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

The plaintiffs challenged two provisions of New York’s Concealed Carry Improvement Act (CCIA): one that criminalizes carrying firearms on private property open to the public unless the owner has explicitly permitted it (the Private Property Provision), and another that prohibits firearm possession in “sensitive locations,” specifically public parks (the Public Parks Provision). Plaintiffs argued that these provisions violate the Second and Fourteenth Amendments. The Private Property Provision was challenged as applied to places open to the public, while the Public Parks Provision was subject to a facial challenge, with plaintiffs later attempting, unsuccessfully, to add an as-applied challenge concerning rural parks.The United States District Court for the Western District of New York permanently enjoined the State from enforcing the Private Property Provision as applied to private property open to the public, finding it unconstitutional because it was not consistent with the nation’s historical tradition of firearms regulation. The district court, however, granted summary judgment to the State on the Public Parks Provision, concluding that it was facially constitutional since historical analogues supported restrictions on firearms in public parks. The district court declined to consider plaintiffs’ as-applied challenge to the parks provision, ruling that this argument had not been properly raised.The United States Court of Appeals for the Second Circuit reviewed both appeals. It affirmed the permanent injunction against the Private Property Provision, holding that the State failed to show that the restriction is consistent with the historical tradition of regulating firearms, as required by New York State Rifle & Pistol Association, Inc. v. Bruen. The court also affirmed the judgment in favor of the State on the Public Parks Provision, finding it constitutional as applied to urban parks, and declined to consider the as-applied challenge regarding rural parks since it had not been raised below. View "Christian v. James" on Justia Law

Union Plaintiffs, comprised of two labor organizations, challenged the federal government's termination of approximately $400 million in funding to Columbia University and its demand for significant reforms at the institution. Columbia University was not a party in the lawsuit. The plaintiffs sought injunctive relief to restore funding, prevent enforcement of the government’s reform demands, protect future grants and contracts, and recover damages.The United States District Court for the Southern District of New York denied the plaintiffs’ motion for a preliminary injunction and dismissed the case for lack of standing. After this dismissal, the plaintiffs appealed to the United States Court of Appeals for the Second Circuit. While the appeal was pending, Columbia and the government reached an agreement whereby most of the disputed funding was restored and Columbia agreed to implement certain reforms. Following this, the plaintiffs withdrew their requests for prospective equitable relief and damages, citing changed circumstances.The United States Court of Appeals for the Second Circuit reviewed a joint motion from both parties to dismiss the appeal, vacate the district court’s order, and remand with instructions to dismiss the case as moot. The court held that the case was moot for reasons not fairly attributable to the plaintiffs and granted the joint motion in full. The court dismissed the appeal as moot, vacated the district court’s order, and remanded with instructions to dismiss the case as moot, emphasizing that vacatur was appropriate due to circumstances beyond the plaintiffs’ control and the agreement between the parties. View "Am. Ass'n of Univ. Professors v. Department of Justice" on Justia Law

A Puerto Rican international banking entity, which operated under an offshore charter and was regulated by Puerto Rico’s Office of the Commissioner of Financial Institutions, maintained a master account with the Federal Reserve Bank of New York. In 2019, following a federal investigation into potential anti-money laundering violations involving a Venezuelan client, the entity’s offices were raided and its account was temporarily suspended. After the investigation concluded with a fine and compliance improvements, the account was restored under stricter risk-mitigation terms. However, in 2022 and 2023, the Federal Reserve Bank determined the entity had not met required compliance standards and ultimately terminated the master account, citing serious risk concerns related to money laundering and deficiencies in compliance programs.The entity sued in the United States District Court for the Southern District of New York, seeking to compel reinstatement of its account and damages. It claimed a statutory entitlement to a master account under the Federal Reserve Act, as amended by the Monetary Control Act, and brought claims under the Administrative Procedure Act, Mandamus Act, Declaratory Judgment Act, the Fifth Amendment, and New York contract law, among others. The district court denied preliminary relief and dismissed all claims, holding that the relevant statutes did not create a nondiscretionary entitlement to a master account and finding failures in both standing and the plausibility of the claims.The United States Court of Appeals for the Second Circuit affirmed. It held that the Federal Reserve Act does not grant depository institutions a statutory or nondiscretionary right to a master account; instead, regional Reserve Banks retain discretion over account access. The court further found that the plaintiff lacked standing to sue the Federal Reserve Board of Governors, failed to plausibly allege contract or constitutional claims, and that amendment of the complaint would be futile. The district court’s judgment was affirmed in all respects. View "Banco San Juan Internacional, Inc. v. Fed. Rsrv. Bank of N.Y., Bd. of Governors of the Fed. Rsrv." on Justia Law

A junior mortgage holder sought to quiet title against a senior mortgage on a Brooklyn property, arguing that the senior mortgage had become unenforceable under New York’s six-year statute of limitations. The senior mortgage had been accelerated by the filing of a foreclosure action in 2007, which was later discontinued without prejudice. The junior mortgage was subsequently assigned to the plaintiff, who argued that the limitations period had expired, thus barring any further foreclosure by the senior lienholder. The validity of the original 2007 foreclosure action, specifically whether it properly accelerated the debt, was disputed.The United States District Court for the Eastern District of New York denied both parties’ motions for summary judgment, citing a disputed issue of material fact regarding the standing of the entity that initiated the 2007 foreclosure. Shortly after this ruling, New York enacted the Foreclosure Abuse Prevention Act (FAPA), which, among other provisions, bars the defense that a prior acceleration was invalid in quiet title actions unless a court previously expressly determined invalidity. The district court, upon reconsideration, held FAPA applied retroactively and did not violate constitutional due process protections, and granted summary judgment to the junior mortgage holder.On appeal, the United States Court of Appeals for the Second Circuit certified questions to the New York Court of Appeals, which held that FAPA applies retroactively and that such application does not violate the New York Constitution’s due process guarantees. The Second Circuit then addressed whether retroactive application of FAPA violates substantive or procedural due process, the Contracts Clause, or the Takings Clause under the U.S. Constitution. The Second Circuit held that FAPA’s retroactive application does not violate any of these federal constitutional provisions and affirmed the district court’s judgment. View "Article 13 LLC v. LaSalle NationalBank Ass'n" on Justia Law

Federal authorities investigated a man after discovering that his co-defendant, who had been involved in two separate shooting incidents, had purchased a firearm for him. The defendant was charged with illegal receipt of a trafficked firearm based on this transaction. He pleaded guilty to that charge and was released pending sentencing, but while on bail, he was alleged to have participated in an assault and attempted robbery at a gas station, leading to the revocation of his bail.The United States District Court for the District of Connecticut held a sentencing hearing, during which it imposed a sentence of 30 months’ imprisonment—substantially above the advisory Sentencing Guidelines range of 12 to 18 months. The district court based its decision in part on the defendant’s alleged uncharged conduct while on bail and on the violent conduct of the co-defendant, specifically the two shootings. The district court reasoned that these incidents provided relevant context for the nature and circumstances of the defendant’s offense, even though there was no evidence that the defendant participated in or was aware of the co-defendant’s shootings, and no finding was made regarding the reliability or proof of the uncharged conduct by the defendant.On appeal, the United States Court of Appeals for the Second Circuit held that the district court plainly erred by considering the co-defendant’s prior violent activities in sentencing the defendant. The Second Circuit found there was no basis to attribute the co-defendant’s shootings to the defendant under any sentencing factor, as they were not part of a joint undertaking or conspiracy and were not shown to be relevant to the defendant’s conduct. The court vacated the sentence and remanded for a full resentencing, instructing the district court not to consider the co-defendant’s unrelated violent acts and clarifying the process for addressing any alleged uncharged conduct by the defendant. View "United States v. Dralle" on Justia Law

The case involves an individual who, in January 2020, sold fentanyl-laced heroin to an undercover police detective using his phone to arrange the sales. That same month, he shot someone in the knee and, after his arrest, was found with crack cocaine, heroin, and marijuana. He was indicted on five counts, including possession of ammunition after a felony conviction and drug-related offenses. He ultimately pled guilty to the ammunition charge under a plea agreement that included an express waiver of appeal for sentences within a specified range.The United States District Court for the Southern District of New York sentenced him to 105 months’ imprisonment and three years of supervised release, imposing several special conditions. Three of those conditions—electronic device searches upon reasonable suspicion, mandatory community service when unemployed, and participation in an outpatient mental health counseling program—were challenged by the defendant. In a prior appeal, the United States Court of Appeals for the Second Circuit vacated these three conditions due to insufficient explanation and remanded for further proceedings. On remand, the District Court elaborated on the reasons for imposing the conditions and reimposed them with some modifications.In the current appeal, the United States Court of Appeals for the Second Circuit reviewed the procedural and substantive reasonableness of these special conditions. The court held that the District Court did not abuse its discretion when imposing the challenged conditions, as they were sufficiently individualized and reasonably related to the relevant sentencing factors. The court also held that the defendant’s challenge to his term of imprisonment was barred by the appeal waiver in the plea agreement. Accordingly, the Second Circuit affirmed the judgment of the District Court. View "United States v. Jimenez" on Justia Law

The case involves an altercation in the lobby of an apartment building, where Darryl Brown, an off-duty corrections officer, shot and killed Vonde Cabbagestalk, his daughter’s boyfriend. During a heated argument, Brown drew his firearm. Witness testimony established that Cabbagestalk became physically aggressive and swung at Brown, after which Brown pulled out his gun and held it at his waist. Cabbagestalk made a threatening remark and attempted to swipe at the gun, at which point Brown fired, resulting in Cabbagestalk’s death.Brown was tried in the New York Supreme Court, Bronx County, and convicted of first-degree manslaughter. The trial judge declined to instruct the jury on the justification (self-defense) defense, finding the evidence insufficient to warrant the charge. On direct appeal, a divided Appellate Division, First Department, vacated the conviction, reasoning that the evidence could support Brown’s belief that he needed to use deadly force. However, the New York Court of Appeals unanimously reversed and reinstated the conviction, holding that Brown’s act of drawing his gun made him the initial aggressor under New York law, disqualifying him from the justification defense. The court found no evidence that Brown withdrew from the encounter or that Cabbagestalk threatened deadly force before Brown drew his weapon.Brown sought federal habeas relief in the United States District Court for the Southern District of New York, arguing that denial of a justification instruction violated his federal due process rights. The district court denied relief, agreeing with the New York Court of Appeals. The United States Court of Appeals for the Second Circuit affirmed, holding that Brown was not entitled to a justification instruction under New York law and, consequently, there was no constitutional violation justifying habeas relief. View "Brown v. James" on Justia Law

A dispute arose between a commercial landlord and tenant after government emergency orders during the COVID-19 pandemic required non-essential businesses in New York City to close. The tenant, operating a retail clothing store in Manhattan, stopped paying rent, arguing that the lease excused rent payments when government actions prevented it from operating its business. The landlord disagreed, terminated the lease for nonpayment, and sought damages for breach of contract. The tenant vacated the premises and counterclaimed, alleging the landlord wrongfully terminated the lease and wrongfully kept two payments made after termination.The United States District Court for the Southern District of New York granted summary judgment in favor of the landlord, finding that the government’s orders did not constitute a “taking” under the lease because the tenant was not fully deprived of the use or occupancy of the premises. The district court also rejected the tenant’s counterclaims for breach of contract and unjust enrichment, holding that the notice-and-cure provision applied and that the unjust enrichment claim was duplicative. The court awarded damages to the landlord, though the landlord cross-appealed, asserting the award was insufficient.The United States Court of Appeals for the Second Circuit reviewed the case. It held that the district court misinterpreted the lease’s takings provision, which excused the tenant from paying rent when it was unable to operate its business due to government orders. The appellate court reversed the summary judgment for the landlord on its breach of contract claim and concluded the tenant was entitled to summary judgment on both its own breach of contract counterclaim and its claim that the landlord improperly terminated the lease. The court further vacated the judgment on the unjust enrichment counterclaim and remanded for further proceedings. The landlord’s cross-appeal on damages was dismissed as moot. View "Delshah 60 Ninth, LLC v. Free People of PA LLC" on Justia Law

A group of branded gasoline retailers, known as the Old Jericho Plaintiffs, operated gas stations and accepted Visa and Mastercard payment cards during a specified period. Following a long-running federal antitrust class action alleging that Visa and Mastercard imposed unlawfully high interchange fees, a $5.6 billion settlement was reached in 2019 with a class defined as all entities accepting Visa- or Mastercard-branded cards in the United States from January 1, 2004, to January 24, 2019. The Old Jericho Plaintiffs did not opt out of this settlement. However, after the opt-out period ended, they filed a separate class action asserting state-law antitrust claims for damages based on the same alleged conduct, contending that their suppliers were the direct payors of the fees and thus should be the proper class members.The United States District Court for the Eastern District of New York determined that the Old Jericho Plaintiffs were members of the original settlement class and that the settlement agreement barred their new claims. The district court found the term “accepted” in the settlement ambiguous but, after reviewing extrinsic evidence—such as contracts and how transactions were conducted—concluded that the retailers themselves, not their suppliers, “accepted” payment cards within the meaning of the agreement.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that its prior decision in Fikes Wholesale, Inc. v. HSBC Bank USA, N.A. did not require class membership to be determined solely by identifying the “direct payor.” The court found no clear error in the district court’s factual determination that the Old Jericho Plaintiffs were intended to be class members. Additionally, it held that the claims brought by these plaintiffs were validly released in the settlement because they rested on the same factual predicate as the released claims and the plaintiffs had been adequately represented. View "In Re: Payment Card Interchange Fee and Merchant Discount Antitrust Litigation" on Justia Law

Two Vermont residents who worked as delivery drivers for a baked goods company sued the company, alleging violations of the Fair Labor Standards Act (FLSA) because they were not paid overtime despite regularly working more than 40 hours per week. The company classified them as independent contractors, not employees, and both the drivers and the company are located in different states: the drivers in Vermont, and the company is incorporated in Delaware with its principal place of business in Pennsylvania. The drivers brought the lawsuit in the United States District Court for the District of Vermont, both on their own behalf and on behalf of other similarly situated delivery drivers.After the case was filed, the plaintiffs asked the district court to allow notification of potential collective action members not just in Vermont, but also in Connecticut and New York. The company objected, arguing that the district court did not have personal jurisdiction over claims by out-of-state drivers. The district court disagreed, concluding that it did have personal jurisdiction over the company regarding claims by non-Vermont drivers, and permitted notification to potential plaintiffs in all three states. The district court then certified the personal jurisdiction issue for interlocutory appeal and stayed its decision.The United States Court of Appeals for the Second Circuit reviewed the case and disagreed with the district court. The appellate court held that, unless Congress has provided otherwise (which it has not in the FLSA), a federal district court’s personal jurisdiction over a defendant for out-of-state plaintiffs’ claims is limited by the same rules that bind state courts. Because there was no showing that the claims by Connecticut and New York drivers arose out of the company's contacts with Vermont, the district court lacked personal jurisdiction over those claims. The Second Circuit reversed the district court’s ruling and remanded the case for further proceedings. View "Provencher v. Bimbo Foods Bakeries Distribution LLC" on Justia Law