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

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

Plaintiffs Moses Lugo and Cheryl Seaton, who use motorized wheelchairs, sued the City of Troy, New York, under the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973 (RA). They alleged that the city failed to maintain accessible pedestrian pathways. After discovery, Plaintiffs moved for summary judgment, while the City of Troy moved to dismiss the complaint for lack of standing or, alternatively, for summary judgment. The district court dismissed the complaint, finding the factual allegations insufficient to establish standing, without considering the full summary-judgment record.The United States District Court for the Northern District of New York dismissed the complaint based on the pleadings, concluding that the allegations were too generic to establish standing for city-wide remedies and that the specific obstacles mentioned had been remedied, thus mooting those claims. The court did not evaluate whether the evidence from discovery could establish standing.The United States Court of Appeals for the Second Circuit reviewed the case. The appellate court found that the district court erred by resolving the standing issue based solely on the pleadings rather than the full summary-judgment record. The appellate court held that the district court should have considered the evidence developed during discovery to determine whether Plaintiffs had standing. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings, instructing the lower court to evaluate the standing issue based on the complete evidentiary record and to determine if summary judgment is warranted or if Plaintiffs should be allowed to amend their complaint. View "Lugo v. The City of Troy, New York" on Justia Law

Samuel Boima, a native of Sierra Leone, was charged with assaulting federal officers at the Buffalo Federal Detention Facility while awaiting deportation. The incident involved Boima spitting a mixture of saliva and blood on the officers. Following his arrest, Boima exhibited uncooperative and erratic behavior, leading to a court-ordered psychological evaluation. Dr. Kari Schlessinger diagnosed Boima with a psychotic disorder, concluding he was incompetent to stand trial. Boima was subsequently committed to the Federal Medical Center in Butner, North Carolina, for further evaluation.The United States District Court for the Western District of New York found Boima incompetent to stand trial and ordered his hospitalization. Dr. Kristina P. Lloyd and Dr. Charles Cloutier at FMC Butner diagnosed Boima with schizophrenia and recommended antipsychotic medication to restore his competency. The government moved for a Sell hearing to authorize involuntary medication. The district court granted the motion but did not address whether the government had an important interest in prosecuting Boima, a necessary finding under Sell v. United States.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court's order authorizing forced medication, noting the lower court's failure to consider whether important governmental interests were at stake, as required by Sell. The appellate court remanded the case for further proceedings to determine if the government’s interest in prosecuting Boima justified involuntary medication, considering factors such as the seriousness of the crime, potential civil commitment, and the time Boima had already spent in custody. View "United States v. Boima" on Justia Law

Victor Rivera participated in a robbery crew responsible for over a dozen robberies of jewelers and luxury watch owners between October 2019 and November 2020. The crew identified victims on social media and ambushed them, often at gunpoint. Rivera was arrested and indicted on 18 counts. He pled guilty to one count of participating in a Hobbs Act robbery conspiracy under a plea agreement with a stipulated Guidelines range of 168 to 210 months’ imprisonment.The United States District Court for the Southern District of New York accepted Rivera's plea agreement. However, the Probation Office's Presentence Investigation Report (PSR) revealed additional convictions in Puerto Rico, increasing Rivera's criminal history points from three to ten, placing him in Criminal History Category V. The Government, agreeing with the PSR, advocated for a revised Guidelines range of 235 to 240 months. Rivera's defense argued that the Government should have reviewed his criminal history more thoroughly before the plea agreement. The district court sentenced Rivera to 235 months’ imprisonment.The United States Court of Appeals for the Second Circuit reviewed the case. Rivera argued that the Government breached the plea agreement by advocating for a higher Guidelines range based on information available at the time of the plea and by describing him as a leader in the conspiracy. The court found that the Government breached the plea agreement by relying on Rivera’s Puerto Rico convictions, which were available at the time of the plea. However, this breach did not amount to a "plain" error. The court also found no error in the Government's description of Rivera as a leader, as it was relevant to the sentencing factors. Rivera's procedural and substantive challenges to his sentence were rejected, and his request for resentencing due to a recent amendment to the Sentencing Guidelines was denied. The judgment of the district court was affirmed. View "United States v. Rivera" on Justia Law

In the early 1990s, the Republic of Argentina issued collateralized bonds as part of a sovereign-debt-relief plan. Argentina retained reversionary interests in the collateral, which would revert to Argentina if the bonds were fully paid. However, Argentina defaulted on the bonds in 2001. Two decades later, holders of other defaulted Argentine bonds sought to attach these reversionary interests to satisfy judgments from Argentina’s default. They argued that the reversionary interests were used for commercial activity in the U.S., thus falling under an exception to the Foreign Sovereign Immunities Act (FSIA).The United States District Court for the Southern District of New York granted the attachment of the reversionary interests. During the appeal, the bonds matured, and the district court ordered the turnover of the reversionary interests to the bondholders. Argentina appealed both the attachment and turnover orders, leading to a consolidated appeal.The United States Court of Appeals for the Second Circuit affirmed the district court’s orders. The court held that Argentina’s reversionary interests were not protected by the FSIA because Argentina used them in commercial activity in the U.S. The court also found Argentina’s arguments against the turnover under New York law to be meritless. Additionally, the court ordered the parties to resubmit their briefs and appendices with narrow redactions, as the reasons for sealing the case were no longer compelling. The court denied the motion to supplement the record and granted the motion to limit the scope of sealing. View "Attestor Master Value Fund LP v. Republic of Argentina" on Justia Law

Malcolm H. Wiener, the plaintiff, purchased three life insurance policies from AXA Equitable Life Insurance Company in 1986. Over the years, Wiener's policies lapsed multiple times due to insufficient funds, but he managed to reinstate them each time. In 2013, the policies lapsed again, and AXA terminated them after Wiener failed to make the necessary payments within the grace period. Wiener claimed that AXA and his insurance agent, David Hungerford, caused the lapse by not sending premium notices and by changing the mailing address without his authorization. He also alleged that AXA wrongfully denied his application to reinstate the policies.The United States District Court for the Southern District of New York granted summary judgment in favor of AXA and Hungerford on all claims. The court found that AXA was not obligated to send premium notices after the policies lapsed and that Wiener had waived any objection to the address change by acquiescing for nearly five years. The court also concluded that Hungerford had no duty to notify Wiener of the lapse. Regarding the reinstatement claim, the court ruled that AXA's denial was not arbitrary and capricious, as it was based on Wiener’s low serum albumin levels, which were consistent with AXA’s underwriting guidelines.The United States Court of Appeals for the Second Circuit affirmed the district court’s summary judgment on the termination claims, agreeing that Wiener could not show that AXA’s failure to send premium notices caused the policies to lapse and that he had waived any objection to the address change. However, the appellate court vacated the summary judgment on the reinstatement claim, finding that there were genuine disputes of material fact regarding the actual reasons for AXA’s denial and whether those reasons were arbitrary. The case was remanded for further proceedings on the reinstatement claim. View "Wiener v. AXA Equitable Ins. 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

Michael Grecco Productions, Inc. (MGP) sued Ruthie Allyn Davis and associated entities for copyright infringement, alleging that Davis used Michael Grecco’s copyrighted photos without a license. The United States District Court for the Southern District of New York dismissed MGP’s complaint, reasoning that MGP, being a sophisticated plaintiff in detecting and litigating infringements, should have discovered the alleged infringement within three years of its occurrence. The district court concluded that MGP’s claims were time-barred by the Copyright Act’s three-year limitations provision.The district court’s decision was based on the premise that sophisticated plaintiffs cannot benefit from the discovery rule, which determines when a claim accrues. The court held that MGP’s sophistication in detecting infringements meant it should have discovered the alleged infringement within three years of its occurrence. Consequently, the court dismissed the complaint as time-barred, offering MGP the opportunity to amend the complaint to allege a separately occurring act of infringement within the limitations period, which MGP declined.The United States Court of Appeals for the Second Circuit reviewed the case and disagreed with the district court’s application of the discovery rule. The appellate court held that the discovery rule, not the injury rule, determines when a copyright infringement claim accrues, regardless of the plaintiff’s sophistication. The court emphasized that there is no “sophisticated plaintiff” exception to the discovery rule or to a defendant’s burden to plead and prove a statute-of-limitations defense. The appellate court found that it was not clear from the face of the complaint that MGP’s claims were time-barred and vacated the district court’s dismissal, remanding the case for further proceedings. View "Michael Grecco Prods., Inc. v. RADesign, Inc." on Justia Law

A consumer of a glucosamine-based dietary supplement filed a putative class action lawsuit against the supplement’s manufacturer and retailer under New York law. The plaintiff alleged that the supplement was mislabeled because it contained a different formulation of glucosamine than what was displayed on the front of the label and disclosed as the main ingredient on the side. Specifically, the plaintiff claimed that the product contained blended glucosamine rather than single-crystal glucosamine, which she believed to be more effective for alleviating joint pain.The United States District Court for the Eastern District of New York granted summary judgment for the defendants on federal preemption grounds. The court concluded that the plaintiff’s state law mislabeling claims were preempted by the Food, Drug, and Cosmetic Act (FDCA), which establishes national standards for the labeling of dietary supplements. The district court found that the FDCA’s comprehensive regulatory scheme and its broad preemption clauses foreclosed the plaintiff’s state law claims.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the plaintiff’s state law mislabeling claims were expressly preempted by the FDCA. The court reasoned that the FDCA preempts any state law that imposes labeling requirements not identical to those set forth in the FDCA and its regulations. The court found that the product’s labeling complied with the FDCA’s requirements, as the dietary ingredient “glucosamine sulfate potassium chloride” was identified using methods endorsed by the FDA. Therefore, the plaintiff’s claims were preempted, and the judgment of the district court was affirmed. View "Jackson-Mau v. Walgreen Co." on Justia Law

In June 2020, plaintiffs were arrested for violating a week-long nighttime curfew imposed by New York City in response to violence and destruction during demonstrations protesting George Floyd's death. They claimed the curfew violated their First, Fourth, and Fourteenth Amendment rights, particularly the right to travel.The United States District Court for the Eastern District of New York dismissed the plaintiffs' § 1983 putative class action. The court determined that the curfew had to withstand strict scrutiny but concluded that it did so because it served a compelling governmental interest in curbing escalating crime and restoring public order and was narrowly tailored to that interest.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's dismissal, holding that the curfew satisfied strict scrutiny. The court found that the curfew served a compelling state interest in reducing crime and restoring public order, which was escalating unpredictably across the city. The curfew was narrowly tailored, being limited in duration to one week, applied only during nighttime hours, and included exceptions for essential workers and homeless individuals. The court concluded that the curfew was the least restrictive means available to address the compelling public interest, given the circumstances of escalating violence and destruction. Thus, the plaintiffs' right-to-travel claim was dismissed as a matter of law. View "Jeffery v. City of New York" on Justia Law