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

Plaintiffs, CompassCare, the National Institute of Family and Life Advocates (NIFLA), and First Bible Baptist Church, challenged the constitutionality of New York Labor Law Section 203-e, which prohibits discrimination based on an employee’s or a dependent’s reproductive health decision making. They argued that the law infringed on their First Amendment rights of expressive association, speech, and religion, and that the Notice Provision, which required employers issuing employee handbooks to include information about employees' rights under the Act, compelled speech in violation of the First Amendment.The United States District Court for the Northern District of New York dismissed Plaintiffs' claims related to expressive association, speech, free exercise, religious autonomy, and vagueness. However, it permanently enjoined the enforcement of the Act’s Notice Provision. The case was then influenced by the Second Circuit's decision in Slattery v. Hochul, which held that an employer might have an associational-rights claim if the Act forces the employer to employ individuals acting against the organization’s mission.The United States Court of Appeals for the Second Circuit reviewed the case. It vacated the District Court’s dismissal of Plaintiffs’ expressive-association claim, the grant of summary judgment to Plaintiffs regarding the Notice Provision, and the permanent injunction. The Court remanded the case for the District Court to determine whether any Plaintiff has plausibly alleged an associational-rights claim under the precedent set by Slattery. The Court held that the Act’s Notice Provision is subject to rational basis review and is reasonably related to the State’s interest in preventing deception of employees regarding their statutory rights. It also affirmed the dismissal of Plaintiffs’ free speech and free exercise claims. View "CompassCare v. Hochul" on Justia Law

A dental hygienist brought claims for sex discrimination, retaliation, and negligence against her former employer and supervisors. She alleged that her supervisor made repeated sexual advances and harassed her throughout her employment. The United States District Court for the Southern District of New York granted summary judgment in favor of the defendants on the retaliation claims and allowed the other claims to proceed to trial. A jury awarded the plaintiff $575,000 in emotional distress damages and $2 million in punitive damages. However, the district court granted a motion for a new trial, finding the damages excessive and indicative of unfair prejudice. In the second trial, the court precluded certain evidence, and the jury awarded the plaintiff only $1 in nominal damages.The plaintiff appealed the district court’s summary judgment ruling, the order granting a new trial, and the evidentiary rulings. The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court’s summary judgment on the retaliation claims, agreeing that the plaintiff did not engage in protected activity as required for such claims. The court also upheld the district court’s decision to grant a new trial, finding no abuse of discretion in the determination that the jury’s damages award was excessive and indicative of prejudice. Additionally, the court affirmed the district court’s evidentiary rulings, including the exclusion of the plaintiff’s psychiatric records, portions of a coworker’s deposition testimony, and an anonymous fax.The Second Circuit concluded that the district court did not err in any of its challenged rulings and affirmed the judgment of the district court. View "Qorrolli v. Metropolitan Dental Associates" on Justia Law

Participants in Deloitte LLP’s 401(k) retirement plan filed a class action lawsuit against the plan fiduciaries, alleging that they breached their fiduciary duty under the Employee Retirement Income Security Act (ERISA) by allowing excessive administrative and recordkeeping fees. The plaintiffs claimed that the fees were higher than those of comparable plans and that the fiduciaries failed to obtain lower fees.The United States District Court for the Southern District of New York dismissed the action, finding that the plaintiffs did not plausibly allege that the fees were excessive relative to the services provided. The court also denied the plaintiffs' motion to file an amended complaint, deeming it futile as the proposed amendments did not cure the deficiencies in the original complaint.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs failed to provide sufficient factual allegations to support a plausible inference that the defendants breached their duty of prudence. The court noted that the plaintiffs did not adequately compare the services provided by the plan to those of the comparator plans, nor did they provide context to show that the fees were excessive. The court also upheld the dismissal of the derivative claim for failure to monitor, as it was dependent on the primary claim of breach of fiduciary duty. View "Singh v. Deloitte LLP" on Justia Law

A former chauffeur, Hyunhuy Nam, filed a lawsuit against the Permanent Mission of the Republic of Korea to the United Nations, alleging violations of federal, state, and city wage-and-hour and anti-discrimination laws. Nam, a South Korean citizen and U.S. permanent resident, was employed by the Mission as a chauffeur. His duties included driving high-level officials, adhering to diplomatic protocols, and maintaining confidentiality of classified information. Nam was required to undergo a high-level security clearance and sign annual confidentiality agreements. He was eventually terminated at age 61, after his contract was extended due to his wife's job loss during the pandemic.The United States District Court for the Southern District of New York denied the Mission's motion to dismiss, holding that Nam's employment fell within the "commercial activity" exception to the Foreign Sovereign Immunities Act (FSIA). The court later granted Nam's motion for partial summary judgment, awarding him damages and interest on his wage-and-hour claims, while the remaining claims were set for trial. The Mission appealed, arguing that it was immune under the FSIA.The United States Court of Appeals for the Second Circuit vacated the district court's decision and remanded the case for further proceedings. The appellate court held that the district court erred in granting summary judgment to Nam without resolving factual disputes regarding the nature of his employment. The court emphasized that the district court should have considered whether Nam's employment was governmental or commercial in nature, taking into account the context of his duties and the security measures involved. The appellate court instructed the district court to weigh the evidence, resolve conflicts, and, if necessary, conduct an evidentiary hearing to determine the applicability of the FSIA's commercial activity exception. View "Nam v. Permanent Mission of the Republic of Korea to the United" on Justia Law

In this case, Denise Kemp, a manager at Regeneron Pharmaceuticals, Inc., worked remotely in June 2016 to care for her child with a serious medical condition. Regeneron then restricted her remote work to one day per week and required her to use intermittent leave under the Family and Medical Leave Act (FMLA) for additional time away. Kemp sued Regeneron, alleging interference with her FMLA rights, and discrimination, retaliation, and constructive discharge under the New York State Human Rights Law (NYSHRL).The United States District Court for the Southern District of New York dismissed Kemp’s FMLA claim, reasoning that Regeneron had not denied her FMLA benefits and that the claim was time-barred. The court also dismissed her NYSHRL claims on the merits.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that an employer can violate the FMLA by interfering with an employee’s use of FMLA benefits, even if the benefits are ultimately granted. However, the court affirmed the dismissal of Kemp’s FMLA claim as time-barred, finding no evidence of a willful violation by Regeneron to extend the statute of limitations. The court also affirmed the dismissal of Kemp’s NYSHRL claims for discrimination and retaliation as time-barred, noting that Kemp was informed of the adverse actions before the relevant date. Lastly, the court upheld the dismissal of Kemp’s constructive discharge claim, concluding that her working conditions were not intolerable enough to compel resignation.The Second Circuit affirmed the District Court’s judgment, dismissing all of Kemp’s claims. View "Kemp v. Regeneron Pharm., Inc." on Justia Law

Robert Guthrie, a former employee of Rainbow Fencing Inc. (RFI), filed a lawsuit seeking unpaid wages and statutory damages for RFI's failure to provide wage notices and wage statements as required by New York law. Guthrie worked as a welder for RFI from 2014 to 2021 and claimed he was not paid for overtime hours. The district court entered a default judgment for the unpaid wages but dismissed Guthrie's claim for statutory damages, ruling that he lacked standing because he did not allege an injury-in-fact resulting from the failure to provide the required notices and statements.The United States District Court for the Eastern District of New York initially reviewed the case. The court granted a default judgment for Guthrie's unpaid wages but dismissed his claim for statutory damages due to lack of standing. The court concluded that Guthrie did not allege a concrete injury-in-fact caused by the absence of wage notices and statements, which is necessary to meet the case-or-controversy requirement of Article III.The United States Court of Appeals for the Second Circuit reviewed the case on appeal. The court affirmed the district court's decision, agreeing that Guthrie lacked standing to pursue statutory damages. The appellate court held that a plaintiff must allege a concrete injury-in-fact resulting from the statutory violation to have standing. Guthrie's general claims about potential harms did not suffice, as he failed to link these potential harms to any actual injury he experienced. Therefore, the court concluded that Guthrie did not meet the requirements for Article III standing and affirmed the dismissal of his claim for statutory damages. View "Guthrie v. Rainbow Fencing Inc." on Justia Law

Plaintiff Joseph Pessin, representing himself and others similarly situated, sued JPMorgan Chase & Company (JPMC), the JPMorgan Chase Retirement Plan, and its fiduciaries under the Employee Retirement Income Security Act of 1974 (ERISA). Pessin alleged that the Defendants failed to provide adequate disclosures to pension plan participants after converting the retirement plan from a traditional defined benefit plan to a cash balance plan. Specifically, Pessin claimed that the Defendants did not properly inform participants about the "wear-away" effect, which could freeze their benefits until the cash balance exceeded the previously accrued benefits.The United States District Court for the Southern District of New York dismissed Pessin’s amended complaint for failure to state a claim. The court found that the Defendants had provided sufficient disclosures explaining the retirement plan's workings and did not mislead participants about the conversion's impact on their accrued benefits. The court concluded that the summary plan descriptions (SPDs) and benefit statements were adequate and that the Defendants did not breach their fiduciary duties under ERISA.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed with the district court that the Defendants sufficiently disclosed the wear-away effect and that the SPDs clearly explained how benefits would be calculated. However, the appellate court disagreed with the district court's finding that the Defendants complied with ERISA § 105(a) regarding annual pension benefit statements. The court held that the benefit statements did not properly indicate the total benefits accrued, as they only included the cash balance amount and not the higher minimum benefit from the prior plan. Consequently, the court found that Pessin adequately alleged a breach of fiduciary duty by the JPMC Board for failing to monitor the JPMC Benefits Executive's performance regarding the benefit statements.The Second Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings consistent with its opinion. View "Pessin v. JPMorgan Chase" on Justia Law

In this case, the plaintiff, Patricia Olivieri, alleged that her employer, Stifel, Nicolaus & Company, Incorporated, and her manager, Neil Isler, subjected her to sexual harassment and a hostile work environment. Olivieri claimed that Isler sexually assaulted and harassed her, and that after she reported his behavior, she faced retaliation and continued harassment from Stifel and other defendants. Olivieri's allegations included inappropriate comments, physical contact, and retaliatory actions such as changes in her job responsibilities and work environment.The United States District Court for the Eastern District of New York initially granted the defendants' motion to compel arbitration based on an arbitration agreement in Olivieri's employment contract. However, after the enactment of the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), Olivieri moved for reconsideration. The district court vacated its earlier decision, concluding that Olivieri's claims accrued after the EFAA's effective date, making her arbitration agreement voidable under the new law.The United States Court of Appeals for the Second Circuit reviewed the district court's decision. The appellate court agreed with the lower court, applying the continuing violation doctrine to determine that Olivieri's hostile work environment claims accrued after the EFAA's effective date of March 3, 2022. The court held that the EFAA applied to Olivieri's claims, rendering her arbitration agreement invalid and unenforceable. Consequently, the Second Circuit affirmed the district court's order denying the motion to compel arbitration. View "Olivieri v. Stifel, Nicolaus & Company, Inc." on Justia Law

Scott Lupia, a locomotive engineer for New Jersey Transit Rail Operations, Inc. (NJT), was injured when the air conditioning (A/C) unit in his cab malfunctioned, causing the temperature to rise to 114 degrees Fahrenheit. Despite notifying his supervisors, Lupia was instructed to operate the train, leading to his collapse from heat exhaustion and subsequent permanent injuries. Lupia filed a lawsuit under the Federal Employers’ Liability Act (FELA), alleging that NJT violated the Locomotive Inspection Act (LIA) by failing to maintain the locomotive's parts and appurtenances, including the A/C unit, in safe operating condition.The United States District Court for the Southern District of New York denied NJT's motion for summary judgment, holding that a temperature control system, including an A/C unit, is considered a "part and appurtenance" of a locomotive under the LIA. The court found sufficient evidence that NJT's failure to maintain the A/C unit in proper condition posed an unnecessary danger of personal injury. During the trial, the court allowed Lupia to introduce a report to impeach NJT’s witness and permitted arguments regarding noneconomic damages. The jury awarded Lupia significant damages for lost earnings and pain and suffering.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the District Court's judgment. The appellate court agreed that a temperature control system is an integral part of a locomotive and that NJT was required to maintain the A/C unit in safe operating condition once it chose to use it as part of its temperature control system. The court also found no abuse of discretion in the District Court's evidentiary rulings and its decision to allow arguments on noneconomic damages. View "Lupia v. New Jersey Transit Rail Operations, Inc." on Justia Law

Manoucheka Francois, a train conductor for Metro-North Commuter Railroad Company, was injured in a car crash while being transported by a taxi hired by her employer. The taxi driver, Michael Cellante, had consumed four to five shots of alcohol before picking her up. As a result, the taxi crashed, and Francois sustained injuries.Francois sued Metro-North under the Federal Employers’ Liability Act (FELA), alleging both direct liability for negligently hiring the impaired taxi driver and vicarious liability for the driver’s negligence. The United States District Court for the Southern District of New York granted summary judgment in favor of Metro-North on both theories. The court found no evidence that Metro-North could have foreseen the driver’s intoxication, thus negating direct liability. It also concluded that the driver’s act of drinking removed him from the scope of his agency, precluding vicarious liability.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court’s decision regarding direct liability, agreeing that Metro-North had no reason to foresee the driver’s intoxication. However, the court vacated the summary judgment on vicarious liability. It held that whether the driver acted within the scope of his agency while driving Francois, despite being impaired, presented a triable issue of fact. The court emphasized that in FELA cases, plaintiffs enjoy a relaxed burden of proof, and issues of agency and foreseeability should generally be decided by a jury.The Second Circuit thus affirmed the district court’s ruling on direct liability, vacated the ruling on vicarious liability, and remanded the case for further proceedings. View "Francois v. Metro-North Commuter Railroad Co." on Justia Law