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

The case involves Travis Woods, a wheelchair user, who sued the Central New York Regional Transportation Authority and its subsidiary Centro of Oneida, Inc. (collectively, "Centro"), which operate the public bus service in Oneida County. Woods claimed that Centro violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act by failing to provide wheelchair-accessible bus stops. He argued that the district court erred in granting summary judgment to Centro on his claims.The United States District Court for the Northern District of New York granted summary judgment to Centro, dismissing Woods's complaint. The court found that Centro's paratransit service and its flexible pick-up and drop-off policy were reasonable accommodations providing meaningful access to Centro’s bus service.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court found that Woods's claims under sections 12147 and 12148 of the ADA failed as a matter of law. The court concluded that Woods had not shown that the altered portions of Centro’s bus stops were inaccessible or that Centro’s bus service was not readily accessible to individuals with disabilities. The court also found that Woods had not established that any modifications to Centro’s policies, practices, or procedures were necessary to avoid discrimination or to provide program access. Therefore, the court affirmed the judgment of the district court. View "Woods v. Centro of Oneida, Inc." 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

In 2021, New York enacted the Affordable Broadband Act (ABA), which required internet service providers to offer broadband internet to qualifying households at reduced prices. A group of trade organizations representing internet service providers sued, arguing that the ABA was preempted by federal law. The district court agreed with the plaintiffs and granted a preliminary injunction barring New York from enforcing the ABA. The parties later requested that the district court enter a stipulated final judgment and permanent injunction.The United States Court of Appeals for the Second Circuit disagreed with the lower court's decision. The appellate court concluded that the ABA was not field-preempted by the Communications Act of 1934 (as amended by the Telecommunications Act of 1996), because the Act does not establish a framework of rate regulation that is sufficiently comprehensive to imply that Congress intended to exclude the states from entering the field. The court also concluded that the ABA was not conflict-preempted by the Federal Communications Commission’s 2018 order classifying broadband as an information service. The court reasoned that the order stripped the agency of its authority to regulate the rates charged for broadband internet, and a federal agency cannot exclude states from regulating in an area where the agency itself lacks regulatory authority. Accordingly, the court reversed the judgment of the district court and vacated the permanent injunction. View "New York State Telecommunications Association, Inc. v. James" on Justia Law

The case in question involves a defendant, Saba Rosario Ventura, who was initially detained by Immigration and Customs Enforcement (ICE) after the District Court ordered his release on bail pending his criminal trial. The District Court later dismissed the indictment against Ventura, arguing that ICE had detained him in bad faith, aiming to circumvent the bail order. The case was appealed to the United States Court of Appeals for the Second Circuit, which previously remanded the case to the District Court to clarify whether it had found that ICE's detention of Ventura was a direct violation of a federal court order releasing him under the Bail Reform Act.On remand, the District Court reasserted its claim that ICE's detention of Ventura was pretextual and in bad faith, not for removal, but to detain him pending his criminal trial. However, the Court of Appeals disagreed, finding no substantial evidence to support the District Court's assertion. The Court of Appeals noted that the District Court's finding was based on legal arguments rather than factual evidence. It also noted that, even if ICE disagreed with the District Court's assessment of Ventura's risk of flight, it was not enough to prove that ICE's detention was pretextual.The Court of Appeals ultimately reversed the District Court's orders, concluding that the finding of ICE's pretextual and bad faith detention of Ventura was clearly erroneous, given the lack of factual evidence. View "United States v. Ventura" on Justia Law

The case involves a dispute over the legality of an agreement between River 1, LLC, an American company, and Viking USA LLC, a subsidiary of a Swiss company, under federal maritime law. The United States Maritime Administration (MARAD) had confirmed the legality of the agreement as a "time charter" under 46 U.S.C. § 56101(a)(i). However, American Cruise Lines argued that the agreement should be construed as a "bareboat" charter which is not covered under the standing blanket approval of MARAD, and thus, grants a foreign company impermissible control of an American vessel.The United States Court of Appeals for the Second Circuit affirmed MARAD's decision. It found that the agreement didn't grant Viking exclusive possession and control of the cruise ship in a way that blackletter maritime law recognizes as sufficient to create a bareboat charter. It noted that the ship's crew was provided by River 1, the vessel master was overseen by River 1, and River 1 bore primary responsibility for the ship’s day-to-day maintenance and care. Viking's ability to set the itinerary was consistent with the maritime law definition of a time charter.The court also rejected American Cruise Lines' allegations that MARAD failed to follow the notice and comment provisions applicable to this case. It concluded that MARAD fully complied with the new procedural requirements imposed by the National Defense Authorization Act of 2021. View "American Cruise Lines v. United States of America" on Justia Law

The United States Court of Appeals for the Second Circuit heard a case initiated by Adam Hart, who filed a qui tam action under the False Claims Act (FCA) against pharmaceutical distributor McKesson. Hart alleged that McKesson provided business management tools to its customers for free in exchange for commitments to purchase drugs, which he claimed violated the federal anti-kickback statute (AKS) and several analogous state laws. The district court dismissed Hart's FCA claim, determining he failed to allege McKesson acted "willfully" as required by the AKS.On appeal, the Second Circuit held that to act "willfully" under the AKS, a defendant must knowingly act in a way that is unlawful. The court found that Hart failed to provide sufficient facts to meet this standard. However, the court disagreed with the district court's assertion that Hart's state claims were premised solely on a violation of the federal AKS. Consequently, the Second Circuit affirmed the dismissal of Hart’s federal FCA claim, vacated the dismissal of the remaining state claims, and remanded for further proceedings. View "United States, ex rel. Hart v. McKesson Corp." on Justia Law

The case involves Brian Benjamin, a state senator in New York from 2017 to 2021, who was indicted on charges of federal funds bribery, honest services wire fraud, conspiracy to commit each of those offenses, and falsifying records. The U.S. District Court for the Southern District of New York dismissed three of the charges on the ground that the indictment failed to allege an explicit quid pro quo between Benjamin and his campaign donor. The government appealed this decision.According to the allegations, Benjamin agreed to allocate state funds to a non-profit organization controlled by a real estate developer in his district, in exchange for campaign contributions. The developer was allegedly aware of the quid pro quo arrangement and proceeded to provide funds to Benjamin's campaign. Furthermore, Benjamin allegedly attempted to conceal this arrangement by falsifying campaign forms and providing false information during his background check when he was nominated to be lieutenant governor of New York.On appeal, the United States Court of Appeals for the Second Circuit reversed the lower court's decision. The appellate court held that an explicit quid pro quo does not need to be expressly stated; it can be inferred from the official’s and the payor’s words and actions. The court concluded that the indictment sufficiently alleged an explicit quid pro quo, as it stated that Benjamin obtained campaign contributions in exchange for his agreement to use his official authority to obtain a state grant for a non-profit organization. Therefore, the case was remanded for further proceedings. View "United States v. Benjamin" on Justia Law

John Wilson, the plaintiff-appellant, made several requests under the Freedom of Information Act (FOIA) to the Federal Bureau of Investigation (FBI), the defendant-appellee, to release records concerning him. Dissatisfied with the FBI's response, Wilson filed a suit in the Southern District of New York, alleging that the FBI failed to conduct an adequate search. The District Court ruled in favor of Wilson, partially granting his motion for summary judgment by ordering the FBI to conduct a search of an additional database. However, the search did not yield any new disclosures to Wilson. Subsequently, Wilson filed a motion seeking attorneys’ fees and costs under FOIA's fee-shifting provision, arguing that he was a substantially prevailing party. The District Court denied his motion, applying the criteria set by the United States Court of Appeals for the Second Circuit in a previous case, Pietrangelo v. United States Army. Wilson appealed this decision.On appeal, the Second Circuit Court affirmed the decision of the District Court, concluding that the District Court correctly applied the Pietrangelo factors and did not abuse its discretion in ruling that those factors weighed against an award of attorneys’ fees and costs. The Second Circuit Court found that the public benefit derived from Wilson's case was minimal, Wilson's interest in the records was personal rather than public, and the FBI had a reasonable basis for withholding the requested information. As such, it concluded that the District Court did not err in denying Wilson's motion for attorneys’ fees and costs. View "Wilson v. Federal Bureau of Investigation" on Justia Law

After two United States Army pilots tragically perished in a helicopter crash, their surviving family members sued various companies responsible for the making of the helicopter. The family members alleged that manufacturing and/or defective operating instructions and warnings caused the pilots’ deaths. The companies countered that the family members’ asserted state law claims were barred by a number of preemption doctrines. The district court granted summary judgment in favor of the companies, finding that there was implied field preemption under the Federal Aviation Act (the “FAAct” or “Act”).   The Second Circuit vacated. The court explained that it believes that field preemption is always a matter of congressional intent, and Congress’s removal of military aircraft from the FAAct’s reach indicates that it did not wish to include them in the FAAct’s preempted field. Rather, Congress intended for the Department of Defense (“DoD”) to have autonomy over its own aircraft. While it is possible that the family members’ claims may be barred by the military contractor defense, another preemption doctrine, see generally Boyle v. United Techs. Corp., 487 U.S. 500 (1988)—this determination requires a fact-intensive analysis to be handled by the district court in the first instance. Further, the court wrote that aside from any issues of preemption by the military contractor defense, the family members offered sufficient evidence under Georgia law for their strict liability manufacturing defect claim to survive summary judgment. View "Jones et al. v. Goodrich Pump & Engine Control Systems, Inc. et al." on Justia Law

Defendant Klarna, Inc. ("Klarna") provides a "buy now, pay later" service that allows shoppers to buy a product and pay for it in four equal installments over time without incurring any interest or fees. Plaintiff paid for two online purchases using Klarna. Plaintiff incurred $70 in overdraft fees. Plaintiff brought this action on behalf of herself and a class of similarly situated consumers, alleging that Klarna misrepresents and conceals the risk of bank-overdraft fees that consumers face when using its pay-over-time service and asserting claims for common-law fraud and violations of the Connecticut Unfair Trade Practice Act ("CUTPA"). Klarna moved to compel arbitration. The district court denied Klarna's motion.   The Second Circuit reversed he district court's order and remanded with instructions to grant Klarna's motion to compel arbitration. The court explained that when Plaintiff arrived at the Klarna Widget, she knew well that purchasing the GameStop item with Klarna meant that she was entering into a continuing relationship with Klarna, one that would endure at least until she repaid all four installments. The Klarna Widget provided clear notice that there were terms that would govern this continuing relationship. A reasonable internet user, therefore, would understand that finalizing the GameStop transaction, entering into a forward-looking relationship with Klarna, and receiving the benefit of Klarna's service would constitute assent to those terms. The court explained that Plaintiff was on inquiry notice that her "agreement to the payment terms," necessarily encompassed more than the information provided on the Klarna Widget, and the burden was then on her to find out to what terms she was accepting. View "Najah Edmundson v. Klarna Inc." on Justia Law