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

Plaintiff filed suit against MTA, alleging claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12112-12117. On appeal, plaintiff challenged the district court's grant of summary judgment to MTA and its dismissal of plaintiff's claims. The district court, based on Collins v. New York City Transit Authority, gave almost preclusive weight to the NYSDHR's dismissal of this claim. The court vacated and remanded the dismissal of the disability discrimination claim because Collins addresses only the effect of arbitration awards under a collective bargaining agreement and does not apply to the decisions of state administrative agencies. The NYSDHR’s findings are admissible evidence, and the court held only that consideration of them on a motion for summary judgment, or, if appropriate, at a trial, is not governed by Collins. The court affirmed the dismissal of the retaliation claim. View "Cortes v. MTA New York City Transit" on Justia Law

Plaintiff appealed from the district court's dismissal of his claims stemming from his confinement in the Special Housing Unit of the Metropolitan Correctional Center in Manhattan, and then the Special Housing Unit of the Metropolitan Detention Center in Brooklyn, for an extended period of time, allegedly without procedural protections, and in retaliation for protected speech. The district court concluded that plaintiff failed to file his complaint within the three‐year statute of limitations applicable to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics claims. In this case, plaintiff's claim as he has pled it, assuming it otherwise is viable, accrued only after the defendants had confined him in the SHU for some threshold period of time. Therefore, the court concluded that the continuing violation doctrine does apply to plaintiffʹs Eighth Amendment claim, but that it does not apply to his First or Fifth Amendment claims. Further, certain aspects of his Fifth Amendment claim may be timely. Accordingly, the court affirmed in part. vacated in part, and remanded in part for further proceedings. View "Gonzalez v. Hasty" on Justia Law

Plaintiff, a high school math teacher, filed suit against the District, alleging claims of discrimination and retaliation under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1983 against two principals. Plaintiff alleged that defendants discriminated against him because of his Hispanic ethnicity and that they retaliated against him after he complained of discrimination. The district court granted defendants' motion for judgment on the pleadings. The court held, however, that certain of plaintiff's claims were not time-barred, as the district court had concluded; retaliation claims are actionable under section 1983; a Title VII plaintiff need not plead a prima facie case of discrimination to survive a motion to dismiss; and, in this case, plaintiff has sufficiently pleaded discrimination and retaliation claims. Accordingly, the court vacated and remanded for further proceedings. View "Vega v. Hempstead Union Free Sch. Dist." on Justia Law

Plaintiff filed suit pro se under 42 U.S.C. 1983, against several corrections officers and supervisors at a New York corrections facility, alleging that, while he was incarcerated, he endured a cruel campaign of harassment at the hands of corrections officers in retaliation for his refusal to provide false information against another inmate. The district court subsequently granted defendants' motion for summary judgment. The court concluded that the grant of summary judgment conflicts with Rule 56(f) of the Federal Rules of Civil Procedure because it reached, sua sponte without notice, claims not briefed in defendants’ motion. The court reiterated the proper standard for granting summary judgment on grounds not raised by the movant, which was not met here; the court clarified the standard for a claim for unconstitutional retaliation; the court disagreed with the district court’s analysis of plaintiff’s claim for unsanitary conditions; the court revived plaintiff's claims for nutritionally inadequate meals, theft of legal documents, harassment, malicious prosecution, and false imprisonment; and the court suggested to the district court that on remand plaintiff receive appointed counsel, an opportunity to take further discovery, and leave to file a second amended complaint. Accordingly, the court vacated the judgment and remanded for further proceedings. View "Willey v. Kirkpatrick" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against New York City and NYPD officers, alleging claims for false arrest and use of excessive force in violation of the Fourth Amendment, and retaliation in violation of the First Amendment. The officers arrested plaintiff after a scuffle that occurred while plaintiff was searching for a bathroom. Earlier that evening, plaintiff had gone to Zuccotti Park to observe the Occupy Wall Street crowd. The court concluded that plaintiff's claim against the officers for unlawful arrest is defeated by their defense of qualified immunity, her First Amendment claim was properly dismissed as lacking any merit, and her claim against them for use of excessive force must be remanded for trial. The court did not need to consider plaintiff's claims against the City because her brief on appeal does not challenge the dismissal of those claims. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Brown v. City of New York" on Justia Law

Plaintiffs, current and former inmates of the Eastern Correctional Facility, filed suit alleging that a corrections officer sexually abused them and thus subjected them to cruel and unusual punishment. The district court dismissed the case. The court agreed with the district court that the complaint failed to state a claim under Boddie v. Schnieder. Boddie set forth the standard for stating an Eighth Amendment claim arising from sexual abuse in prison. The court clarified that a corrections officer’s intentional contact with an inmate’s genitalia or other intimate area, which serves no penological purpose and is undertaken with the intent to gratify the officer’s sexual desire or to humiliate the inmate, violates the Eighth Amendment. Further, the court recognized that sexual abuse of prisoners deeply offends today's standards of decency and the proper application of the rule in Boddie must reflect such standards. In this case, plaintiffs stated a cognizable Eighth Amendment claim by alleging that the officer fondled their genitals for personal gratification and without penological justification. Accordingly, the court reversed and remanded. View "Crawford v. Cuomo" on Justia Law

Plaintiff filed suit against the City, individual detectives and officers, and the City's Chief of Police, under 42 U.S.C. 1983, after plaintiff's rib was broken and his spine was broken in two places. The court concluded that the district court's summary judgment dismissal of the section 1983 claim against Detective Watson for use of excessive force was error because no officer in 2009 could reasonably have believed it permissible under the Fourth Amendment to jump on the back of a prone and compliant suspect gratuitously, with sufficient force to break his spine and rib. Accordingly, the court vacated to the extent that it dismissed plaintiff's section 1983 claim against Watson for the use of excessive force and his state-law claims related to the use of excessive force. The court affirmed in all other respects. The matter is remanded for further proceedings. View "Rogoz v. City of Hartford" on Justia Law

Plaintiff filed suit against the City, individual detectives and officers, and the City's Chief of Police, under 42 U.S.C. 1983, after plaintiff's rib was broken and his spine was broken in two places. The court concluded that the district court's summary judgment dismissal of the section 1983 claim against Detective Watson for use of excessive force was error because no officer in 2009 could reasonably have believed it permissible under the Fourth Amendment to jump on the back of a prone and compliant suspect gratuitously, with sufficient force to break his spine and rib. Accordingly, the court vacated to the extent that it dismissed plaintiff's section 1983 claim against Watson for the use of excessive force and his state-law claims related to the use of excessive force. The court affirmed in all other respects. The matter is remanded for further proceedings. View "Rogoz v. City of Hartford" on Justia Law

Plaintiffs, a group of religious non-profit organizations affiliated with the Roman Catholic Archdiocese, filed suit challenging regulations promulgated under the Patient Protection and Affordable Care Act of 2010, Pub. L. No. 111-148, 124 Stat. 119. The district court concluded that regulations promulgated under the Act that allow religious non-profit employers to opt out of providing contraceptive coverage themselves violate these religious employers’ rights under the Religious Freedom Restoration Act, 42 U.S.C. 2000bb et seq. The court concluded, however, that the challenged accommodation for religious objectors relieves, rather than imposes, any substantial burden on plaintiffs’ religious exercise, and thus does not violate the Religious Freedom Restoration Act. Accordingly, the court reversed the district court's judgment. View "Catholic Health Care Sys. v. Burwell" on Justia Law

Plaintiffs, a group of religious non-profit organizations affiliated with the Roman Catholic Archdiocese, filed suit challenging regulations promulgated under the Patient Protection and Affordable Care Act of 2010, Pub. L. No. 111-148, 124 Stat. 119. The district court concluded that regulations promulgated under the Act that allow religious non-profit employers to opt out of providing contraceptive coverage themselves violate these religious employers’ rights under the Religious Freedom Restoration Act, 42 U.S.C. 2000bb et seq. The court concluded, however, that the challenged accommodation for religious objectors relieves, rather than imposes, any substantial burden on plaintiffs’ religious exercise, and thus does not violate the Religious Freedom Restoration Act. Accordingly, the court reversed the district court's judgment. View "Catholic Health Care Sys. v. Burwell" on Justia Law