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

Plaintiff filed suit alleging claims for forced labor and human trafficking in violation of the Trafficking Victims Protection Act (TVPA) and the Alien Tort Statute (ATS), as well as a claim for unpaid overtime under Article 19 of the New York Labor Law. Plaintiff, a Filipino citizen, lawfully entered the United States as a temporary guest worker. Defendants are Grandeur, a provider of hotel and resort services, and the manager of Grandeur.The Second Circuit vacated the district court's dismissal of plaintiff's TVPA claims for forced labor and human trafficking. The court held that plaintiff has plausibly stated violations of the TVPA where the complaint alleged that the employers recruited plaintiff to work for them, told him to rely on them, represented that they were ensuring that he could remain lawfully in this country, and warned him that they would cancel their sponsorship if he left them or gave them any trouble. View "Adia v. Grandeur Management, Inc." on Justia Law

Plaintiffs filed suit against the State in 1991 on behalf of a statewide class of children with intellectual disabilities for failing to comply with the requirement in the Individuals with Disabilities Education Act (IDEA), that children with disabilities be educated in the "least restrictive environment" that meets their needs. After the parties negotiated a settlement, and near the end of the agreement's term, plaintiffs' counsel moved for additional attorneys' fees.The Second Circuit affirmed the district court's award of attorneys' fees in part, holding that counsel was not barred from further attorneys' fees by the text of the settlement agreement or the definition of "prevailing party" contained in Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health & Human Resources, 532 U.S. 598 (2001). However, the court reversed in part, holding that the district court misapplied the Delaware Valley standard in awarding several categories of work. Accordingly, the court remanded for further proceedings. View "P.J. v. Connecticut State Board of Education" on Justia Law

The Nnebe plaintiffs, taxi drivers, filed a 42 U.S.C. 1983 action alleging that their constitutional rights were violated when their licenses were suspended following their arrests and they were not given meaningful post-suspension hearings to consider whether their licenses should be reinstated.The Second Circuit held that the Taxi and Limousine Commission's suspension procedures did not afford plaintiffs adequate process, because the drivers' property interests in their licenses was substantial, the risk of erroneous deprivation was unacceptably high, and defendants could institute a more meaningful process at minimal financial and administrative costs. Therefore, the court affirmed in part, reversed in part, and remanded.The Stallworth plaintiffs, also taxi drivers, brought a similar action challenging the same regulatory regime. The court held that the district court erroneously dismissed their complaint for failure to state a claim in reliance on its Nnebe ruling. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Nnebe v. Daus" on Justia Law

Respondent appealed the district court's final order granting petitioner's petition under the Hague Convention on the Civil Aspects of International Child Abduction for the return of the parties' minor child. The Second Circuit agreed with the district court's habitual residence determination, but held that the district court erred in granting the petition because the most important protective measures it imposed are unenforceable and not otherwise accompanied by sufficient guarantees of performance. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings concerning the availability of alternative ameliorative measures. View "Saada v. Golan" on Justia Law

Plaintiff filed suit against NYIT, alleging violations of the Americans with Disabilities Act (ADA), Title IX of the Education Amendments of 1972, and New York State Human Rights Law (NYSHRL). Plaintiff alleged that NYIT discriminated against him based on his homosexuality and mental health disability.The Second Circuit affirmed in part, holding that plaintiff's 2010-11 claims were untimely, and the continuing violation doctrine did not apply to these claims. However, the court held that the district court erred in dismissing plaintiff's 2013-14 claims under the ADA and Title IX, because the four month statute of limitations for a New York State Article 78 Proceeding did not apply to these claims. Rather, a three year statute of limitations applied to both claims, and thus his claims were timely. Accordingly, the court vacated in part and remanded. View "Purcell v. N.Y. Institute of Technology - College of Osteopathic Medicine" on Justia Law

The Second Circuit reversed the district court's denial of the City's motion for summary judgment in an action challenging the City's rules banning advertisements in for-hire vehicles (FHVs) absent authorization from the Taxi and Limousine Commission. The district court concluded that the City's rules banning advertisements in for‐hire passenger vehicles, such as Ubers and Lyfts, violate the First Amendment, primarily because the City permits certain advertising in taxicabs.The court held that the City's prohibition on advertising in FHVs did not violate the First Amendment under the Central Hudson test. In this case, the City's asserted interest in improving the overall passenger experience is substantial, the prohibition "directly advances" that interest, and the prohibition was no more extensive than necessary to serve that interest. The court held that the City's determination that banning ads altogether is the most effective approach was reasonable. View "Vugo, Inc. v. City of New York" on Justia Law

The Second Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court held that the police did not violate defendant's Fourth Amendment rights by returning to search his car, because both searches of defendant's car were valid inventory searches; contrary to defendant's argument, the district court did not abuse its discretion in declining to admit his post‐arrest statements denying ownership of the gun; and defendant's arguments regarding the inadmissibility of the evidence of his gang affiliation and willingness to assist the police either (a) failed because the evidence was properly admitted pursuant to Federal Rule of Evidence 404(b) and was not unfairly prejudicial or (b) were waived. View "United States v. Williams" on Justia Law

The Second Circuit affirmed the district court's judgment, holding that when jurisdiction‐granting class‐action allegations are removed from a complaint, a district court is divested of Class Action Fairness Act (CAFA) jurisdiction and the action must be dismissed. In this case, a Connecticut attorney filed suit against a group of title insurance companies for allegedly violating a Connecticut law that allows only Connecticut attorneys to act as title agents in the state. After plaintiffs amended the complaint to remove all class action allegations, the district court concluded that the withdrawal of the class‐action allegations divested it of CAFA jurisdiction and dismissed the amended complaint. View "Gale v. Chicago Title Insurance Co." on Justia Law

Tweed, seeking to expand its primary runway, filed suit to invalidate a Connecticut statute that had limited the runway's length. As a preliminary matter, the Second Circuit held that Tweed had Article III standing because it established an injury in fact, the injury was caused by the Runway Statute, and a favorable decision will likely redress Tweed's fear of the statute's enforcement. The court joined the Fifth and Tenth Circuits in holding that a subdivision may sue its state under the Supremacy Clause. Therefore, Tweed, as a political subdivision of Connecticut, may bring suit against Connecticut.On the merits, the court held that the Runway Statute was preempted by the Federal Aviation Act where the Act's preemption applies to airport runways and the Runway Statute falls within the scope of that preemption. Furthermore, Congress intended the Act to occupy the entire field of air safety including runway length. Accordingly, the court reversed and remanded for entry of judgment in favor of Tweed. View "Tweed-New Haven Airport Authority v. Tong" on Justia Law

The Second Circuit affirmed the district court's decision declining to reconsider its original decision granting the Town's motion to dismiss the amended complaint alleging claims of, inter alia, breach of contract, innocent misrepresentation, and fraud in connection with plaintiff's loan to a licensee of the Town that was allegedly secured by the Town.The court held that PHL's arguments with regard to dismissals of the unjust enrichment and negligent misrepresentation claims were not properly before the court. Even if they were properly before the court, the court would still reject PHL's arguments. The court also held that PHL's amended complaint failed to state a claim on which relief can be granted for breach of contract or equitable relief because it failed to plausibly allege a valid contract; PHL's claims for misrepresentation failed because PHL failed to allege that it reasonably or justifiably relied on the misrepresentation; and there was no merit to PHL's contention that it should have been allowed to file a second amended complaint. View "PHL Variable Insurance Co. v. Town of Oyster Bay" on Justia Law