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

Angel Diaz, a prisoner in the custody of the New York State Department of Corrections and Community Supervision (DOCCS), filed a pro se petition for a writ of habeas corpus in the Southern District of New York. Diaz argued that due to the COVID-19 pandemic, the State could not provide him with constitutional conditions of confinement at any of its facilities, necessitating his release. He claimed that his high blood pressure and morbid obesity put him at severe risk of serious harm or death from COVID-19 and that DOCCS had no plan to protect medically vulnerable inmates like himself.The District Court referred the case to a magistrate judge, who recommended denying the petition on the grounds that Diaz's claim was not cognizable in habeas and should be brought under 42 U.S.C. § 1983 instead. The District Court adopted this recommendation, holding that Diaz's complaints about the conditions of his confinement did not challenge the validity or duration of his confinement. Diaz's request for a certificate of appealability was initially denied by the District Court but later granted by the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit reviewed the case and held that Diaz's claim was indeed cognizable under habeas corpus because he alleged violations of the Constitution that would require his release from all available facilities. However, the court found that Diaz failed to provide sufficient factual support to make his claim plausible. As a result, the Second Circuit affirmed the District Court's decision to dismiss the petition. View "Diaz v. Kopp" on Justia Law

Samantha Long, a former Clerk of the Town Justice Court for the Town of New Lebanon, filed a lawsuit against the Town of New Lebanon and Jessica Byrne, a former Town Justice. Long alleged that she was unlawfully terminated in retaliation for cooperating with an investigation by the New York State Commission on Judicial Conduct into Byrne’s suspected judicial misconduct. Long claimed that she provided specific case files to the Commission and refused to discuss the investigation with Byrne, which led to her termination. She argued that her termination violated her First Amendment rights and her rights under New York State Civil Service Law § 75-b.The United States District Court for the Northern District of New York dismissed Long’s claims. The court concluded that Long’s actions were not protected by the First Amendment because they were part of her official duties as Court Clerk and did not constitute protected citizen speech. Consequently, the court declined to exercise supplemental jurisdiction over Long’s Section 75-b claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court’s judgment and remanded the case for further proceedings. The appellate court held that Long’s complaint adequately alleged that she acted as a private citizen, not pursuant to her work responsibilities, when she cooperated with the Commission’s investigation and refused to discuss it with Byrne. The court emphasized that Long’s refusal to discuss the investigation with Byrne was not within the scope of her job duties and that her cooperation with the Commission was motivated by a sense of civic duty rather than employment-related responsibilities. The court also vacated the district court’s dismissal of Long’s state-law claim under Section 75-b, as the legal premise for the dismissal was defeated by the reinstatement of her First Amendment claim. View "Long v. Byrne" on Justia Law

The case involves a dispute over the rights to stage adaptations of Harper Lee's novel "To Kill a Mockingbird." In 1969, Lee granted The Dramatic Publishing Company (Dramatic) the exclusive rights to develop and license a stage adaptation of the novel for non-first-class productions. Decades later, Lee terminated this grant and authorized a new stage adaptation, with Atticus Limited Liability Company (Atticus) holding the rights to produce this second adaptation. Atticus sought a declaration from the United States District Court for the Southern District of New York that its performances did not infringe on any copyright interest held by Dramatic. Dramatic argued that it retained exclusive rights under the Copyright Act's derivative works exception and that Atticus's acquisition of rights was invalid.The district court rejected Dramatic's arguments, ruling in favor of Atticus and awarding it attorney's fees. Dramatic appealed the judgment on the merits and both parties cross-appealed the award of attorney's fees.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's judgment granting declaratory relief to Atticus, holding that Dramatic's exclusive rights did not survive Lee's termination of the 1969 grant. The court found that the derivative works exception did not preserve Dramatic's exclusive license to stage non-first-class productions after the termination. The court also rejected Dramatic's arguments regarding the invalidity of the 2015 grant to Atticus and the timeliness of Atticus's claim.Regarding attorney's fees, the Second Circuit vacated the district court's award and remanded for further consideration. The court agreed that Dramatic's statute of limitations and res judicata arguments were objectively unreasonable but found that the district court erred in concluding that Dramatic had forfeited its statute of limitations defense and that its discovery requests unnecessarily prolonged the litigation. The court affirmed the district court's decision to deny fees incurred before April 27, 2023, and declined to award Atticus its fees on appeal. View "Atticus Ltd. Liab. Co. v. The Dramatic Publ'g Co." on Justia Law

Karl Greenwood pled guilty to charges related to a cryptocurrency scam that defrauded investors of over $4.5 billion. Prior to sentencing, Greenwood submitted a partially redacted sentencing memorandum and exhibits, many of which were sealed. Matthew Lee, associated with Inner City Press, filed a motion to unseal and unredact these documents, arguing a right of access.The United States District Court for the Southern District of New York denied Lee's motion, stating that the redactions were limited to sensitive information such as medical details and personal information of Greenwood and his family. Lee appealed this decision, contending that the district court did not sufficiently justify the sealing of the exhibits.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the First Amendment right of access applies to sentencing memoranda and exhibits, requiring specific findings to justify sealing. The court found that while the district court adequately justified the redactions in the sentencing memorandum, it did not sufficiently explain the complete sealing of the exhibits. The appellate court vacated the district court's order in part and remanded the case for further proceedings to provide a more detailed justification for sealing the exhibits. The court affirmed the district court's decision regarding the redactions in the sentencing memorandum. View "Lee v. Greenwood" on Justia Law

Natalia Mikhaylovna Bardakova, a Russian citizen, was indicted for conspiring to help Oleg Deripaska, a Russian industrial magnate, evade U.S. sanctions and for making false statements to the FBI. Bardakova allegedly traveled to California to arrange for Deripaska’s partner to give birth there and lied to FBI agents about her ties to Deripaska. She left for Russia three days after being interviewed by the FBI and has not returned to the U.S. despite being indicted four months later.The United States District Court for the Southern District of New York denied Bardakova’s motion to dismiss the indictment, concluding that she was a fugitive from justice and should be disentitled from relief in federal court. Bardakova argued that she was not a fugitive and that even if she were, she should not have been disentitled.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Bardakova had constructively fled U.S. jurisdiction by allegedly committing a crime in the U.S. before leaving and refusing to return to face prosecution. The court determined that the district court did not abuse its discretion by disentitling her. The court affirmed the district court’s order denying Bardakova’s motion to dismiss the indictment, holding that the fugitive disentitlement doctrine applied and that the district court properly exercised its discretion in denying her motion. View "United States v. Bardakova" on Justia Law

In 2014, Tyrone Walker, who had been in solitary confinement for punitive reasons since 2000, was placed in solitary confinement as a preventative measure by prison officials, based on a determination that he posed a threat to prison security. The officials were constitutionally obligated to conduct regular, meaningful reviews of Walker’s solitary confinement. Walker argued that the reviews he received were not constitutionally meaningful, as they did not adequately assess his current threat level or consider his behavior over time.The United States District Court for the Northern District of New York granted summary judgment to the defendants, ruling that Walker demonstrated no genuine issues of material fact regarding the constitutional meaningfulness of his reviews. The court also decided that all defendants were entitled to qualified immunity because no clearly established right of Walker’s had been violated during the review process.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that a reasonable jury could find that the reviews Walker received during his continued solitary confinement were not constitutionally meaningful. The court noted that the reviews were repetitive and rote, failed to consider Walker’s positive behavior, and often used circular logic to justify his continued confinement. Additionally, the court found that the delays in completing and providing the reviews to Walker raised genuine issues of material fact regarding the meaningfulness of the process.The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings, emphasizing that the focus was on the procedural due process rights of Walker, not the substantive outcome of his confinement. The court also determined that it was premature to grant qualified immunity to the defendants at this stage. View "Walker v. Bellnier" on Justia Law

Plaintiffs, thirty survivors of childhood sexual abuse, sought damages for negligence from the Holy See under a vicarious liability theory. They alleged that the Holy See promulgated a mandatory policy of secrecy that governed how its dioceses and bishops handled reports of sexual abuse by clerics. Plaintiffs claimed that bishops in New York failed to warn children and parents of the dangers posed by the accused clerics and failed to report suspected abuse to law enforcement, thus emboldening abusers and exposing children to harm.The District Court granted the Holy See’s motion to dismiss for lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The court concluded that the discretionary function exclusion from the FSIA’s tortious activity exception barred Plaintiffs’ claims. The court found that the bishops’ conduct was discretionary and susceptible to policy analysis, thus falling within the discretionary function exclusion.The United States Court of Appeals for the Second Circuit reviewed the case de novo and affirmed the District Court’s judgment. The appellate court agreed that the discretionary function exclusion applied, precluding federal courts from exercising jurisdiction over the claims against the Holy See. The court held that the bishops’ challenged conduct involved discretionary acts and that Plaintiffs failed to allege that the bishops’ conduct violated a mandatory policy. Additionally, the court found that the bishops’ conduct was susceptible to policy analysis, satisfying the second prong of the Berkovitz/Gaubert test. Therefore, the discretionary function exclusion barred the exercise of jurisdiction over Plaintiffs’ claims against the Holy See. View "Blecher v. Holy See" on Justia Law

Bruce Silva was detained pending his criminal trial on various charges, including firearms, racketeering-conspiracy, and wire-fraud, related to his alleged involvement in the Dub City street gang. The New York City Police Department obtained a search warrant for Silva’s cell phone based on an affidavit by Detective Joseph Boyer, which included information from a confidential informant and Boyer’s expertise in gang-related crimes. The affidavit suggested that Silva’s cell phone might contain evidence of his criminal activities.The United States District Court for the Southern District of New York granted Silva’s motion to suppress the evidence obtained from his cell phone, ruling that the warrant application did not establish probable cause that Silva used his cell phone in connection with his criminal activities. The district court also found that law enforcement did not execute the search in good faith.The United States Court of Appeals for the Second Circuit reviewed the case and vacated the district court’s suppression order. The appellate court held that the district court misapprehended the probable-cause standard. It clarified that a warrant could be issued if there is probable cause to believe that the place to be searched contains evidence of a crime, regardless of whether there is probable cause indicating that the target used the property in furtherance of the criminal conduct. The court also found that the Boyer Affidavit, which included specific factual allegations and Boyer’s expertise, established the requisite nexus between Silva’s alleged crimes and his cell phone. Additionally, the court determined that law enforcement officers executed the search in good-faith reliance on the magistrate judge’s decision to issue the warrant. The case was remanded for further proceedings. View "United States v. Silva" on Justia Law

N.G.B., on behalf of her child J.B., filed a due process complaint against the New York City Department of Education (DOE) alleging that DOE failed to provide J.B. with a free appropriate public education (FAPE) for the 2019-2020 school year. An impartial hearing officer ruled in favor of N.G.B. Subsequently, N.G.B. sought attorneys' fees under the Individuals with Disabilities Education Act (IDEA). The district court found the claimed hourly rates and hours expended by N.G.B.'s counsel to be unreasonable and adjusted them. However, it also found that N.G.B. was substantially justified in rejecting a settlement offer from DOE, allowing her to recover fees and costs incurred post-rejection.The United States District Court for the Southern District of New York granted in part and denied in part N.G.B.'s motion for summary judgment. The court reduced the claimed hourly rates and hours but found that DOE's settlement offer did not account for significant work performed by N.G.B.'s counsel. The court concluded that N.G.B. was substantially justified in rejecting the offer, as it was based on outdated billing records and did not reflect the actual work done.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's judgment, holding that the district court applied the correct standard in determining substantial justification. The appellate court agreed that a prevailing parent under the IDEA can be substantially justified in rejecting a settlement offer if they have a good-faith, reasonable belief that the offer does not adequately compensate for the work performed. The court found no abuse of discretion in the district court's findings and reasoning, concluding that the rejection of DOE's offer was substantially justified. View "N.G.B. v. New York City Department of Education" on Justia Law

A wholesale food supplier, Vista Food Exchange, Inc. ("Vista"), sued Comercial De Alimentos Sanchez S De R L De C.V. ("Sanchez") for breach of contract, alleging that Sanchez failed to pay for over $750,000 worth of meat products. Vista claimed that Sanchez was required to make payments to Vista's headquarters in New York, but Sanchez contended it had paid the invoices in cash to Vista's salesman, Eduardo Andujo Rascón, in Tijuana, Mexico. Sanchez supported its claim with declarations and documents, including an affidavit from Rascón stating he received the cash payments.The United States District Court for the Southern District of New York granted summary judgment in favor of Sanchez, dismissing Vista's breach-of-contract claim. The court found that Sanchez provided unrefuted evidence of cash payments to Rascón, fulfilling its contractual obligations. It also ruled that even if paying Rascón in cash breached the contract, Vista could not show that its damages were proximately caused by the breach because Rascón's theft of the money was unforeseeable. The court dismissed Vista's other claims for breach of implied contract, promissory estoppel, and unjust enrichment, citing New York law that forecloses such claims when an enforceable contract exists.On appeal, the United States Court of Appeals for the Second Circuit found that genuine disputes of material fact existed regarding Sanchez's claimed performance, the modification of the contract, and the foreseeability of damages. The appellate court vacated the district court's judgment dismissing Vista's claims for breach of contract and unjust enrichment and remanded the case for trial on those claims. The appellate court affirmed the dismissal of Vista's claims for implied contract and promissory estoppel. View "Vista Food Exchange, Inc. v. Comercial de Alimentos Sanchez" on Justia Law