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

Articles Posted in Constitutional Law
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This case involves two legal permanent residents, Carol Williams Black and Keisy G.M., who were detained by the U.S. government for several months without a bond hearing under the authority of 8 U.S.C. § 1226(c), pending the conclusion of their separate removal proceedings. Black and G.M. each sought habeas relief, asserting that their prolonged detentions without any bond hearing violated their Fifth Amendment rights to due process. The district court granted Black's petition and he was released, while G.M.'s petition was denied.In the United States Court of Appeals for the Second Circuit, the court concluded that the constitutional guarantee of due process precludes a noncitizen’s unreasonably prolonged detention under section 1226(c) without a bond hearing. The court affirmed the district court’s judgment granting habeas relief to Black, concluding that the district court properly required the government to show the necessity of his continued detention by clear and convincing evidence. As to G.M., the court concluded that his detention had become unreasonably prolonged and reversed the district court’s judgment denying habeas relief. View "Black v. Decker" on Justia Law

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Sanjay Tripathy, a former inmate in the New York correctional system, filed a lawsuit against state prison officials. He claimed that they forced him to enroll in a sex-offender program that required him to accept responsibility for his crimes, which he argued violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the First Amendment. He also claimed that he was assigned to a more intensive tier of the program in violation of his due process rights, and that he was retaliated against after he challenged the program by filing grievances and this lawsuit.The United States District Court for the Western District of New York dismissed Tripathy's claims. The court ruled that his claim for damages under RLUIPA was barred by precedent that the statute does not permit individual-capacity damages. The court also found that his demands for injunctive and declaratory relief became moot when his state convictions were vacated and he was released from prison. Regarding his constitutional claims, the court concluded that Tripathy’s free exercise claim under the First Amendment was barred by qualified immunity, that he lacked standing to seek damages for his due process claim under the Fourteenth Amendment, and that he failed to state a claim for retaliation in violation of the First Amendment.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court agreed that Tripathy's claim for damages under RLUIPA was barred by precedent, that his demands for injunctive and declaratory relief were moot due to his release from prison, and that his constitutional claims were properly dismissed by the district court. View "Tripathy v. McKoy" on Justia Law

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Chamma K. Brandon, an inmate in the custody of the New York State Department of Corrections and Community Supervision, filed a lawsuit against three prison officials. Brandon alleged that the officials violated his First Amendment right to the free exercise of religion by denying him a special meal in celebration of Eid al-Adha. He also claimed that one of the officials, Mark Royce, violated his Eighth Amendment right to be free from cruel and unusual punishment by ordering that his housing block be constantly illuminated.The United States District Court for the Southern District of New York granted the defendants' motion for summary judgment on Brandon's First Amendment claim and denied Brandon's request to reopen discovery for a second time to permit expert testimony on his Eighth Amendment claim. Following a trial, a jury found that Royce had not violated Brandon's Eighth Amendment right.On appeal, the United States Court of Appeals for the Second Circuit agreed with Brandon that the district court erred in granting summary judgment to the defendants on his First Amendment claim. The court found that there was a genuine dispute of material fact regarding whether Brandon had an alternative means of exercising his right to the free exercise of religion. The court also found that the penological concerns raised by the defendants did not support granting judgment as a matter of law in their favor. However, the court found no error in the district court's denial of Brandon's motion to reopen discovery. The court therefore vacated in part and affirmed in part the district court's decision. View "Brandon v. Royce" on Justia Law

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A U.S. citizen, Maalik Alim Jones, pleaded guilty to terrorism-related charges for his involvement with al-Shabaab, an Islamist military organization in Kenya and Somalia. The district court accepted his plea and sentenced him to 25 years of imprisonment. Jones challenged his plea agreement and sentence, arguing that a prior mandate of the court precluded the government from charging him in a superseding indictment, that the language of his plea agreement was ambiguous and inapplicable to him, and that his sentence was based on erroneous factual findings and constitutionally impermissible factors.Jones was initially indicted on five counts related to his support and training with al-Shabaab. He later consented to a superseding information, which reduced the charges to three counts. Jones pleaded guilty to these charges and was sentenced to 35 years of imprisonment. However, following a Supreme Court ruling that found a section of the law under which Jones was charged to be unconstitutionally vague, Jones appealed his conviction on one of the counts. The court vacated this conviction and remanded for resentencing on the remaining counts. On remand, the district court denied the government's motion to reinstate the initial indictment but did not preclude the government from seeking a superseding indictment. The government subsequently filed a superseding indictment, which Jones moved to dismiss.The United States Court of Appeals for the Second Circuit rejected Jones's arguments and affirmed the judgment of the district court. The court found that the mandate did not preclude a superseding indictment, and that the plea agreement unambiguously allowed for new charges if a conviction was vacated. The court also found that Jones's sentence was not based on erroneous factual findings or constitutionally impermissible factors, and that his challenges were barred by the appeal waiver in the plea agreement. View "United States v. Jones" on Justia Law

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A group of citizens and a civic organization, Citizens United To Protect Our Neighborhoods (CUPON), filed a lawsuit against the Village of Chestnut Ridge, New York, alleging that the village violated the Establishment Clause of the First Amendment by enacting a new zoning law related to places of worship in 2019. The plaintiffs claimed that the new law favored religious uses over secular uses, thus violating the constitutional separation of church and state.The case was initially heard in the United States District Court for the Southern District of New York, where it was dismissed. The district court found that none of the plaintiffs had constitutional standing to pursue the claim. The court determined that the individual plaintiffs lacked municipal-taxpayer, direct-harm, or denial-of-benefits standing, and that CUPON lacked associational or organizational standing.The case was then appealed to the United States Court of Appeals for the Second Circuit. The appellate court agreed with the lower court's decision, affirming that neither the individual plaintiffs nor CUPON had any form of standing. The court found that the plaintiffs failed to demonstrate a measurable appropriation or loss of revenue attributable to the challenged activities, a personal constraint or control under the challenged law, or a denial of benefits. The court also found that CUPON failed to show that it had suffered an injury in fact that was distinct and palpable. Therefore, the court affirmed the district court's judgment, dismissing the plaintiffs' complaint for lack of standing. View "Citizens United To Protect Our Neighborhoods v. Village of Chestnut Ridge" on Justia Law

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Six full-time professors at the City University of New York filed a lawsuit challenging New York’s Public Employees’ Fair Employment Act, known as the Taylor Law, alleging it violated their First Amendment rights to free speech and association. The professors argued that the law unfairly compelled them to be part of a bargaining unit represented exclusively by the Professional Staff Congress/CUNY (PSC), despite their vehement disagreement with PSC's political views, specifically on issues related to Israel and Palestine. They also challenged a specific section of the Taylor Law which allows PSC to decline representation of non-union employees in certain proceedings.The defendants filed motions to dismiss the claims, which were granted by the United States District Court for the Southern District of New York. The professors appealed, but the United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The appellate court agreed with the district court that the professors' claims were foreclosed by the Supreme Court’s decision in Minnesota State Board for Community Colleges v. Knight, and that the professors failed to allege that the contested section of the Taylor Law violates the First Amendment. Thus, the court concluded that the PSC's exclusive representation of the professors in collective bargaining did not violate the First Amendment, and that the limited fiduciary duty imposed by the contested section of the Taylor Law did not burden their First Amendment rights. View "Goldstein v. Professional Staff Congress/CUNY" on Justia Law

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The defendant-appellant, Alex Oliveras, was sentenced to sixty-three months' imprisonment and a three-year supervised release term for possessing cocaine with intent to distribute and possessing a firearm in furtherance of drug trafficking. On appeal, Oliveras challenged the imposition of a special condition of his supervised release that allowed for suspicionless searches by a probation officer.The United States Court of Appeals for the Second Circuit held that the "special needs" doctrine of the Fourth Amendment permits, when sufficiently supported by the record, the imposition of a special condition of supervised release that allows suspicionless searches of the defendant's person, property, vehicle, place of residence, or any other property under their control by a probation officer. However, the court also found that the district court exceeded its discretion in imposing that special condition here. The court explained that the district court failed to make the individualized assessment required to support the special condition under 18 U.S.C. § 3583(d), including a sufficient explanation as to how the condition was reasonably related in this particular case to the applicable statutory factors under 18 U.S.C. § 3553(a) and involved no greater deprivation of liberty than was reasonably necessary under those factors. Therefore, the Court of Appeals vacated the Search Condition and remanded the case to the district court for further consideration of whether it is necessary to impose the Search Condition in this particular case and, if so, for the district court to explain the individualized basis for imposing the Search Condition. View "United States v. Oliveras" on Justia Law

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The United States Court of Appeals for the Second Circuit affirmed the decision of the United States District Court for the Eastern District of New York, which dismissed the plaintiffs' complaint. The plaintiffs, Ben and Hank Brinkmann and their company Mattituck 12500 LLC, had alleged that the Town of Southold, New York's use of eminent domain to take their land for public park purposes was a pretextual and bad faith exercise of the Takings Clause of the Fifth Amendment. The plaintiffs argued that the real motive was to prevent them from constructing a hardware store on the property.The Court of Appeals ruled that if a property is taken for a public purpose, in this case, the creation of a park, courts do not inquire into alleged pretexts and motives. The court found that a public park serves a public purpose, and thus, the taking of the property was permissible under the Takings Clause of the Fifth Amendment. It concluded that the plaintiffs' allegations of pretext and bad faith did not violate the Takings Clause as the intended use of the property was for a public park. The court stated that a pretextual taking would only violate the Takings Clause if the actual purpose of the taking was for a non-public (i.e., private) use, which was not the case here. View "Brinkmann v. Town of Southold, New York" on Justia Law

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In this case, the United States Court of Appeals for the Second Circuit affirmed a decision from the United States District Court for the District of Vermont. The defendant, Cory Johnson, had been convicted for the production of child pornography and challenged his conviction on the basis of a motion to suppress evidence and a motion to dismiss the indictment.The evidence in question was a video depicting the sexual abuse of a toddler, which had been found following a review of digital data seized from Johnson's devices. This review had taken place after his sentencing for an earlier prosecution. Johnson argued that this review violated his Fourth Amendment rights, as it had taken place after the sentencing and had looked for evidence of a new crime. The court disagreed, ruling that the review was within the scope of the original search warrant and did not violate the Fourth Amendment.Johnson also argued that his second prosecution was barred by his earlier plea agreement. He contended that the plea agreement prohibited future prosecution for offenses "known to the United States as of the date it signed the agreement." The court, however, found that the government had not been aware of Johnson’s sexual abuse of his daughter and his production of child pornography at the time of the agreement. Thus, the plea agreement did not preclude his subsequent prosecution for these crimes.In conclusion, the court affirmed Johnson's conviction. View "United States v. Johnson" on Justia Law

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The United States Court of Appeals for the Second Circuit addressed a dispute involving the Triborough Bridge and Tunnel Authority (TBTA) and several plaintiffs who had been fined for failing to pay tolls at TBTA crossings. The plaintiffs claimed that the fines were unconstitutional under the Eight Amendment’s Excessive Fines Clause and that TBTA was unjustly enriched under New York law. The court considered the case on appeal from the United States District Court for the Southern District of New York, which had granted summary judgment in favor of TBTA. The Court of Appeals affirmed the lower court's decision.The plaintiffs had failed to pay their tolls for various reasons, such as receiving bills at old addresses or having malfunctioning transponders. They then received substantial fines, which they eventually paid at reduced amounts. The main issue was whether these fines were excessive in relation to the seriousness of the offenses. The court applied the four-factor test from United States v. Bajakajian, which considers the nature of the offense, whether the defendant fits into the class of persons the law was designed for, the maximum potential sentence and fine, and the harm caused by the defendant's conduct.The court found that the fines were not excessive. It pointed out that the plaintiffs' violations were not willful or fraudulent, and that the fines were in line with those for similar offenses in other states. The court also noted that the fines helped TBTA prevent the harms it would suffer if people did not pay their tolls.Regarding the unjust enrichment claim, the court concluded that the plaintiffs had not shown that it was inequitable for TBTA to retain the fines. The plaintiffs' non-payment of tolls had violated TBTA regulations, and it was not inequitable for such violations to result in fines. Therefore, the court affirmed the lower court's grant of summary judgment in favor of TBTA on the unjust enrichment claims as well. View "Reese v. Triborough Bridge and Tunnel Authority" on Justia Law