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

Plaintiff, an inmate and practicing Muslim, filed suit against prison officials alleging that they unconstitutionally burdened his religious exercise when they ordered him to provide a urine sample within a three-hour window while he fasted in observance of Ramadan. On appeal, plaintiff challenged the district court's entry of judgment in favor of the officials. The court concluded that the choice either to provide a urine sample by drinking water during plaintiff's fast or to face disciplinary action placed a substantial burden on his religious exercise. Therefore, the court vacated the district court's judgment insofar as it concerns defendant's claim for damages under the First Amendment's Free Exercise Clause and remanded for further consideration of the claim. The court affirmed the judgment in favor of the officials on plaintiff's Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., claim, his Fourteenth Amendment claim, his First Amendment retaliation claim, and his free exercise claim for an injunction.View "Holland v. Goord" on Justia Law

Plaintiffs, provider of short-term loans over the internet, sought a preliminary order enjoining DFS from interfering with the tribes' consumer lending business. New York's usury laws prohibit unlicensed lenders from lending money at an interest rate above 16 percent per year, and criminalized loans with interest rates higher than 25 percent per year. DFS received complaints from New York residents for loans from plaintiffs with interest rates as high as 912.49 percent. Plaintiffs argued that New York projected its regulations over the internet and onto reservations in violation of Native Americans' tribal sovereignty protected by the Indian Commerce Clause of the Constitution. The court affirmed the district court's denial of plaintiffs' motion for a preliminary injunction because the district court reasonably concluded that plaintiffs failed to establish that the challenged loan transactions occurred on Native American soil, a fact necessary to weaken New York State's regulatory authority over them. View "Otoe-Missouria Tribe v. New York State Dept. of Fin. Servs." on Justia Law

Safelite appealed from the denial of a preliminary injunction against enforcement of Connecticut's Public Act 13-67, "An Act Concerning Automotive Glass Work." The court held that the district court erred in applying rational basis review under Zauderer v. Office of Disciplinary Counsel of the Supreme Court of Ohio, but rather should have applied intermediate scrutiny under Central Hudson Gas & Electric Corp. v. Public Service Commission of New York. Under Central Hudson, the court concluded that there is no claim, much less evidence, that Safelite's communications to its customers were false, misleading, or illegal; the court was skeptical that the government's asserted consumer protection interests are genuine and not merely post-hoc rationalizations; even if the government had a substantial interest in consumer choice, PA 13-67 advances that interest, if at all, in an indiscernible or de minimus fashion; PA 13-67 is more restrictive than necessary to effectuate the government's legitimate interests; and PA 13-67 is underinclusive because it only applies to third-party insurance claims administrators who also own an affiliated glass shop. Accordingly, the court vacated the district court's judgment and remanded with instructions to enter a preliminary injunction and for further proceedings. View "Safelite Group, Inc. v. Jepsen" on Justia Law

CCR seeks disclosure of certain videos and photographs of a high-profile Guantanamo Bay detainee, Mohammed al-Qahtani (the so called "20th hijacker" in the September 11, 2001 attacks), under the Freedom of Information Act (FOIA), 5 U.S.C. 552. The court held that the government has met its burden of establishing that these images are exempt from disclosure under FOIA Exemption 1, which authorizes non-disclosure of records that are properly authorized by Executive order to be kept secret in the interest of "national defense or foreign policy." The court found that the declarations submitted by the government establish with adequate specificity that release of images depicting the detainee could logically and plausibly harm national security because these images are uniquely susceptible to use by anti-American extremists as propaganda to incite violence against United States interests domestically and abroad. Accordingly, the court affirmed the district court's grant of summary judgment for defendants. View "Center for Constitutional Rights v. CIA" on Justia Law

Plaintiffs filed a putative class action against defendants alleging that defendants violated the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. 1692 et seq., and New York statutory and common law. Plaintiffs alleged that defendants obtained unauthorized attorneys' fees and costs in connection with actions to foreclose liens on plaintiffs' properties arising out of unpaid municipal property taxes and water and sewer charges. The court held that liens for mandatory water and sewer charges imposed by New York City as an incident to property ownership, which are treated as akin to property tax liens, are not subject to the FDCPA because they do not involve a "debt" as that term is defined in the statute. The court also held that the district court properly declined to exercise supplemental jurisdiction over the state law claims. Accordingly, the court affirmed the judgment of the district court. View "Boyd v. J.E. Robert Co., Inc." on Justia Law

Plaintiff filed suit under the Freedom of Information Act (FOIA), 5 U.S.C. 552, seeking disclosure of records held by NARA of archived presidential and vice-presidential materials submitted by or on behalf of former President George W. Bush and former Vice-President Richard B. Cheney. The court concluded that the records are protected by FOIA's Exemption 6, which permits the withholding of personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy. The records requested in this case were made for purposes of private speech, perhaps for preparation of memoirs, and reveal preliminary thinking and personal matters. Accordingly, the court affirmed the district court's grant of summary judgment to NARA. View "Cook v. Nat'l Archives & Records Admin." on Justia Law

VRLC is a non-profit corporation and VRLC-FIPE is a political committee formed under Vermont law. VRLC challenged three disclosure provisions of Vermont's election laws as unconstitutionally vague and violating freedom of speech. The court concluded that the Vermont statutory disclosure provisions concerning electioneering communications and mass media activities are constitutional and did not violate the Fourteenth Amendment's due process guarantee due to vagueness nor the First Amendment's free speech guarantee; Vermont's "political committee" definition did not violate the Fourteenth Amendment's due process guarantee because of vagueness nor violate the First Amendment's free speech guarantee; and Vermont may impose contribution limits on VRLC-PC, an entity that makes contributions to candidates, and the statute's contribution limits were constitutionally applied to VRLC-FIPE, which claims to be an independent-expenditure-only PAC. Accordingly, the court affirmed the district court's grant of summary judgment to defendants. View "Vermont Right to Life Committee v. Sorrell, et al." on Justia Law

Claimants appealed from the district court's forfeiture orders of 23 of the defendant funds and properties to the United States. The judgments were entered by default after the district court granted the motion of the United States under the fugitive disentitlement statute, 28 U.S.C. 2466, to strike Claimants' claims to the properties on the ground that Claimants Padma and Reddy (the "Allens") remained outside the United States in order to avoid prosecution in a related criminal case. The court rejected the government's contention that the burden of proof as to intent under the fugitive disentitlement statute was on Claimants. However, the court also rejected Claimants' contentions that summary judgment standards were applicable, and that the court was required to find that avoidance of criminal prosecution was the Allens' sole, dominant, or principal reason for remaining outside of the United States. The court concluded that the district court's findings were not clearly erroneous and that its application of the fugitive disentitlement statute was well within the bounds of its discretion. The court considered all of Claimants' challenges and found them to be without merit. Accordingly, the court affirmed the judgment of the district court. View "United States v. Technodyne LLC" on Justia Law

Plaintiff filed suit against the Town after a decade of dealing with the Town in plaintiff's efforts to apply for subdivision approval. The court reversed the district court's decision to dismiss plaintiff's federal takings claims, concluding that his claim became ripe because of the way the Town handled his application under Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City where the Town employed a decade of unfair and repetitive procedures, which made seeking a final decision futile. The Town also unfairly manipulated the litigation of the case in a way that might have prevented plaintiff from ever bringing his takings claim. The court vacated the district court's dismissal of plaintiff's non-takings claims based on ripeness grounds and declined to exercise supplemental jurisdiction over his state law claims. The court affirmed the district court's decision to dismiss plaintiff's 42 U.S.C. 1981 claim, to deny plaintiff leave to amend to add a 42 U.S.C. 1982 claim, and to dismiss plaintiff's procedural due process claim based on the consultants' fee law. View "Sherman v. Town of Chester" on Justia Law

Plaintiff filed suit against the City, the NYPD, and four individual State and Federal law enforcement officials under 42 U.S.C. 1981, 1983, 1985, and 1988 and State law. Plaintiff claimed that a Federal agent presented false testimony to the State grand jury that returned the indictment against him. The court concluded that the district court correctly concluded that plaintiff's Bivens and section 1983 claims were foreclosed by Rehberg v. Paulk; plaintiff's allegation that his indictment was premised on faulty laboratory results failed to support a plausible fair trial claim; the district court correctly held that plaintiff failed to state a claim for abuse of process as to either the individual NYPD defendants or the agent; the district court did not err in dismissing plaintiff's claim of malicious prosecution; plaintiff failed to plead facts showing that defendants acted with discriminatory animus, as required to state a claim under sections 1981 or 1985; and the district court properly dismissed plaintiff's claim against the City and the NYPD for municipal liability. Accordingly, the court affirmed the district court's dismissal of plaintiff's second amended complaint. View "Morales v. City of New York" on Justia Law