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

Mary Doe, a social worker proceeding under a pseudonym, challenged New York’s Reproductive Health Act (RHA), arguing it violated constitutional rights. Doe sought to represent a class of viable fetuses, claiming the RHA’s decriminalization of abortion and elimination of fetal homicide laws harmed them. She also sought to amend her complaint post-judgment to include a specific fetus, "Baby Nicholas," alleging he faced harm due to the RHA.The United States District Court for the Northern District of New York dismissed Doe’s claims for lack of standing, denying her motion to be appointed as "next friend" to the fetuses, citing her lack of a significant relationship with them. The court also denied her post-judgment motion to amend the complaint, finding it futile as Baby Nicholas lacked standing.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed that the district court erred in requiring a significant relationship for next friend appointments under Federal Rule of Civil Procedure 17(c). However, it affirmed the dismissal of Doe’s claims on the grounds that she failed to identify or describe any specific member of the viable fetus class, thus failing to establish a live case or controversy under Article III.Regarding the post-judgment motion, the Second Circuit affirmed the district court’s denial, concluding that Baby Nicholas lacked standing. The court found that the alleged risks to Baby Nicholas were not imminent and traceable to the RHA, as required for standing. The potential harm from a third party was not sufficiently connected to the RHA’s provisions.The Second Circuit affirmed the district court’s judgment, maintaining the dismissal of Doe’s claims and denying the motion to amend the complaint. View "Doe v. Hochul" on Justia Law

Plaintiff-Appellant Mansoor Hamoud Hadwan, a natural-born U.S. citizen, has been stranded in Yemen for twelve years. In 2013, he visited the U.S. Embassy in Sana’a, Yemen, to apply for immigration paperwork for his children. During this visit, embassy staff retained his Consular Report of Birth Abroad (CRBA) and U.S. passport. Nine months later, the U.S. Department of State formally revoked both documents, alleging they were fraudulently obtained. Hadwan was unable to attend his hearing challenging the revocation.The United States District Court for the Southern District of New York upheld the State Department's decision to revoke Hadwan's documents. The court found that Hadwan had waived most of his arguments by not presenting them at the agency hearing, which he was not permitted to attend. The court also found that the State Department's hearing process did not violate due process requirements.The United States Court of Appeals for the Second Circuit reviewed the case and found that the State Department erred in two ways. First, the decision to uphold the revocation was arbitrary and capricious, violating the Administrative Procedure Act, because it failed to consider material, undisputed facts about Hadwan’s English literacy, which raised doubts about the reliability of his alleged confession statement. Second, the State Department violated Hadwan’s constitutional due process rights by revoking his documents without providing him an opportunity to be heard in a meaningful manner. The court reversed the district court's judgment and the State Department's decision, ordering the State Department to return Hadwan’s CRBA and expired passport so he may reapply for a new passport if he chooses. View "Hadwan v. US Dep't of State" on Justia Law

A group of landlords and property owners in New York's Hudson Valley region challenged the constitutionality of the 2023 amendments to New York's rent stabilization law. These amendments, known as the Vacancy Provisions, allow municipalities to impose civil penalties on landlords who do not cooperate with vacancy surveys and to presume zero vacancies for nonresponsive landlords. The landlords argued that these provisions authorize warrantless searches of their records without an opportunity to challenge the searches' scope, violating the Fourth Amendment, and that they prevent landlords from contesting vacancy calculations, violating procedural due process under the Fourteenth Amendment.The United States District Court for the Northern District of New York denied the landlords' motion for a preliminary injunction and dismissed their complaint for failure to state a claim. The landlords appealed the decision.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court held that the Vacancy Provisions are facially valid under the Fourth Amendment because landlords have adequate pre-compliance review available under Article 78 of the New York Civil Practice Law and Rules. The court also found that the searches authorized by the Vacancy Provisions are not unreasonable in every situation, given the ample notice and minimal penalties involved. Additionally, the court held that the Vacancy Provisions do not violate procedural due process because landlords can contest vacancy calculations at public hearings before rent stabilization is adopted and through Article 78 after adoption. View "Hudson Shore v. State of New York" on Justia Law

Mohsen Mahdawi, a Lawful Permanent Resident and undergraduate student at Columbia University, was arrested during his naturalization interview in Vermont. He was detained and served with a Notice to Appear, indicating that the U.S. Secretary of State had determined he was removable under the Immigration and Nationality Act. Mahdawi filed a habeas petition, claiming his arrest and detention were in retaliation for his advocacy on the war in Gaza, violating his First and Fifth Amendment rights. The district court issued a temporary restraining order (TRO) preventing his removal from Vermont and later granted his release on bail, finding he was neither a flight risk nor a danger to the community.The United States District Court for the District of Vermont initially granted Mahdawi’s emergency motion for a TRO and later extended it. The court also granted his motion for release on bail pending the resolution of his habeas petition. The government sought an emergency stay of these orders, arguing that the district court lacked jurisdiction over Mahdawi’s habeas petition and the authority to order his release.The United States Court of Appeals for the Second Circuit reviewed the case and denied the government’s motion for a stay. The court found that the government was unlikely to succeed on its arguments that the district court lacked jurisdiction over Mahdawi’s habeas petition and the authority to order his release. The court also concluded that the government had not demonstrated irreparable injury and that the balance of equities tipped in favor of denying the stay. Consequently, the government’s motion for a stay and request for a writ of mandamus were both denied. View "Mahdawi v. Trump" on Justia Law

Kenneth Michael Sikorsky purchased a property in Newburgh, New York, in 2006 but fell behind on his property taxes, leading to foreclosure by the City of Newburgh in 2012. Sikorsky and the City later agreed on a contract for Sikorsky to repurchase the property, but the sale fell through when Sikorsky failed to make the required payments. The City subsequently sold the property for $350,500, significantly more than the $92,786.24 Sikorsky owed in taxes, but did not return the surplus to Sikorsky.The United States District Court for the Southern District of New York dismissed Sikorsky's pro se complaint, which alleged a constitutional taking and violations of New York state laws. Sikorsky, now represented by counsel, appealed the dismissal, arguing that he had stated a valid claim under the Takings Clause of the Fifth Amendment and that he had a right to recover under new New York state laws enacted during the appeal.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Sikorsky had indeed stated a claim for a constitutional taking against the City of Newburgh and Jeremy Kaufman. The court found that the new New York laws did not provide Sikorsky with a remedy, as they only applied to properties sold on or after May 25, 2023, or to those with active proceedings under N.Y. CPLR § 7803(1) on the effective date of the act. Since Sikorsky's property was sold in June 2021 and he had not initiated an Article 78 proceeding, he lacked a local remedy.The Second Circuit vacated the District Court's dismissal of Sikorsky's constitutional taking claims against the City of Newburgh and Jeremy Kaufman and remanded the case for further proceedings consistent with its opinion. View "Sikorsky v. City of Newburgh" on Justia Law

Darrell Robinson was convicted of being a felon in possession of firearms, in violation of 18 U.S.C. § 922(g), after law enforcement officers found six firearms in his vehicle during a search. Robinson pled guilty to the charge and was sentenced to 50 months’ imprisonment and three years of supervised release. The district court also imposed a special condition of supervised release that allowed for the search of Robinson’s electronic devices upon reasonable suspicion of a violation of a condition of supervision.The United States District Court for the Eastern District of New York adopted the Presentence Investigation Report (PSR) without modification and imposed the special search condition as recommended in the PSR. Robinson did not object to the PSR or the special condition during sentencing but later moved to correct the judgment, arguing that the electronic search condition was not orally pronounced at sentencing. The district court denied the motion, finding that it had met its obligation by referencing the PSR.The United States Court of Appeals for the Second Circuit reviewed Robinson’s appeal, where he argued that the electronic search condition was not orally pronounced, was procedurally unreasonable, and violated his Fourth Amendment rights. The court found that the district court’s reference to the PSR was sufficient to impose the special condition, and the need for the condition was self-evident given Robinson’s extensive criminal history and dishonesty with law enforcement. The court also held that the condition, which required reasonable suspicion, did not violate Robinson’s Fourth Amendment rights due to his diminished expectation of privacy while on supervised release.The Second Circuit affirmed the judgment of the district court, upholding the special condition of supervised release allowing for the search of Robinson’s electronic devices. View "United States v. Robinson" on Justia Law

In 2020, Article 13 LLC filed a quiet title action against LaSalle National Bank Association (now U.S. Bank) to discharge a mortgage as time-barred, arguing that the statute of limitations had expired since a foreclosure action was commenced in 2007. U.S. Bank contended that the statute of limitations had not expired because the 2007 foreclosure action was invalid to accelerate the mortgage debt. The district court found a disputed issue of material fact regarding the validity of the 2007 foreclosure action and denied both parties' motions for summary judgment.Following the district court's ruling, New York enacted the Foreclosure Abuse Prevention Act (FAPA), which bars the defense of the invalidity of prior accelerations of mortgages in quiet title actions. Article 13 LLC moved for reconsideration, and the district court applied FAPA retroactively, granting summary judgment in favor of Article 13 LLC. U.S. Bank appealed, arguing that FAPA should not be applied retroactively and that such retroactivity would be unconstitutional under both the New York and U.S. Constitutions.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the questions of FAPA's retroactivity and its constitutionality under the New York Constitution were novel and essential to the resolution of the appeal. Consequently, the Second Circuit certified two questions to the New York Court of Appeals: whether Section 7 of FAPA applies to foreclosure actions commenced before the statute's enactment, and whether FAPA's retroactive application violates substantive and procedural due process under the New York Constitution. The Second Circuit deferred its resolution of the appeal pending the New York Court of Appeals' response. View "Article 13 LLC v. Lasalle Nat'l Bank Ass'n" on Justia Law

Willie Dennis was convicted of three counts of cyberstalking under 18 U.S.C. § 2261A(2)(B) for sending repeated abusive electronic communications to his former partners at the law firm K&L Gates LLP after his ouster from the partnership. Dennis argued that the statute was unconstitutional as applied to his case because the trial evidence was insufficient to prove that his communications constituted "true threats" of physical harm, which would fall outside the First Amendment's protection of free speech. He also contended that erroneous jury instructions allowed the jury to find him guilty without proof of true threats and that he was unduly prejudiced by trial rulings and the trial judge's statements about his pro se status.The United States District Court for the Southern District of New York convicted Dennis on three counts of cyberstalking. Dennis appealed, arguing that the evidence was insufficient to prove true threats and that the jury instructions were erroneous. He also claimed that he was prejudiced by the exclusion of certain evidence and by the trial judge's comments.The United States Court of Appeals for the Second Circuit reviewed the case and found that the evidence was sufficient to permit a reasonable jury to find true threats in Dennis's communications to two of the victims, Bicks and Bostick, but insufficient as to the third victim, Cottle. The court held that Dennis's conviction on Count Two must be reversed due to insufficient evidence of true threats. The court also found that Dennis's failure to raise a true-threat challenge to the jury instructions in the district court limited appellate review to plain error, which was not evident. The court concluded that Dennis's other arguments were without merit.The Second Circuit affirmed Dennis's conviction on Counts One and Four but reversed the conviction on Count Two. View "United States v. Dennis" on Justia Law

On October 24, 2016, Syracuse Police Department officers entered Troy Alexander's home without a warrant after receiving a report of a sexual assault. They searched the home for 12.5 hours before obtaining a warrant, during which they also towed Alexander's cars. After obtaining the warrant, they found narcotics in Alexander's bedroom. Alexander was arrested and faced multiple charges, including burglary, narcotics, and sexual assault. He posted bail twice but was not immediately released. Eventually, all charges were dropped.Alexander filed a lawsuit alleging violations of his constitutional rights and state law by the City of Syracuse, County of Onondaga, and Detective Rory Gilhooley. He claimed the warrantless entry and prolonged seizure of his home violated his Fourth Amendment rights, that he was falsely arrested, maliciously prosecuted, and improperly detained after posting bail. The United States District Court for the Northern District of New York granted summary judgment to the defendants on all claims.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that Alexander's claims regarding the warrantless entry, search, and seizure of his home, as well as his false arrest and malicious prosecution claims related to the burglary charges, presented triable issues of fact. The court also found gaps in the evidentiary record regarding Alexander's state law claims of continued detention after posting bail, precluding summary judgment for the City and County on these claims. The court vacated and remanded the judgment on these claims but affirmed the judgment in all other respects. View "Alexander v. City of Syracuse" on Justia Law

In 2020, the Vermont Superior Court transitioned to electronic filing and adopted a policy that delayed public access to newly filed civil complaints until a court clerk reviewed them for compliance with technical requirements and the absence of unredacted confidential information. Plaintiffs, consisting of news and media organizations, challenged this practice, claiming it violated their First Amendment right of access to court documents.The United States District Court for the District of Vermont held a bench trial and ruled in favor of the Plaintiffs. The court found that Vermont’s pre-access review process violated the First Amendment and issued a permanent injunction preventing the Defendants from withholding complaints until the completion of the review process. The Defendants, administrators and clerks of the Vermont Superior Court, appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that Vermont’s practice, as reviewed, violated the Plaintiffs’ First Amendment rights. However, the appellate court found that the terms of the permanent injunction were not supported by the court’s findings. The Second Circuit affirmed the district court’s judgment to the extent it found the practice violated the First Amendment but vacated the permanent injunction. The case was remanded for further proceedings to reconsider the terms of an appropriate injunction. The court also addressed and rejected the Defendants' arguments regarding abstention and mootness. View "Courthouse News Service v. Corsones" on Justia Law