerk and did not constitute protected citizen speech. Consequently, the court declined to exercise supplemental jurisdiction over Long’s Section 75-b claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court’s judgment and remanded the case for further proceedings. The appellate court held that Long’s complaint adequately alleged that she acted as a private citizen, not pursuant to her work responsibilities, when she cooperated with the Commission’s investigation and refused to discuss it with Byrne. The court emphasized that Long’s refusal to discuss the investigation with Byrne was not within the scope of her job duties and that her cooperation with the Commission was motivated by a sense of civic duty rather than employment-related responsibilities. The court also vacated the district court’s dismissal of Long’s state-law claim under Section 75-b, as the legal premise for the dismissal was defeated by the reinstatement of her First Amendment claim. View "Long v. Byrne" on Justia Law

In 2014, Tyrone Walker, who had been in solitary confinement for punitive reasons since 2000, was placed in solitary confinement as a preventative measure by prison officials, based on a determination that he posed a threat to prison security. The officials were constitutionally obligated to conduct regular, meaningful reviews of Walker’s solitary confinement. Walker argued that the reviews he received were not constitutionally meaningful, as they did not adequately assess his current threat level or consider his behavior over time.The United States District Court for the Northern District of New York granted summary judgment to the defendants, ruling that Walker demonstrated no genuine issues of material fact regarding the constitutional meaningfulness of his reviews. The court also decided that all defendants were entitled to qualified immunity because no clearly established right of Walker’s had been violated during the review process.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that a reasonable jury could find that the reviews Walker received during his continued solitary confinement were not constitutionally meaningful. The court noted that the reviews were repetitive and rote, failed to consider Walker’s positive behavior, and often used circular logic to justify his continued confinement. Additionally, the court found that the delays in completing and providing the reviews to Walker raised genuine issues of material fact regarding the meaningfulness of the process.The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings, emphasizing that the focus was on the procedural due process rights of Walker, not the substantive outcome of his confinement. The court also determined that it was premature to grant qualified immunity to the defendants at this stage. View "Walker v. Bellnier" on Justia Law

Plaintiffs, thirty survivors of childhood sexual abuse, sought damages for negligence from the Holy See under a vicarious liability theory. They alleged that the Holy See promulgated a mandatory policy of secrecy that governed how its dioceses and bishops handled reports of sexual abuse by clerics. Plaintiffs claimed that bishops in New York failed to warn children and parents of the dangers posed by the accused clerics and failed to report suspected abuse to law enforcement, thus emboldening abusers and exposing children to harm.The District Court granted the Holy See’s motion to dismiss for lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The court concluded that the discretionary function exclusion from the FSIA’s tortious activity exception barred Plaintiffs’ claims. The court found that the bishops’ conduct was discretionary and susceptible to policy analysis, thus falling within the discretionary function exclusion.The United States Court of Appeals for the Second Circuit reviewed the case de novo and affirmed the District Court’s judgment. The appellate court agreed that the discretionary function exclusion applied, precluding federal courts from exercising jurisdiction over the claims against the Holy See. The court held that the bishops’ challenged conduct involved discretionary acts and that Plaintiffs failed to allege that the bishops’ conduct violated a mandatory policy. Additionally, the court found that the bishops’ conduct was susceptible to policy analysis, satisfying the second prong of the Berkovitz/Gaubert test. Therefore, the discretionary function exclusion barred the exercise of jurisdiction over Plaintiffs’ claims against the Holy See. View "Blecher v. Holy See" on Justia Law