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

Plaintiffs, former New York state prisoners who brought separate actions in the district court and whose appeals have been consolidated in this court, appealed from the district court's judgment dismissing their complaints against officials of the New York State DOCS and the Parole Division. The complaints, brought under 42 U.S.C. 1983 for damages and declaratory relief, alleged that defendants violated plaintiffs' due process rights as announced in Hill v. United States ex rel. Wampler and described in Earley v. Murray, by administratively imposing and enforcing conditions of supervision on plaintiffs following their release from prison, despite the absence of any order for such supervision by the courts that sentenced plaintiffs for their crimes. The court concluded that Earley I did not rule that the rights asserted by plaintiffs were clearly established by Wampler with respect to a defense of qualified immunity; but the court concluded that Earley I itself did clearly establish the unconstitutionality of the administrative imposition or enforcement of postrelease conditions that were not judicially imposed. Accordingly, the court affirmed in part and vacated and remanded in part. View "Vincent v. Yelich; Earley v. Annuci" on Justia Law

Plaintiffs, labor organizations and state employees, brought this action contending that defendants, state officials, violated their First Amendment right to freedom of association. The court concluded that, on the stipulated facts, defendants violated plaintiffs' rights by targeting union employees for firing based on their union membership. Therefore, the court reversed the district court's grant of summary judgment to defendants; remanded to the district court with instruction to grant summary judgment to plaintiffs on their First Amendment claim and to craft appropriate equitable relief; reversed the district court's dismissal on the pleadings of plaintiffs' claims against defendants in their individual capacities; and remanded those claims for further proceedings. View "State Employees Bargaining Agent Coalition v. Rowland" on Justia Law

The United States brought suit pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., alleging racial discrimination in the hiring of New York City firefighters. On appeal, the City of New York, Mayor Michael Bloomberg, and former Fire Commissioner Nicholas Scoppetta challenged the district court's order issuing an injunction against the City with respect to the hiring of entry-level firefighters. Intervenors cross-appealed a partial final judgment dismissing their federal and state law claims against Mayor Bloomberg and Commissioner Scoppetta. The City, inter alia, sought review of an order granting Intervenors summary judgment on their disparate treatment claim. The court concluded that (1) summary judgment was improperly entered on Intervenors' disparate treatment claims; (2) the federal and state law claims against Mayor Bloomberg were properly dismissed, as were the state law claims against Commissioner Scopetta, but the federal law claims against Commissioner Scoppetta should be reinstated; (3) most portions of the injunction based on the unchallenged disparate impact finding were within the district court's remedial discretion, but other portions, particularly those portions based on the improper discriminatory treatment ruling, exceeded that discretion; and (4) on remand, the bench trial on the liability phase of the disparate treatment claim against the City should be reassigned to a different district judge. Therefore, the court affirmed in part, vacated in part, and remanded. View "United States v. City of New York" on Justia Law

The City amended it's zoning laws to prohibit the nonconforming use of non-owner-occupied multiple dwellings in various zoning districts. Plaintiffs alleged that the City's failure to notify them, as affected property owners, prior to enacting this zoning change violated their due process rights under the Fourteenth Amendment. The court affirmed the district court's conclusion that the change of zoning rules did not offend the procedural guarantees of the Due Process Clause because the zoning amendment was prospective and generally applicable, and was therefore "legislative" in character rather than "adjudicative." View "Edelhertz v. City of Middletown" on Justia Law

Plaintiff sued her former employer asserting claims of gender discrimination and retaliation under the New York City Human Rights Law (NYCHRL), N.Y.C. Admin. Code 8-107(1)(a), (7). The district court granted summary judgment to the employer and dismissed the complaint. The court concluded, however, that the district court erred in granting summary judgment because the record presented genuine disputes of material fact regarding both plaintiff's claims under the NYCHRL. Accordingly, the court vacated the judgment and remanded for trial. View "Mihalik v. Credit Agricole Cheuvreux N. Am., Inc." on Justia Law

Plaintiff filed suit under Title VII and the New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq., alleging that an affair that one of her brothers had with another worker in their family business created a hostile work environment and that both of her brothers retaliated against her for complaining about the affair. On appeal, plaintiff challenged the dismissal of her retaliation claim. The court examined all of plaintiff's arguments on appeal and found them to be without merit. Because there was no indication that plaintiff believed that her sex had anything to with her treatment or that defendants could have understood her statements as such, she failed to establish a prima facie case for retaliation under Title VII and the NYSHRL. Accordingly, the court affirmed the district court's judgment. View "Kelly v. Howard I. Shapiro & Assocs. Consulting Eng'rs., P.C." on Justia Law

Plaintiff, a New York State prisoner who had been administratively confined since 2003, appealed the district court's dismissal of his amended complaint. The complaint, brought pursuant to 42 U.S.C. 1983, alleged that plaintiff's due process rights have been violated because the decisions to continue his confinement in a Special Housing Unit (SHU) have been based on evidence that should have been expunged from his record, the periodic reviews have been perfunctory and meaningless, and the reasons given for his continued confinement have been false or misleading. Because plaintiff had previously lost a similar suit, the district court dismissed the complaint on the grounds that the present action was barred by principles of res judicata and collateral estoppel. The court concluded that the district court's applications of claim preclusion and issue preclusion, which the court reviewed de novo and in light of Computer Associates International, Inc. v. Altai, Inc., were in large part erroneous. Accordingly, the court vacated and remanded for further proceedings. View "Proctor v. LeClaire" on Justia Law

NOM, a nonprofit advocacy organization, appealed the district court's dismissal of its amended complaint for lack of subject-matter-jurisdiction. NOM was seeking declaratory and injunctive relief, arguing that New York Election Law 14-100.1, which defined the term "political committee" for the purposes of state elections, violated the First Amendment. The court determined that NOM's case presented a live controversy that was ripe for consideration and vacated the district court's determination that it lacked jurisdiction. Because that conclusion prevented the district court from reaching the merits of NOM's claims, the court declined to comment on the substance of NOM's claims in the first instance. Therefore, the court remanded for further proceedings. View "National Organization for Marriage, Inc. v. Walsh" on Justia Law

Plaintiff was convicted of attempted murder in the second degree and subsequently pled guilty to a lesser charge for which the penalty was a one-year sentence - a jail term that he had already served. Plaintiff then brought the instant action under 42 U.S.C. 1983, alleging Brady violations against the officials who conducted his original investigation and prosecution. The district court granted defendants' motion for summary judgment, ruling that plaintiff's section 1983 claims were barred under Heck v. Humphrey. The court concluded, however, that because plaintiff was no longer in custody, and therefore could no longer bring a federal habeas suit, Heck's narrow exception to section 1983's otherwise broad coverage did not apply. Plaintiff may bring suit under section 1983 regardless of any defenses which might arise based on his subsequent guilty plea to the lesser charge. Accordingly, the court vacated the district court's decision granting summary judgment and remanded for further proceedings. View "Poventud v. City of New York" on Justia Law

Plaintiff appealed the district court's dismissal of her claims of employment discrimination and retaliation under federal, state, and New York City law. Plaintiff claimed that defendants unfairly reprimanded her, observed her classroom with unusual frequency, evaluated her classroom performance negatively, and gave her less desirable classroom assignments and duties. She argued that these actions were unwarranted and motivated by discriminatory and retaliatory animus. Defendants acknowledged that they increased their supervision of and attention toward plaintiff, but they contended that they did so to address her performance and behavioral issues. The court concluded that the district court properly granted summary judgment in favor of defendants for substantially the reasons articulated by the district court. With respect to plaintiff's retaliation claims, even if the court assumed that defendants' actions resulted in adverse employment action, no reasonable jury could find that such actions were motivated by a retaliatory animus. Accordingly, the court affirmed the judgment in its entirety. View "Sotomayor v. City of New York" on Justia Law