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

Articles Posted in Constitutional Law
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D.S., a child with a disability who receives special education services under the Individuals with Disabilities Education Act (IDEA), appealed the district court's denial of his motion for summary judgment and grant of the Board's motion for summary judgment. After the child's parents disagreed with the functional behavioral assessment (FBA) that his school conducted, they sought an independent educational evaluation (IEE) at public expense.The Second Circuit held that an FBA is not an evaluation as that term is employed in the relevant IDEA provisions and that a parent's dissatisfaction with an FBA does not entitle them to a publicly funded IEE. In regard to the parents' disagreement with the child's 2014 reevaluation, the court held that parents need not file a due process complaint under the IDEA to disagree with an evaluation and that the statute of limitations does not apply here. Rather, the court held that the IDEA's cyclical evaluation process establishes the operative time frame in which a parent may disagree with an evaluation and obtain an IEE at public expense. Accordingly, the court vacated the judgment, reversed the district court's decision, and remanded for further proceedings. View "D.S. v. Trumbull Board of Education" on Justia Law

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After Plaintiffs Moya and Ruiz applied to become naturalized citizens of the United States and the government denied their requests for disability exemptions from the civics and English testing requirements, they filed suit in federal court claiming that the naturalization process is unlawful.The Second Circuit affirmed the district court's dismissal of plaintiffs' claims, holding that the Immigration and Nationality Act (INA) does not allow Moya and Ruiz to seek judicial review of their denial of their applications until after completion of the available administrative review procedures, and thus Moya and Ruiz did not exhaust their administrative remedies. The court also held that the district court correctly found that the other plaintiff in this appeal, YMPJ, had Article III standing to sue, but did not fall within the zone of interests of the INA, the Administrative Procedure Act, or the Due Process Clause. Therefore, YMPJ, a non-profit organization that assists applicants for naturalization, could not bring a cause of action on its own behalf. View "Moya v. United States Department of Homeland Security" on Justia Law

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Plaintiff appealed the district court's order adopting the Magistrate Judge's sua sponte order administratively closing plaintiff's civil rights suit against defendants and denying his motion to reconsider. The district court concluded that, because plaintiff had been deported to the Dominican Republic, plaintiff would be unavailable in the United States for depositions, further medical examinations, and trial testimony, and the case should be closed.The Second Circuit held that an administrative closure in such circumstances is a last resort that is appropriate only when all other alternatives are virtually impossible or so impractical as to significantly interfere with the operations of the district court or impose an unreasonable burden on the party opposing the plaintiff's claim. In this case, the court held that numerous alternatives to the issues identified by the district court exist, and none seems virtually impossible or so impractical as to significantly interfere with the operations of the district court or impose an unreasonable burden on the party opposing plaintiff's claim. Accordingly, the court vacated the district court's order and remanded for further proceedings. View "Rodriguez v. Gusman" on Justia Law

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The Second Circuit affirmed the district court's grant of defendants' motion for summary judgment on plaintiff's claims under the Free Exercise Clause of the First Amendment and the Religious Land Use and Institutionalized Persons Act (RLUIPA). Plaintiff alleged that prison officials violated his rights by interfering with his observance of Ramadan during a five-day prison lockdown and by transferring him to a special housing unit where he was unable to participate in group prayer.The court held that plaintiff's Free Exercise claims fail because defendants are entitled to qualified immunity where there was no clearly established law requiring the accommodation of inmates' religious practices during a prison lockdown. Furthermore, federal law does not provide any clearly established right of an inmate confined to the SHU to attend group prayer, and New York law actually prohibits it. The court also held that plaintiff's RLUIPA claims are moot because he was transferred from the Auburn Correctional Facility. Finally, the district court properly admitted certain hearsay and character evidence during the trial on his retaliation claim. View "Booker v. Graham" on Justia Law

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After plaintiff was acquitted for disorderly conduct, resisting arrest, and harassment, he filed suit under 42 U.S.C. 1983, alleging claims of excessive force, false arrest, and malicious prosecution. Two officers moved for summary judgment based on qualified immunity, but the district court denied the motion.The Second Circuit dismissed the officers' appeal based on lack of appellate jurisdiction, holding that the district court did not err as a matter of law when it concluded that there is a genuine dispute of material fact as to whether one of the officers gave verbal commands to disperse prior to his arresting plaintiff and thus had probable cause for the arrest. The court also held that it is properly up to the jury, not a court of appeals, to determine whether to believe testimony supporting plaintiff's claim that there was no such command from the officer. View "Franco v. City of Syracuse" on Justia Law

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After a jury returned a verdict in favor of plaintiff on her claim of intentional discrimination on the basis of race or national origin by her former employer, Rockefeller University, both plaintiff and the University appealed the final judgment of $250,000 in back pay and $200,000 in remitted emotional distress damages.The Second Circuit affirmed and rejected both parties' claims of error. The court held that, at bottom, any evidence in the trial record that could even arguably justify punitive damages is sparse, and the failure to instruct the jury on such damages accordingly did not cut to the core of plaintiff's case; plaintiff cannot demonstrate that the failure to instruct the jury on punitive damages constituted an error so serious and flagrant that it goes to the very integrity of the trial; the requirement of intentional discrimination was clearly expressed in the jury instructions and thus the court rejected the University's contention to the contrary; there was no prejudicial error in the formulation of the verdict form necessitating a new trial; the district court had the power to rescind its discharge order and, in the circumstances of this case, its decision to do so was a proper exercise of discretion; and the court rejected the University's challenge to the second verdict form. View "Emamian v. Rockefeller University" on Justia Law

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Plaintiffs filed suit challenging the quarantine decisions of certain Connecticut state officials in response to an Ebola epidemic in West Africa. On appeal, plaintiffs challenged the district court's denial of their motion for class certification and dismissing their suit for lack of standing and based on qualified immunity. Plaintiffs primarily argue that they suffered actual or imminent injuries that create standing to seek prospective relief to avert allegedly unconstitutional future quarantines; clearly established law required that any quarantine imposed be medically necessary and comport with certain procedural safeguards; and their class is sufficiently numerous to merit certification.The Second Circuit affirmed and held that the district court properly deemed plaintiffs' injuries too speculative to support standing. In this case, plaintiffs failed to plead a sufficient likelihood that, under the revised policy, any of them faces a substantial risk of suffering a future injury. The court also held that the law surrounding quarantines was not clearly established such that a state official may be held liable for the actions taken here. The court did not reach the class certification issue because it is mooted by the court's conclusion as to standing. Accordingly, the court remanded with instructions to amend the judgment to clarify that the state law claims were dismissed without prejudice. View "Liberian Community Ass'n v. Lamont" on Justia Law

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Plaintiffs appealed the district court's dismissal, under Federal Rule of Civil Procedure 12(b)(1) and 12(b)(6), of plaintiffs' amended complaint brought under 42 U.S.C. 1983 against various state officials, alleging that New York State's firearm licensing laws, N.Y. Penal Law 400.00, violate plaintiffs' rights under the Second and Fourteenth Amendments to the Constitution. The district court dismissed on grounds of mootness or lack of standing the claims of all but two plaintiffs, against all but two defendants, for failure to plead injury-in-fact or traceability of injury to other defendants; dismissed claims for money damages against the two remaining defendants on grounds of judicial and Eleventh Amendment immunity; dismissed individual-capacity claims against those defendants for injunctive relief as barred by 42 U.S.C. 1983; and dismissed the surviving claims on the grounds that the section 400.00 licensing criteria of "good moral character," "good cause," and "proper cause" are not unconstitutionally vague, and that the statutory scheme, while impacting Second Amendment rights, does not burden those rights substantially, closely relates to the State's interests in public safety, and thus survives intermediate scrutiny.The Second Circuit has been informed by the parties of events that have rendered the claims of certain plaintiffs moot and the court otherwise affirmed the rulings of the district court principally for the reasons stated by the district court. The court dismissed as to the Libertarian Party, which expressly disclaimed any request for appellate relief; dismissed as moot insofar as it pursues relief on behalf of plaintiff Rober, who is deceased with no successor or representative having been substituted for her; dismissed insofar as it pursues relief on behalf of plaintiff Kuzma, whose acquisition of a firearm license has made moot any claim that was pursued for him; and dismissed insofar as it pursues injunctive relief on behalf of plaintiff Cuthbert, whose relocation to Colorado has made him ineligible to apply for a New York concealed-carry permit. The court considered all of the other arguments properly before it and found them to be without merit. View "Libertarian Party of Erie County v. Cuomo" on Justia Law

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Under 28 U.S.C. 2253, in a habeas corpus proceeding or a proceeding under section 2255 before a district judge, the final order shall be subject to review, on appeal, by the court of appeals for the circuit in which the proceeding is held.The Second Circuit determined, sua sponte, that it lacks jurisdiction to hear petitioner's appeal because a district court's order denying a certificate of appealability is not an appealable final order. In this case, petitioner moves for a certificate of appealability and for leave to file an oversized motion for a certificate of appealability, challenging the district court's order denying a certificate of appealability. The court dismissed the appeal for lack of jurisdiction and denied petitioner's motion as moot. View "Lasher v. United States" on Justia Law

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Plaintiffs, a group of state and local governments and a group of non-profit organizations, filed separate suits under the Administrative Procedure Act, both challenging the validity of a DHS rule interpreting 8 U.S.C. 1182(a)(4), which renders inadmissible to the United States any non-citizen deemed likely to become a public charge. The district court entered orders in both cases to enjoin implementation of the rule nationwide.After determining that the States and the Organizations have Article III standing to challenge the rule and that they fall within the zone of interests of the public charge statute, the Second Circuit affirmed the district court's grant of a preliminary injunction enjoining the implementation of the rule. The court held that plaintiffs have demonstrated a likelihood of success on the merits of their claim that the rule is contrary to the Immigration and Nationality Act (INA). The court explained that, in reenacting the public charge ground in 1996, Congress endorsed the settled administrative and judicial interpretation of that ground as requiring a holistic examination of a non-citizen's self-sufficiency focused on ability to work and eschewing any idea that simply receiving welfare benefits made one a public charge. Furthermore, the rule makes receipt of a broad range of public benefits on even a short-term basis the very definition of "public charge." Therefore, that exceedingly broad definition is not in accordance with law.The court also held that plaintiffs have demonstrated a likelihood of success on the merits of their claim that the rule is arbitrary and capricious. In this case, DHS has not provided a reasoned explanation for its changed definition of "public charge" or the rule's expanded list of relevant benefits. The court further held that plaintiffs have established irreparable harm, and that the balance of the equities and the public interest tips in favor of granting the injunction. However, the court modified the scope of the injunctions to cover only the states of New York, Connecticut, and Vermont. View "New York v. United States Department of Homeland Security" on Justia Law