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

The case revolves around Anthony Pica, who was convicted of conspiracy to commit robbery and attempted robbery. Pica, along with Salvatore Maniscalco, Jr., and John Delutro, planned to rob Louis Antonelli, a jeweler. They recruited Christopher Prince and Charles Santiago for the robbery. Despite Pica's instruction that Antonelli was not to be harmed, Santiago shot Antonelli twice during the robbery attempt, leading to Antonelli's death.Pica was initially sentenced to 360 months' imprisonment by the United States District Court for the Eastern District of New York. The court applied U.S.S.G. § 2A1.1, the Sentencing Guideline for first-degree murder, in sentencing him. Pica appealed, arguing that the district court should have sentenced him under U.S.S.G. § 2B3.1, the guideline for robbery. His appeal was unsuccessful.Later, Pica filed a petition to vacate his convictions based on new precedent from the United States Supreme Court. The district court granted his petition, vacating his convictions for using and carrying a firearm during and in relation to a crime of violence, and causing the death of another during the commission of a violation. The court ordered a resentencing hearing.At the resentencing hearing, the district court again applied U.S.S.G. § 2A1.1, sentencing Pica to 264 months' imprisonment. Pica appealed again, arguing that Antonelli's murder was not relevant conduct under U.S.S.G. § 1B1.3(a)(1)(B) and that the district court should not have applied U.S.S.G. § 2A1.1.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that Antonelli's murder was within the scope of Pica's jointly undertaken criminal activity and was reasonably foreseeable. Therefore, the district court correctly applied U.S.S.G. § 2A1.1 in sentencing Pica. View "United States v. Pica" on Justia Law

The case revolves around Brad Packer, a shareholder of 1-800-Flowers.com, Inc. (FLWS), who alleged that Raging Capital Management, LLC, Raging Capital Master Fund, Ltd., and William C. Martin (collectively, the Appellees) violated Section 16(b) of the Securities Exchange Act of 1934. This section requires owners of more than 10% of a company's stock to disgorge profits made from buying and selling the company's stock within a six-month window. Packer claimed that the Appellees, as 10% beneficial owners of FLWS, engaged in such "short-swing" trading and failed to disgorge their profits. After FLWS declined to sue the Appellees, Packer filed a shareholder derivative suit on behalf of FLWS.The United States District Court for the Eastern District of New York dismissed Packer's suit, reasoning that he lacked constitutional standing because he did not allege a concrete injury. The District Court concluded that the Supreme Court's decision in TransUnion LLC v. Ramirez, which elaborated on the "concrete injury" requirement of constitutional standing, abrogated the Second Circuit's previous decision in Donoghue v. Bulldog Investors General Partnership. In Donoghue, the Second Circuit held that a violation of Section 16(b) inflicts an injury that confers constitutional standing.The United States Court of Appeals for the Second Circuit disagreed with the District Court's interpretation. The Appeals Court held that TransUnion did not abrogate Donoghue, and the District Court erred in holding that it did. The Appeals Court emphasized that a District Court must follow controlling precedent, even if it believes that the precedent may eventually be overturned. The Appeals Court found that nothing in TransUnion undermines Donoghue, and thus, the District Court erred in dismissing Packer's Section 16(b) suit. The Appeals Court reversed the District Court's judgment and remanded the case for further proceedings. View "Packer v. Raging Capital Management, LLC" on Justia Law

The case revolves around Windstream Holdings, Inc. ("Windstream"), a telecommunications provider that filed for Chapter 11 reorganization. During Windstream's bankruptcy, Charter Communications Inc. and Charter Communications Operating, LLC (collectively, "Charter"), a competitor, launched an advertising campaign targeting Windstream's customers. Windstream alleged that Charter's advertising campaign was an attempt to exercise control over Windstream's customer contracts and goodwill, thereby violating the automatic stay provision of the Bankruptcy Code.The United States Bankruptcy Court for the Southern District of New York agreed with Windstream, holding Charter in civil contempt for its actions and imposing sanctions against Charter. However, the United States District Court for the Southern District of New York reversed the bankruptcy court's decision, finding that a fair ground of doubt existed as to whether Charter violated the automatic stay.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court found that while Windstream's customer contracts and goodwill were property of the estate, Charter's advertising campaign did not exercise control over those assets. The court concluded that there was a fair ground of doubt as to whether Charter's actions violated the automatic stay, and therefore, the district court did not err by refraining from holding Charter in civil contempt. View "In re: Windstream Holdings, Inc." on Justia Law

Joseph McGrain was sentenced to 264 months in prison for sexually abusing his then-girlfriend’s fourteen-year-old daughter and obstructing the investigation into the abuse. The district court applied a two-offense-level enhancement under section 2G2.1(b)(5) of the Sentencing Guidelines because the victim was in McGrain’s “custody, care, or supervisory control” when he abused her. The court also denied McGrain an offense-level reduction for acceptance of responsibility because he merited an enhancement for obstruction of justice and continued to deny his sexual relationship with the victim and that he convinced her to send him sexually explicit images.McGrain appealed the district court's decisions, arguing that each was reversible error and that his sentence should be vacated. He also requested that his case be assigned to a different judge on remand.The United States Court of Appeals for the Second Circuit affirmed the judgment of the district court. The court rejected McGrain's arguments, stating that the "custody, care, or supervisory control" enhancement was correctly applied given McGrain's relationship with the victim. The court also affirmed the district court's denial of a reduction for acceptance of responsibility, stating that McGrain had not demonstrated acceptance of responsibility for his actions. Finally, the court found no error in the district court's determination that McGrain was dangerous, which factored into his sentencing. View "United States v. McGrain" on Justia Law

The case involves defendants Dennis A. Bradley, Jr., and Jessica Martinez, who were charged with wire fraud and conspiracy to commit wire fraud in relation to Bradley’s 2018 campaign for Connecticut state senator. The government obtained two videos from videographers hired by Bradley, one 13-minute video and a 28-minute video, both of which were recorded at an event where Bradley announced his campaign. The government only became aware of the existence of the 28-minute video a week before the trial and promptly provided it to the defendants. Bradley moved to preclude the 28-minute video, arguing that the government had violated Rule 16(a)(1)(E) by not obtaining and producing the video earlier.The United States District Court for the District of Connecticut granted Bradley's motion, ruling that the government had violated its disclosure obligations by not obtaining and producing the 28-minute video at an earlier date. The government appealed this decision, arguing that it did not have the video in its possession, custody, or control until the eve of the trial.The United States Court of Appeals for the Second Circuit reversed the district court's order. The court held that neither Rule 16(a)(1)(E) nor the Connecticut District Court’s Standing Order imposed a requirement on the government to discover and turn over to a criminal defendant evidence that the government did not have in its physical possession, custody, or control, or that it did not have a duty to obtain from a third party. The case was remanded for further proceedings consistent with this opinion. View "United States v. Bradley" on Justia Law

Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law

The case involves Amazon.com Services LLC and the National Labor Relations Board (NLRB). The NLRB alleged that Amazon committed an unfair labor practice by discharging an employee for engaging in protected concerted activity. While the charge was pending before the Board, the Board sought temporary injunctive relief, including the employee’s reinstatement. The district court found "reasonable cause" to believe Amazon committed an unfair labor practice in terminating the employee. However, it concluded that ordering Amazon to cease and desist from committing certain violations of the Act was "just and proper," but that ordering Amazon to reinstate the employee was not.The district court's decision was appealed to the United States Court of Appeals for the Second Circuit. The appellate court found that the district court did not adequately explain why the cease-and-desist order was just and proper, particularly in light of its conclusion that the employee’s reinstatement was not. Therefore, the injunction was vacated in part. The court noted that the district court's lack of explanation for granting the cease-and-desist order, coupled with its explicit, undisputed findings in rejecting the request to order the employee's reinstatement, cast serious doubt on the propriety of the cease-and-desist order. View "Poor v. Amazon.com Services LLC" on Justia Law

The case involves the United States government's appeal against a decision by the United States District Court for the Southern District of New York. The lower court had granted federal prisoner Joe Fernandez's motion for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A), reducing his sentence to time served and ordering his release. The court based its decision on two grounds: Fernandez's possible innocence due to the questionable credibility of the government's key witness, and the fact that Fernandez received a far longer sentence than his co-defendants.The government argued on appeal that the district court had abused its discretion. It contended that potential innocence is never a permissible "extraordinary and compelling reason" for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A), and that Fernandez's sentencing disparity is not an "extraordinary and compelling reason" for a sentence reduction in this case.The United States Court of Appeals for the Second Circuit agreed with the government's arguments. It held that a compassionate release motion is not the proper vehicle for litigating the issues Fernandez raised, irrespective of whether his mandatory life sentence is unjust. The court reversed the judgment of the district court. View "United States v. Fernandez" on Justia Law

The case involves Travis Woods, a wheelchair user, who sued the Central New York Regional Transportation Authority and its subsidiary Centro of Oneida, Inc. (collectively, "Centro"), which operate the public bus service in Oneida County. Woods claimed that Centro violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act by failing to provide wheelchair-accessible bus stops. He argued that the district court erred in granting summary judgment to Centro on his claims.The United States District Court for the Northern District of New York granted summary judgment to Centro, dismissing Woods's complaint. The court found that Centro's paratransit service and its flexible pick-up and drop-off policy were reasonable accommodations providing meaningful access to Centro’s bus service.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court found that Woods's claims under sections 12147 and 12148 of the ADA failed as a matter of law. The court concluded that Woods had not shown that the altered portions of Centro’s bus stops were inaccessible or that Centro’s bus service was not readily accessible to individuals with disabilities. The court also found that Woods had not established that any modifications to Centro’s policies, practices, or procedures were necessary to avoid discrimination or to provide program access. Therefore, the court affirmed the judgment of the district court. View "Woods v. Centro of Oneida, Inc." on Justia Law

Link Motion Inc., a Chinese company incorporated in the Cayman Islands, filed a legal malpractice action against the law firm DLA Piper LLP (US) and one of its attorneys in the New York State Supreme Court. The case was related to a previous lawsuit filed by a shareholder of Link Motion, Wayne Baliga, in which DLA Piper represented Link Motion. The law firm removed the case to the United States District Court for the Southern District of New York, which dismissed Link Motion's complaint as time-barred and denied its motion to remand the case back to state court.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court lacked federal jurisdiction. The court found that the federal law standing question identified by the district court as embedded in Link Motion's malpractice claim did not fall within the narrow category of "disputed and substantial" questions of federal law permitting the exercise of federal jurisdiction over a state law claim. Therefore, the court vacated the district court's decision and remanded the case back to the state court. View "Link Motion Inc. v. DLA Piper LLP" on Justia Law