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

Plaintiff filed suit under 42 U.S.C. 1983 against New York City and NYPD officers, alleging claims for false arrest and use of excessive force in violation of the Fourth Amendment, and retaliation in violation of the First Amendment. The officers arrested plaintiff after a scuffle that occurred while plaintiff was searching for a bathroom. Earlier that evening, plaintiff had gone to Zuccotti Park to observe the Occupy Wall Street crowd. The court concluded that plaintiff's claim against the officers for unlawful arrest is defeated by their defense of qualified immunity, her First Amendment claim was properly dismissed as lacking any merit, and her claim against them for use of excessive force must be remanded for trial. The court did not need to consider plaintiff's claims against the City because her brief on appeal does not challenge the dismissal of those claims. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Brown v. City of New York" on Justia Law

Plaintiffs, current and former inmates of the Eastern Correctional Facility, filed suit alleging that a corrections officer sexually abused them and thus subjected them to cruel and unusual punishment. The district court dismissed the case. The court agreed with the district court that the complaint failed to state a claim under Boddie v. Schnieder. Boddie set forth the standard for stating an Eighth Amendment claim arising from sexual abuse in prison. The court clarified that a corrections officer’s intentional contact with an inmate’s genitalia or other intimate area, which serves no penological purpose and is undertaken with the intent to gratify the officer’s sexual desire or to humiliate the inmate, violates the Eighth Amendment. Further, the court recognized that sexual abuse of prisoners deeply offends today's standards of decency and the proper application of the rule in Boddie must reflect such standards. In this case, plaintiffs stated a cognizable Eighth Amendment claim by alleging that the officer fondled their genitals for personal gratification and without penological justification. Accordingly, the court reversed and remanded. View "Crawford v. Cuomo" on Justia Law

Plaintiff filed suit against the City, individual detectives and officers, and the City's Chief of Police, under 42 U.S.C. 1983, after plaintiff's rib was broken and his spine was broken in two places. The court concluded that the district court's summary judgment dismissal of the section 1983 claim against Detective Watson for use of excessive force was error because no officer in 2009 could reasonably have believed it permissible under the Fourth Amendment to jump on the back of a prone and compliant suspect gratuitously, with sufficient force to break his spine and rib. Accordingly, the court vacated to the extent that it dismissed plaintiff's section 1983 claim against Watson for the use of excessive force and his state-law claims related to the use of excessive force. The court affirmed in all other respects. The matter is remanded for further proceedings. View "Rogoz v. City of Hartford" on Justia Law

Plaintiff filed suit against the City, individual detectives and officers, and the City's Chief of Police, under 42 U.S.C. 1983, after plaintiff's rib was broken and his spine was broken in two places. The court concluded that the district court's summary judgment dismissal of the section 1983 claim against Detective Watson for use of excessive force was error because no officer in 2009 could reasonably have believed it permissible under the Fourth Amendment to jump on the back of a prone and compliant suspect gratuitously, with sufficient force to break his spine and rib. Accordingly, the court vacated to the extent that it dismissed plaintiff's section 1983 claim against Watson for the use of excessive force and his state-law claims related to the use of excessive force. The court affirmed in all other respects. The matter is remanded for further proceedings. View "Rogoz v. City of Hartford" on Justia Law

Plaintiffs, a group of religious non-profit organizations affiliated with the Roman Catholic Archdiocese, filed suit challenging regulations promulgated under the Patient Protection and Affordable Care Act of 2010, Pub. L. No. 111-148, 124 Stat. 119. The district court concluded that regulations promulgated under the Act that allow religious non-profit employers to opt out of providing contraceptive coverage themselves violate these religious employers’ rights under the Religious Freedom Restoration Act, 42 U.S.C. 2000bb et seq. The court concluded, however, that the challenged accommodation for religious objectors relieves, rather than imposes, any substantial burden on plaintiffs’ religious exercise, and thus does not violate the Religious Freedom Restoration Act. Accordingly, the court reversed the district court's judgment. View "Catholic Health Care Sys. v. Burwell" on Justia Law

Plaintiffs, a group of religious non-profit organizations affiliated with the Roman Catholic Archdiocese, filed suit challenging regulations promulgated under the Patient Protection and Affordable Care Act of 2010, Pub. L. No. 111-148, 124 Stat. 119. The district court concluded that regulations promulgated under the Act that allow religious non-profit employers to opt out of providing contraceptive coverage themselves violate these religious employers’ rights under the Religious Freedom Restoration Act, 42 U.S.C. 2000bb et seq. The court concluded, however, that the challenged accommodation for religious objectors relieves, rather than imposes, any substantial burden on plaintiffs’ religious exercise, and thus does not violate the Religious Freedom Restoration Act. Accordingly, the court reversed the district court's judgment. View "Catholic Health Care Sys. v. Burwell" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983 for false arrest, malicious prosecution, and denial of a fair trial. Defendants Velez and Lukeson, officers of the NYPD, and Defendant Calhoun, an NYPD sergeant, appealed from the district court's order that Velez and Lukeson each pay to plaintiff $180,000 in compensatory and punitive damages, and ordering Calhoun to pay $200,000 in compensatory and punitive damages. The court rejected defendants' claims of various evidentiary errors, including the admissibility of the Norman Confession, framing plaintiff, under Federal Rules of Evidence 804(b)(3). The court also rejected defendants' claims of error regarding jury deliberations where each issue was appropriately dealt with by the district court and none of defendants' contentions warrant extended discussion. Finally, defendants were not entitled to judgment as a matter of law dismissing the claims against them for malicious prosecution where, even if the court were persuaded that the malicious prosecution claims against Lukeson and Calhoun should have been dismissed, there would be no basis on which to overturn the verdicts against them for denial of a fair trial or to find that the damages awarded were impermissible with respect to the fair trial verdicts. Accordingly, the court affirmed the judgment. View "Davis v. Velez" on Justia Law

Plaintiffs are commercial trucking companies, their national trade association, and a putative class of commercial truckers. Plaintiff filed suit against the Thruway Authority under 42 U.S.C. 1983, alleging that the Thruway Authority charges excessive tolls in violation of the Commerce Clause because it diverts excessive highway tolls to fund maintenance and improvements of unrelated projects. The district court dismissed the suit under Rule 12(b)(7) for failure to join the State of New York as a necessary party under Rule 19. The court reversed and remanded, concluding that the district court abused its discretion because the State of New York is not a necessary party under Rule 19(a). View "Am. Trucking Ass'n v. N.Y. State Thruway Auth." on Justia Law

Plaintiff filed suit against the City and three supervisors at ACS under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981 and 1983, alleging that she was subjected to a hostile work environment and disparate treatment based on race, and retaliated against because of complaints about such discrimination. Plaintiff also alleged that she was sexually harassed in violation of Title VII. The district court granted defendants' motion to dismiss. The court vacated the district court's judgment granting defendants' motion to dismiss with respect to plaintiff's disparate treatment and retaliation claims against the City under Title VII; plaintiff's disparate treatment claim against Defendant Baker under sections 1981 and 1983 where only Baker was involved in the decision to demote plaintiff; and plaintiff's retaliation claim against Baker under section 1981 where she alleged facts that would be sufficient to establish a prima facie case of retaliation. The court affirmed as to the other claims. The court remanded for further proceedings. View "Littlejohn v. City of New York" on Justia Law

Plaintiffs, individuals employed by the DSNY, filed a putative class action under the Fourteenth Amendment Equal Protection Clause; 42 U.S.C. 1981; Title VII, 42 U.S.C. 2000e; and New York State and City human rights laws, alleging that defendants discriminated against them and others similarly situated on the basis of their race and/or national origin in the DSNY's promotional practices. The district court dismissed all of plaintiffs’ claims. The court concluded that the district court’s decision granting defendants’ motion to dismiss the Equal Protection and section 1981 claims is affirmed. The court held that, to show discriminatory intent in a section 1981 or Equal Protection case based on statistics alone, the statistics must not only be statistically significant in the mathematical sense, but they must also be of a level that makes other plausible non-discriminatory explanations very unlikely. In this case, plaintiffs have failed to allege statistics that meet these standards. Furthermore, the fact that each of the plaintiffs has been promoted at some point undermines their allegations of discrimination in the promotion of sanitation workers to supervisors. The court also concluded that the Title VII claim must be dismissed for failure to exhaust administrative remedies. Accordingly, the court affirmed the judgment. View "Burgis v. New York City Dep’t of Sanitation" on Justia Law