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

Defendant appealed the district court's imposition of an additional four years of supervised release and a special condition that defendant refrain from consuming any alcohol whatsoever while under supervision. The court held that the imposition of the additional four years of supervised release was not substantively unreasonable and defendant's arguments arguing to the contrary lacked merit. The court also held that the district court's imposition of a total ban of the consumption of alcohol was not reasonably related to the nature and circumstances of defendant's offense. Finally, the drug testing special condition was entirely appropriate under the "zero tolerance" policy. View "United States v. Betts" on Justia Law

First degree robbery in violation of Connecticut General Statutes section 53a‐134(a)(4) qualifies as a "violent felony" under the so‐called elements clause of the Armed Career Criminal Act of 1984 (ACCA), 18 U.S.C. 924(e)(2)(B)(i). The Second Circuit affirmed defendant's conviction of unlawful possession of a firearm in violation of 18 U.S.C. 922(g)(1) and of the ACCA, holding that defendant's three prior convictions were for offenses "committed on occasions different from one another" within the meaning of section 924(e)(1). View "United States v. Bordeaux" on Justia Law

The Second Circuit affirmed the district court's judgment in an action brought by parents of a student with an emotional disturbance against the school district. The parents claimed that the school district violated procedural requirements, provided an inadequate individualized education program (IEP) for more than two school years, and offered an inadequate IEP for a third year, which denied the student a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The court agreed with the district court that the school district provided and offered the student a FAPE at all times and that any procedural violations did not entitle the parents to any relief. View "Mr. & Mrs. P. v. West Hartford Board of Education" on Justia Law

The Second Circuit affirmed the district court's judgment in an action brought by parents of a student with an emotional disturbance against the school district. The parents claimed that the school district violated procedural requirements, provided an inadequate individualized education program (IEP) for more than two school years, and offered an inadequate IEP for a third year, which denied the student a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The court agreed with the district court that the school district provided and offered the student a FAPE at all times and that any procedural violations did not entitle the parents to any relief. View "Mr. & Mrs. P. v. West Hartford Board of Education" on Justia Law

The Second Circuit affirmed the district court's dismissal of a putative class action complaint alleging that Abbott violated New York and California statutes and common law by advertising and selling Similac infant formula branded as organic and bearing the "USDA Organic" seal when the formula contained ingredients not permitted by the Organic Foods Production Act (OFPA). The court held that plaintiffs' claims were preempted by federal law and the court need not address Abbott's remaining arguments based on primary jurisdiction, failure to exhaust, or failure to state a claim. The court reasoned that there was no way to rule in plaintiffs' favor without contradicting the certification decision, and thus the certification scheme that Congress enacted in the OFPA. View "Marentette v. Abbott Laboratories" on Justia Law

The Second Circuit affirmed the district court's dismissal of a putative class action complaint alleging that Abbott violated New York and California statutes and common law by advertising and selling Similac infant formula branded as organic and bearing the "USDA Organic" seal when the formula contained ingredients not permitted by the Organic Foods Production Act (OFPA). The court held that plaintiffs' claims were preempted by federal law and the court need not address Abbott's remaining arguments based on primary jurisdiction, failure to exhaust, or failure to state a claim. The court reasoned that there was no way to rule in plaintiffs' favor without contradicting the certification decision, and thus the certification scheme that Congress enacted in the OFPA. View "Marentette v. Abbott Laboratories" on Justia Law

The Second Circuit granted a petition for review of the ARB's final order affirming the ALJ's decision that Intervenor Anthony Santiago was entitled to relief under section 20109(c)(1) of the Federal Railroad Safety Act, 49 U.S.C. 20101 et seq. The court held that the ALJ's determination that Metro‐North had denied, delayed, or interfered with intervenor's medical treatment for a back injury he suffered during the course of his employment was not supported by substantial evidence. In this case, the record considered as a whole was inadequate to support the finding that Metro-North exerted so much influence over OHS that the OHS determination was not truly independent, such that Metro-North could be blamed for the delay in intervenor's medical treatment. Therefore, the court vacated the ARB's order and remanded for further proceedings. View "Metro-North Commuter Railroad Co. v. U.S. Department of Labor" on Justia Law

The Second Circuit granted a petition for review of the ARB's final order affirming the ALJ's decision that Intervenor Anthony Santiago was entitled to relief under section 20109(c)(1) of the Federal Railroad Safety Act, 49 U.S.C. 20101 et seq. The court held that the ALJ's determination that Metro‐North had denied, delayed, or interfered with intervenor's medical treatment for a back injury he suffered during the course of his employment was not supported by substantial evidence. In this case, the record considered as a whole was inadequate to support the finding that Metro-North exerted so much influence over OHS that the OHS determination was not truly independent, such that Metro-North could be blamed for the delay in intervenor's medical treatment. Therefore, the court vacated the ARB's order and remanded for further proceedings. View "Metro-North Commuter Railroad Co. v. U.S. Department of Labor" on Justia Law

The Second Circuit appealed the district court's dismissal of Great Minds' copyright infringement action against FedEx. The court found that Great Minds' license did not explicitly address whether licensees may engage third parties to assist them in exercising their own noncommercial use rights under the license. The court held that, in view of the absence of any clear license language to the contrary, licensees may use third‐party agents such as commercial reproduction services in furtherance of their own permitted noncommercial uses. In this case, because FedEx acted as the mere agent of licensee school districts when it reproduced Great Minds' materials, and because there was no dispute that the school districts themselves sought to use Great Minds' materials for permissible purposes, FedEx's activities did not breach the license or violate Great Minds' copyright. View "Great Minds v. FedEx Office & Print Services, Inc." on Justia Law

The Second Circuit vacated the district court's denial of plaintiff's request for a jury instruction concerning punitive damages for pregnancy discrimination claims arising under the New York City Human Rights Law (NYCHRL). The court certified to the New York Court of Appeals the question of the appropriate standard for determining whether a defendant may be liable for damages under the NYCHRL. The Court of Appeals resolved the certified question by holding that the standard for determining damages under the NYCHRL was whether the wrongdoer has engaged in discrimination with willful or wanton negligence, or recklessness, or a conscious disregard of the rights of others or conduct so reckless as to amount to such disregard. In doing so, the Court of Appeals expressly rejected the application of the federal standard for punitive damages. Therefore, after hearing from the Court of Appeals, the court held that the district court erred in applying the test for whether punitive damages are available under substantive federal law. View "Chauca v. Abraham" on Justia Law