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

Articles Posted in Juvenile Law
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Plaintiffs-appellants, nineteen children in New York City’s foster care system, filed suit alleging “systemic deficiencies” in the administration of the City’s foster care system in violation of federal and state law. The named Plaintiffs moved to represent a class of all children who are now or will be in the foster care custody of the Commissioner of New York City’s Administration for Children’s Services and two subclasses. As remedies, they sought injunctive and declaratory relief to redress alleged class-wide injuries caused by deficiencies in the City’s administration—and the New York State Office of Children and Family Services’ oversight—of foster care. The district court denied Plaintiffs’ motion for class certification. Plaintiffs appealed, arguing that the district court erred in its analysis of the commonality and typicality requirements under Federal Rule of Civil Procedure 23(a).   The Second Circuit vacated the district court’s order denying class certification and remanded. The court held that the district court erred in its analysis of commonality and typicality under Rule 23. The court explained that the district court did not determine whether commonality and typicality exist with respect to each of Plaintiffs’ claims. Instead, it concluded that commonality was lacking as to all alleged harms because “Plaintiffs’ allegations do not flow from unitary, non-discretionary policies.” The court held that this approach was legal error requiring remand. Further, the court wrote that here, the district court largely relied upon its commonality analysis to support its finding that typicality was not satisfied. Thus, the deficiencies identified in its commonality inquiry can also be found in its handling of typicality. View "Elisa W. v. City of New York" on Justia Law

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Niagara County’s Child Protective Services successfully petitioned in Niagara County Family Court to strip Plaintiff of her parental rights over her minor son. Plaintiff appealed the Family Court’s decision. While that appeal was pending, she brought suit in federal court against officials and entities involved in terminating her parental rights. The district court dismissed Plaintiff’s suit pursuant to the Rooker-Feldman doctrine.   The Second Circuit vacated the judgment insofar as the district court denied Plaintiff’s motions for leave to amend and for additional time to serve defendants. The court held that the RookerFeldman doctrine does not apply when an appeal remains pending in state court. Rooker-Feldman applies only after the state proceedings have ended. View "Hunter v. McMahon" on Justia Law

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The Second Circuit affirmed the district court's order granting a preliminary injunction in favor of Hartford and enjoining defendants, who are administrators and clerks at the Connecticut Superior Court, from enforcing a Connecticut statute that mandates automatic sealing of all judicial records and closure to the public of all court proceedings in criminal prosecutions of juvenile defendants transferred to the regular criminal docket.The court held that Public Act Number 19-187 is unconstitutional. The court concluded that the Courant has a qualified First Amendment right of access to criminal prosecutions of juveniles in regular criminal court. The court agreed with the district court that, for cases in criminal court, even those involving juvenile defendants, the "place and process" have historically been open to the public. Furthermore, public access plays a significant positive role in the functioning of the particular process in question. The court also concluded that the Act infringes on that right because it is not narrowly tailored to serve a compelling state interest. Finally, the court concluded that the Courant has shown that all four requirements for a preliminary injunction have been met. View "Hartford Courant Co., LLC v. Carroll" on Justia Law

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The Second Circuit affirmed defendant's 55-year sentence imposed for his conviction of participating in a pattern of racketeering activity evidenced by his role in the murder of four teenagers. Defendant was 15 years old at the time of the offense and a member of the MS-13 gang when he participated in the execution-style murders of four members of a rival gang.The court assumed, for purposes of this appeal, that the district court was required to consider the factors in Miller v. Alabama, 567 U.S. 460 (2012), in determining that a sentence of 55 years, not subject to parole, was warranted for a defendant fifteen years old at the time of the homicide crimes. Even with this assumption, the court concluded that the district court considered the Miller factors and reasonably concluded that a further departure was not warranted. Acknowledging the broad scope of a sentencing judge's discretion and taking into account the care taken by the sentencing judge in exercising that discretion, the court concluded that defendant's sentence is not unreasonable in any legally cognizable sense. Finally, the court noted that defendant's sentence illustrates the unfortunate consequences of eliminating parole. Nevertheless, it is a sentence that a conscientious district judge concluded was appropriate and, upon review, the court affirmed. The court considered defendant's remaining arguments and found them to be without merit. View "United States v. Portillo" on Justia Law

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Defendant appealed his conviction for conspiracy to violate the Racketeer Influenced and Corrupt Organizations Act (RICO), as well as narcotics-conspiracy and firearm-possession charges related to his membership in the 10th Street Gang of Buffalo, New York. Defendant, who was seventeen years old at the time, participated in a double murder and was sentenced to life imprisonment.The Second Circuit rejected defendant's challenges to the introduction into evidence of a gun seized from his home; the denial of his motion for a mistrial based on a Bruton violation; the denial of his Batson challenges, and the denial of his requests for certain jury charges. However, the court held that the district court imposed defendant's sentence without explicitly considering his age at the time of the double murders, and thus violated the principle recognized in Miller v. Alabama, 567 U.S. 460, 471 (2012), that children are constitutionally different from adults for purposes of sentencing. Miller stated that those under the age of eighteen are different because the distinctive attributes of youth diminish the penological justifications for imposing the harshest sentences on juvenile offenders, even when they commit terrible crimes. Therefore, the court affirmed defendant's conviction but vacated his sentence, remanding for resentencing in light of Miller. View "United States v. Delgado" on Justia Law

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Sellers was sentenced to 15 years’ imprisonment for being a felon in possession of a firearm and ammunition under 26 18 U.S.C. 922(g)(1) and under 18 U.S.C. 924(e)(1) of the Armed Career Criminal Act (ACCA). The Second Circuit remanded for resentencing. Application of the ACCA was error. Sellers’s 2001 state conviction for criminal sale of a controlled substance did not qualify as one of the “three previous convictions” necessary to apply the ACCA because he was adjudicated as a youthful offender for that offense under New York law, 18 U.S.C. 924(e)(1). The youthful offender designation “set aside” the conviction. View "United States v. Sellers" on Justia Law

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Plaintiffs, former students of Ithaca High School, claimed that defendants violated their First and Fourteenth Amendment rights by prohibiting the publication of a sexually-explicit cartoon in the Ithaca High School student newspaper ("IHS newspaper") and by prohibiting the on-campus distribution of an independent student newspaper containing the same cartoon. At issue was whether the district court erred in holding that the IHS newspaper was a limited public forum. The court concluded that the IHS newspaper was a limited public form and held that defendants lawfully prohibited the publication of the sexually-explicit cartoon pursuant to the standards for regulation of speech set forth in Bethel School District Number 403 v. Fraser and Hazelwood School District v. Kuhlmeier. The court also held that defendants lawfully prohibited the on-campus distribution of the sexually-explicit cartoon in an independent student newspaper pursuant to Fraser and that the court need not reach the question of whether defendants' prohibition of the on-campus distribution of the independent student newspaper was lawful under Tinker v. DesMoines Indep. Cmty. Scho. Dist.