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

Plaintiff was arrested for third-degree menacing under New York law and brought an action against defendants for false arrest, malicious prosecution, and violation of his constitutional rights under 42 U.S.C. 1983. Plaintiff also sued the City of White Plains under section 1983 for failure to train and supervise the arresting officers. Plaintiff approached a woman in her driveway, questioned her about members of her household, and insisted that her car had hit his. On appeal, plaintiff challenged the district court's grant of summary judgment for defendants. The court vacated the judgment of the district court. The order granting summary judgment to all defendants on the theory that the officers were entitled to qualified immunity was reversed; denying partial summary judgment on plaintiff's state law false arrest claims against the arresting officers and the City was reversed; and denying partial summary judgment for plaintiff against the officers under section 1983 was reversed. The court affirmed the district court's grant of summary judgment for defendants on the Monell claim and the dismissal of all malicious prosecution claims under New York law and section 1983. The court remanded with instructions to grant plaintiff partial summary judgment on liability for his state law false arrest claims against the officers and the City; against the officers under section 1983 for his false arrest claims; and for the dismissal of the affirmative defenses of probable cause. View "Ackerson v. City of White Plains" on Justia Law

Plaintiffs appealed from the district court's grant of summary judgment in favor of defendants. Plaintiff sought declaratory and injunctive relief under 42 U.S.C. 1983, barring New York State handgun licensing officials from requiring that applicants prove "proper cause" to obtain licenses to carry handguns for self-defense pursuant to New York Penal Law section 400.00(2)(f). They argued that application for section 400.00(2)(f) violated the Second and Fourteenth Amendments to the Constitution. Because the proper cause requirement was substantially related to New York's compelling interests in public safety and crime prevention, the court affirmed the judgment. View "Kachalsky v. Cacace" on Justia Law

Plaintiff filed an action under 42 U.S.C. 1983, alleging that defendants unlawfully retaliated against him after he spoke out about issues involving his employer, the Long Beach Fire Department. The district court dismissed some of the claims against some of the defendants and the remaining individual defendants sought to appeal the denial of their dismissal motion, raising a defense of qualified immunity. The court held, however, that it lacked jurisdiction to consider their appeal because they did not file a timely notice of appeal that specified that they intended to appeal. View "Gusler v. The City of Long Beach" on Justia Law

Plaintiff appealed from the district court's dismissal of his claims under Title II of the Americans with Disabilities Act, 42 U.S.C. 12131 et seq., and Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794 et seq., following the district court's grant of defendant's motion for summary judgment. Plaintiff was dismissed from Valley View's volunteer program after engaging in erratic and harassing behavior towards female staff. The court affirmed the judgment, concluding that plaintiff failed to present sufficient evidence to raise a genuine issue of fact as to whether he was discriminated against because of his disability. View "McElwee v. County of Orange" on Justia Law

Defendant, the Superintendent of the Connecticut Technical High School System, renewed a motion for summary judgment, arguing that she was entitled to qualified immunity in this 42 U.S.C. 1983 action in which defendant was alleged to have deprived plaintiff of her right to procedural due process. The district court denied the motion after concluding that there existed a dispute of material fact as to whether plaintiff received sufficient notice before the elimination of her position as a guidance counselor at a Connecticut high school. The court held that defendant's conduct in this case, even when viewed in the light most favorable to plaintiff, did not violate plaintiff's clearly established rights. Therefore, defendant was entitled to qualified immunity. The court reversed and remanded. View "Coollick v. Hughes" on Justia Law

The EEOC appealed from a post-judgment order by the district court denying its request for injunctive relief against defendant following a jury verdict finding defendant liable for sexual harassment and fostering a sexually hostile work environment, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and New York State law. The court held that the district court abused its discretion in denying any injunctive relief to the EEOC. At minimum, the district court was obliged to craft injunctive relief sufficient to prevent further violations of Title VII by the individual who directly perpetrated the egregious sexual harassment at issue in this case. Accordingly, the court vacated and remanded for further proceedings. View "Equal Employment Opportunity v. KarenKim, Inc." on Justia Law

Intervenor appealed from the district court's grant of summary judgment in favor of plaintiff. Plaintiff sued as surviving spouse of a same-sex couple that was married in Canada in 2007 and was resident in New York at the time of her spouse's death in 2009. Plaintiff was denied the benefit of the spousal deduction for federal estate taxes under 26 U.S.C. 2056(A) solely because Section 3 of the Defense of Marriage Act (DOMA), 1 U.S.C. 7, defined the words "marriage" and "spouse" in federal law in a way that barred the IRS from recognizing plaintiff as a spouse or the couple as married. The court held that plaintiff had standing in this action; plaintiff's suit was not foreclosed by Baker v. Nelson; Section 3 of DOMA was subject to intermediate scrutiny under the factors enumerated in City of Cleburn v. Cleburn Living Center, and other cases; and the statute did not withstand that review because it violated equal protection and was therefore unconstitutional. View "Windsor v. United States" on Justia Law

Defendant, a former police officer, appealed the district court's judgment, awarding compensatory and punitive damages to plaintiff on his claim of excessive force and battery. The court concluded that the district court did not exceed its discretion in refusing to grant a continuance because the court's decision was neither arbitrary nor prejudicial to defendant's defense. The court agreed, however, with defendant that the punitive damages award was excessive and concluded that a reduced award would more accurately reflect the severity of defendant's misconduct. View "Payne v. Jones" on Justia Law

This appeal concerned a longstanding land-use dispute between the Church and the Town over the Church's plan to build a worship facility and school on land that it owned within the Town. The Town appealed from the district court's holding that they violated the Church's rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., as well as the First Amendment, the Equal Protection Clause, and New York constitutional and statutory law. The court concluded that the Town's arguments on appeal were without merit and concluded that the district court correctly applied the law, discerning no clear error in its factual findings. Accordingly, the court affirmed the judgment. View "Fortress Bible Church v. Feiner" on Justia Law

Plaintiff sued defendants, Queens County Assistant District Attorneys, alleging that defendants' interrogation of her following the arrest of her boyfriend, former New York State Senator Hiram Monserrate, violated her civil rights. Defendants appealed from the denial of absolute immunity in an action brought under, inter alia, 42 U.S.C. 1983. The court concluded that, viewed through the eye of a reasonable prosecutor, defendants' acts in the present case were well within their legitimate functions as prosecutors. Because the objective circumstances triggered absolute immunity, the court vacated the district court's order denying absolute immunity and remanded for further proceedings. View "Giraldo v. City of New York" on Justia Law