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

Gilead Community Services, Inc. and Connecticut Fair Housing Center, Inc. sued the Town of Cromwell and several of its officials for discrimination and retaliation under the Fair Housing Act (FHA) and Americans with Disabilities Act (ADA). Gilead had purchased a house in Cromwell to be used as a group home for individuals with mental health disabilities. Following significant opposition from town residents and officials, including discriminatory statements and actions by the town's mayor and manager, Gilead was forced to close the group home. The town's actions included petitioning the Department of Public Health to deny a license for the home, issuing a cease-and-desist letter, and denying a tax exemption application.The United States District Court for the District of Connecticut found the Town of Cromwell liable for violating the FHA and ADA, awarding $181,000 in compensatory damages and $5 million in punitive damages. The town appealed, arguing that the district court erred in applying a motivating-factor causation test to FHA claims, in subjecting the municipality to vicarious liability and punitive damages under the FHA, and that the punitive damages were unconstitutionally excessive.The United States Court of Appeals for the Second Circuit reviewed the case. The court rejected Cromwell's arguments regarding the causation standard, vicarious liability, and the availability of punitive damages under the FHA. The court held that motivating-factor causation applies to FHA claims, municipalities can be held vicariously liable under the FHA, and the FHA allows for punitive damages against municipalities. However, the court found the $5 million punitive damages award to be unconstitutionally excessive, given the high ratio of punitive to compensatory damages and the disparity with civil penalties for similar conduct.The Second Circuit affirmed the district court's judgment in part, vacated the punitive damages award, and remanded the case for further proceedings, instructing the district court to grant a new trial on punitive damages unless Gilead agrees to a remittitur reducing the punitive damages to $2 million. View "Gilead Community Services, Inc. v. Town of Cromwell" on Justia Law

In this case, the plaintiff, Basel Soukaneh, alleged that during a routine traffic stop, Officer Nicholas Andrzejewski of the Waterbury, Connecticut police department unlawfully handcuffed and detained him in a police vehicle for over half an hour and conducted a warrantless search of his vehicle. Soukaneh had presented a valid firearms permit and disclosed the presence of a firearm in his vehicle. Andrzejewski argued that the presence of the firearm gave him probable cause to detain Soukaneh and search his vehicle.The United States District Court for the District of Connecticut partially granted and partially denied Andrzejewski’s motion for summary judgment. The court found that the initial stop was justified based on reasonable suspicion of a traffic violation. However, it denied summary judgment regarding the handcuffing and prolonged detention of Soukaneh, as well as the searches of the vehicle and trunk, concluding that Andrzejewski did not have the requisite probable cause and was not entitled to qualified immunity for these actions.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Andrzejewski violated Soukaneh’s Fourth Amendment rights by detaining him in a manner and for a length of time that constituted a de facto arrest without probable cause. The court also found that the warrantless searches of Soukaneh’s vehicle and trunk were not justified under the automobile exception or as a Terry frisk, as there was no reasonable suspicion or probable cause to believe that the vehicle contained contraband or evidence of a crime. Consequently, Andrzejewski was not entitled to qualified immunity for his actions. The case was remanded for further proceedings consistent with the appellate court’s opinion. View "Soukaneh v. Andrzejewski" on Justia Law

In 2021, Ellva Slaughter was charged with illegally possessing a firearm while knowing he had previously been convicted of a felony, violating 18 U.S.C. § 922(g)(1). Slaughter moved to dismiss the indictment, arguing that the jury selection plan of the Southern District of New York (SDNY) systematically underrepresented Black and Hispanic or Latino people, violating his Sixth Amendment right and the Jury Selection and Service Act of 1968 (JSSA). The district court assumed the underrepresentation was significant but denied the motion, finding Slaughter failed to prove systematic exclusion in the jury selection process.The United States District Court for the Southern District of New York denied Slaughter's motion to dismiss the indictment. The court assumed without deciding that there was significant underrepresentation of Black and Hispanic or Latino people but concluded that Slaughter did not establish that this underrepresentation was due to systematic exclusion. The court found that Slaughter's expert did not provide evidence that the identified practices caused the disparities and noted that many of the challenged practices were authorized by the Second Circuit. The court also found that any disparities were due to external factors outside the SDNY's control.The United States Court of Appeals for the Second Circuit reviewed the case. The court applied the framework from Duren v. Missouri, assuming without deciding that the underrepresentation was significant. However, it concluded that Slaughter did not meet his burden of proving systematic exclusion. The court found that Slaughter's expert did not provide sufficient evidence that the SDNY's practices caused the underrepresentation. The court affirmed the district court's judgment, holding that Slaughter failed to establish a prima facie violation of the fair cross-section requirement under the Sixth Amendment and the JSSA. View "United States v. Slaughter" on Justia Law

Laurie Weinlein was convicted of bank fraud and embezzlement from an employee benefit plan, resulting in a sentence of sixty-three months in prison, five years of supervised release, and over $2 million in restitution payments. The crimes were committed in 1994 and 1995. At that time, the Victim and Witness Protection Act (VWPA) stipulated that restitution obligations terminated twenty years from the date of judgment. In 1996, the Mandatory Victims Restitution Act (MVRA) extended the enforcement period for restitution orders. In 2021, Weinlein moved to terminate her restitution obligation, arguing that the VWPA’s enforcement period had expired and that applying the MVRA retroactively violated the Ex Post Facto Clause of the Constitution.The United States District Court for the Northern District of New York denied Weinlein’s motion to terminate her restitution obligation. The court held that retroactive application of the MVRA’s enforcement period did not violate the Ex Post Facto Clause. Weinlein then appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The court held that retroactively applying the MVRA’s longer enforcement period did not violate the Ex Post Facto Clause. The court reasoned that the MVRA did not increase the punishment for Weinlein’s crime but merely extended the time period over which the government could collect the restitution. The court concluded that the punishment imposed by the restitution order remained the same, and the extension of the enforcement period did not constitute a greater punishment than what was originally imposed. View "United States v. Weinlein" on Justia Law

Emilee Carpenter, a wedding photographer, filed a preenforcement challenge against New York’s public accommodations laws, which prohibit discrimination based on sexual orientation. Carpenter argued that these laws violated her First and Fourteenth Amendment rights by compelling her to provide photography services for same-sex weddings, which she claimed conflicted with her religious beliefs. She sought declaratory and injunctive relief, including a preliminary injunction to prevent enforcement of the laws against her.The United States District Court for the Western District of New York dismissed all of Carpenter’s claims. The court found that Carpenter had not sufficiently pled that the public accommodations laws violated her rights to free speech, free association, free exercise of religion, or the Establishment Clause. The court also rejected her claims that the laws were unconstitutionally overbroad or vague. Consequently, the court denied her request for a preliminary injunction as moot.The United States Court of Appeals for the Second Circuit reviewed the case. Following the Supreme Court’s decision in 303 Creative LLC v. Elenis, the appellate court agreed that Carpenter had plausibly stated a free speech claim. However, the court denied her request for a preliminary injunction at this stage, remanding the case to the district court for further proceedings to develop a factual record. The appellate court affirmed the district court’s dismissal of Carpenter’s other claims, including those related to free association, free exercise of religion, the Establishment Clause, and vagueness. The court concluded that the public accommodations laws were neutral, generally applicable, and did not provide for individualized exemptions that would undermine their general applicability. The court also found that Carpenter had waived her overbreadth claim due to inadequate pleading and briefing.The Second Circuit thus affirmed in part, reversed in part, vacated in part, and remanded the case for further proceedings. View "Carpenter v. James" on Justia Law

The case involves the Upstate Jobs Party (UJP) and two of its leaders who sued the Commissioners of the New York State Board of Elections over campaign finance regulations. UJP, an independent body, argued that it is similarly situated to political parties because both nominate candidates that compete in the same elections. UJP claimed that New York's preferential treatment of parties violates the Fourteenth Amendment right to equal protection. UJP also asserted First Amendment violations, alleging that New York's campaign finance rules distinguishing between parties and independent bodies are not closely drawn to a sufficient state interest in preventing corruption or the appearance thereof.The United States District Court for the Northern District of New York determined that differences in contribution limits applicable to parties and independent bodies violate the Fourteenth and the First Amendments. However, it also determined that allowing parties but not independent bodies to maintain so-called “housekeeping accounts” did not violate either amendment. Both UJP and the State Board appealed.The United States Court of Appeals for the Second Circuit reversed in part and affirmed in part the district court’s judgment. The court held that parties and independent bodies are not similarly situated, and that the state’s contribution limits and housekeeping account exception are closely drawn to serve the state’s anticorruption interests. Therefore, the court concluded that the state’s campaign finance laws withstand all constitutional challenges raised. View "Upstate Jobs Party v. Kosinksi" on Justia Law

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

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

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

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