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

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

In 1996, E. Jean Carroll encountered Donald J. Trump at the Bergdorf Goodman department store in Manhattan. Carroll alleged that Trump sexually abused her in a dressing room. In 2022, Trump made public statements denying the allegations and calling Carroll a liar. Carroll sued Trump for defamation and sexual assault, seeking damages.The United States District Court for the Southern District of New York held a nine-day trial. The jury found that Trump sexually abused Carroll and defamed her in his 2022 statements. The jury awarded Carroll $5 million in compensatory and punitive damages. Trump appealed, arguing that the district court made several evidentiary errors, including admitting testimony from two women who alleged past sexual assaults by Trump and a recording of a 2005 conversation where Trump described kissing and grabbing women without consent.The United States Court of Appeals for the Second Circuit reviewed the case for abuse of discretion. The court found that the district court did not err in its evidentiary rulings. The testimony of the two women and the 2005 recording were deemed admissible under Federal Rules of Evidence 413 and 415, which allow evidence of other sexual assaults in cases involving sexual assault claims. The court also found that Trump did not demonstrate that any claimed errors affected his substantial rights.The Second Circuit affirmed the district court's judgment, concluding that the evidentiary rulings were within the range of permissible decisions and that any potential errors were harmless. The court upheld the $5 million award to Carroll. View "Carroll v. Trump" on Justia Law

Sarah Palin filed a defamation lawsuit against The New York Times and its former Opinion Editor, James Bennet, alleging that an editorial falsely linked her political action committee's map to the 2011 shooting of Congresswoman Gabrielle Giffords. The editorial claimed a "clear" and "direct" link between the map and the shooting, which Palin argued was defamatory.Initially, the United States District Court for the Southern District of New York dismissed Palin's complaint under Federal Rule of Civil Procedure 12(b)(6). The Second Circuit Court of Appeals reinstated the case in 2019, finding that Palin had plausibly stated a defamation claim. The case proceeded to trial, where the jury deliberated but the district court dismissed the case again under Federal Rule of Civil Procedure 50, ruling that Palin had not proven actual malice by clear and convincing evidence. Despite this, the jury returned a verdict finding the defendants "not liable."The United States Court of Appeals for the Second Circuit reviewed the case and found that the district court's Rule 50 ruling improperly intruded on the jury's role by making credibility determinations and weighing evidence. The appellate court noted several trial errors, including the exclusion of relevant evidence, an inaccurate jury instruction, and jurors learning of the district court's Rule 50 dismissal during deliberations. These issues undermined the reliability of the jury's verdict.The Second Circuit vacated the district court's Rule 50 judgment and the jury's verdict, remanding the case for a new trial. The appellate court emphasized the importance of the jury's role in determining credibility and weighing evidence, and found that the errors at trial necessitated a retrial. View "Palin v. New York Times Co." on Justia Law

Bruce Kelley and his spouse, Nancy Kelley, filed a medical malpractice lawsuit in Vermont state court after Bruce Kelley was paralyzed from the waist down while residing at Franklin County Rehabilitation Center (FCRC). They alleged that Dr. Teig Marco, employed by Richford Health Center, Inc. (RHC), negligently treated Kelley, leading to his paralysis. RHC is a federally funded community health center deemed a member of the Public Health Service under the Federally Supported Health Centers Assistance Act (FSHCAA).The United States intervened and removed the case to federal district court, asserting that RHC and Dr. Marco were covered under the Federal Tort Claims Act (FTCA) due to their deemed status. The United States District Court for the District of Vermont held an evidentiary hearing and determined that the FSHCAA did not apply to Dr. Marco’s treatment of Kelley because Kelley was not a patient of RHC, and the treatment did not fall under the specified statutory criteria for nonpatients. Consequently, the District Court remanded the case to state court for lack of subject matter jurisdiction.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 Kelley was not a patient of RHC and that Dr. Marco’s treatment did not meet the criteria for FTCA coverage for nonpatients under the FSHCAA. The court concluded that the treatment did not qualify as after-hours coverage or emergency treatment and that RHC had not sought a particularized determination of coverage from the Department of Health and Human Services. Therefore, the remand to state court was appropriate, and the District Court's order was affirmed. View "Kelley v. Richford Health Center, 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

The case involves nine lawsuits filed in Connecticut state court, each asserting state-law personal injury claims related to the use of Zantac. The plaintiffs, represented by the same firm, structured their complaints to avoid federal jurisdiction by including fewer than 100 plaintiffs per suit and ensuring that each suit included a Connecticut plaintiff. The plaintiffs filed a motion to consolidate these actions, citing Connecticut Practice Book § 9-5, which the defendants argued proposed a joint trial, thus triggering federal jurisdiction under the Class Action Fairness Act (CAFA).The United States District Court for the District of Connecticut remanded the cases to state court, finding that the plaintiffs' motion to consolidate was intended only for pretrial purposes, not for a joint trial. The district court noted that the plaintiffs' motion cited authority that could be used for either pretrial management or a joint trial but concluded that the context indicated a pretrial purpose, especially given the plaintiffs' efforts to avoid federal jurisdiction.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court held that CAFA requires a determination of whether the plaintiffs intended to seek a joint trial. The court found that the plaintiffs' motion, when read in context, proposed only pretrial consolidation. The court emphasized that the plaintiffs' consistent efforts to avoid federal jurisdiction supported this interpretation. Thus, the appellate court concluded that the defendants did not meet their burden to demonstrate that federal jurisdiction existed under CAFA. View "Bacher v. Boehringer Ingelheim Pharmaceuticals, Inc." on Justia Law

Laura Henry filed a lawsuit against Olakunle Oluwole and their former employer, Bristol Hospital, alleging that Oluwole had sexually assaulted her. Shortly after the complaint was filed, Oluwole was seriously injured in a motorcycle accident, which he claimed prevented him from receiving timely notice of the action. Oluwole did not initially appear in court, leading the U.S. District Court for the District of Connecticut to enter a default judgment against him. Five years later, Oluwole appeared and moved to set aside the default judgment, but the district court denied his motion. The case against Bristol proceeded to a jury trial, which resulted in a verdict that Henry had failed to prove that Oluwole sexually assaulted, assaulted, or battered her. Following the jury verdict, the district court vacated the default judgment against Oluwole for the assault and battery claims but left it in place for other claims.The U.S. District Court for the District of Connecticut initially entered a default judgment against Oluwole due to his failure to appear. After Oluwole eventually appeared and moved to set aside the default judgment, the district court denied his motion, finding his default willful and that setting it aside would prejudice Henry. The jury trial against Bristol resulted in a verdict in favor of Bristol, finding no proof of sexual assault, assault, or battery by Oluwole. Consequently, the district court vacated the default judgment against Oluwole for the assault and battery claims but maintained it for other claims, including false imprisonment and emotional distress.The United States Court of Appeals for the Second Circuit reviewed the case and found that the district court erred in denying Oluwole’s motions to set aside the default judgment. The appellate court held that the district court should have set aside the default judgment based on the factors established in Enron Oil Corp. v. Diakuhara. Additionally, the appellate court determined that the entire default judgment should have been vacated following the jury verdict, as maintaining it was inconsistent with the jury’s findings, pursuant to the principle in Frow v. De La Vega. The Second Circuit reversed the district court’s judgment and remanded with instructions to enter judgment for Oluwole. View "Henry v. Oluwole" on Justia Law

This case is about a dispute between Richard Roe and St. John’s University (SJU) and Jane Doe. Roe, a male student at SJU, was accused of sexually assaulting two female students, Doe and Mary Smith, on separate occasions. SJU's disciplinary board found Roe guilty of non-consensual sexual contact with both Doe and Smith and imposed sanctions, including a suspension and eventual expulsion. Roe then sued SJU, alleging that his rights under Title IX of the Education Amendments of 1972 and state contract law had been violated. He also sued Doe for allegedly defaming him in an anonymous tweet accusing him of sexual assault. The United States District Court for the Eastern District of New York dismissed Roe's Title IX and state law claims, and declined to exercise jurisdiction over his defamation claim. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision, holding that Roe's complaint failed to state a plausible claim of sex discrimination under Title IX. The court found that, while Roe had identified some procedural irregularities in SJU's disciplinary proceedings, these were not sufficient to support a minimal plausible inference of sex discrimination. Furthermore, the court ruled that Roe's hostile environment claim was fatally deficient, as the single anonymous tweet at the center of his claim was not, standing alone, sufficiently severe to support a claim of a hostile educational environment under Title IX. View "Roe v. St. John's University" on Justia Law

In a defamation lawsuit brought by E. Jean Carroll against former President Donald Trump, the United States Court of Appeals for the Second Circuit ruled that presidential immunity can be waived and that Trump had waived his presidential immunity by failing to raise it as an affirmative defense in his original response to Carroll's complaint. Carroll sued Trump for defamation after he publicly denied her accusation of sexual assault in the mid-1990s. The court affirmed the lower court's decision to deny Trump's motion for summary judgment and his request to amend his answer to include presidential immunity as a defense. The court also upheld the lower court's decision to strike Trump's presidential immunity defense from his answer to Carroll's amended complaint. The case was remanded back to the lower court for further proceedings. View "Carroll v. Trump" on Justia Law

Plaintiff appealed from a partial final judgment of the district court dismissing his Connecticut state law claims for defamation and tortious interference with contract against Defendant, who accused Plaintiff of sexual assault in 2015 while the two were students at Yale University. Plaintiff argued that the district court erred in finding (1) Defendant to enjoy absolute quasi-judicial immunity for statements made at the 2018 Yale disciplinary hearing that resulted in Plaintiff’s expulsion from the university and (2) Plaintiff’s tortious interference claims based on Defendant’s original 2015 accusations to be untimely. On preliminary review, the Second Circuit was unable to determine whether Connecticut would recognize the Yale disciplinary hearing at issue as a quasi-judicial proceeding supporting absolute immunity in this case. Accordingly, the court certified questions pertinent to that determination to the Connecticut Supreme Court. That court responded that absolute immunity does not apply in this case because Yale’s disciplinary hearing was not a quasi-judicial proceeding in that it lacked procedural safeguards associated with judicial proceedings.   In response, The Second Circuit affirmed in part, vacated in part, and remanded. The court explained that while the Connecticut Supreme Court recognized the possibility for participants in such a hearing to be shielded by qualified immunity, the Connecticut Supreme Court concluded that Defendant is not presently entitled to dismissal on that ground because Plaintiff’s complaint sufficiently pleads the malice necessary to defeat such immunity. With this guidance as to Connecticut law, the court concluded on this appeal that Plaintiff’s complaint should not have been dismissed against Defendant except as to his tortious interference claim based on 2015 statements, which is untimely. View "Khan v. Yale Univ." on Justia Law