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

Plaintiff filed a putative class action against defendants and defendants subsequently offered to settle plaintiff's individual claims pursuant to Federal Rule of Civil Procedure 68 for an amount greater than the statutory damages to which plaintiff would have been entitled if successful. Plaintiff refused to accept and defendants filed a motion to dismiss. The district court denied the motion, holding that although plaintiff’s individual claims were rendered moot by the unaccepted Rule 68 offer, his putative class action claims were not. The court held that the district court maintained Article III subject matter jurisdiction over the case because, under the law of the Circuit, an unaccepted Rule 68 offer alone does not render a plaintiff’s individual claims moot before the entry of judgment against the defendants. Therefore, the district court maintained Article III subject matter jurisdiction over the case regardless of plaintiff’s putative class action claims. Accordingly, because it is unnecessary to the disposition of this case, the court did not reach the certified question of whether putative class action claims brought under Rule 23 of the Federal Rules generally provide an independent basis for Article III justiciability. The court affirmed the district court’s decision that it maintained subject matter jurisdiction over the case, albeit on the alternative ground that plaintiff's individual claims were not moot at the time the district court denied the defendants’ motion to dismiss. View "Tanasi v. New Alliance Bank" on Justia Law

Plaintiff filed a putative class action suit against J.C. Christensen, alleging that J.C. Christensen violated the Fair Debt Collections Practices Act (FDCPA), 15 U.S.C. 1692, by offering to settle his debt for less than the full amount without warning him that his total savings might be reduced by an increase in his tax liability. The district court dismissed the suit. The court held that a debt collector need not warn of possible tax consequences when making a settlement offer for less than the full amount owed to comply with the FDCPA. Accordingly, the court affirmed the judgment of the district court. View "Altman v. J.C. Christensen & Assoc." on Justia Law

MetLife appealed the district court's judgment in favor of plaintiff on his claim for pension benefits pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court concluded that MetLife's denial of plaintiff's benefits claim was not arbitrary and capricious where MetLife's rationale for denying plaintiff's claim - that it was impossible to determine whether, or to the extent to which, a FINRA award represented back pay - was not, in fact, unreasonable. The court did not reach MetLife's alternative argument. Accordingly, the court reversed the district court's judgment granting plaintiff relief under ERISA. The court affirmed the denial of plaintiff's request for attorney's fees. View "Roganti v. Metro. Life Ins. Co." on Justia Law

Petitioner sought habeas relief based on the ground that the State denied his constitutional right to a fair trial when it withheld exculpatory evidence in violation of Brady v. Maryland. The district court granted the petition and the court affirmed, concluding that the State violated Brady when it failed to disclose to the defense that a witness had repeatedly denied having any knowledge of the murders and only implicated petitioner after a police detective promised to let him go if he gave a statement in which he admitted to being the getaway driver and incriminated petitioner and another individual. View "Lewis v. Connecticut Comm'r of Corr." on Justia Law

Plaintiff was convicted of rape and murder in 1986 and later acquitted of those charges in 2005. Plaintiff filed suit for, inter alia, due process violations and malicious prosecution under 42 U.S.C. 1983 against the County and NCPD. Plaintiff's claims were tried jointly with two other individuals whose convictions for the rape and murder of the same victim had also been vacated. The jury found in favor of defendants and plaintiff appealed. The district court denied plaintiff's motion for a separate trial on the ground that the statements attributed to the other two plaintiffs were admissible not on the issue of whether the detectives had probable cause to prosecute plaintiff but rather on the lack-of-malice element of plaintiff's malicious prosecution claim. Therefore, the district court's ruling that corroborating statements were made relevant to the malice element of plaintiff's malicious prosecution claim was not error. There was no abuse of discretion in the district court's conclusion that the introduction of statements that were relevant on the issue of malice, and most of which did not explicitly or implicitly mention plaintiff, did not unfairly prejudice him. The court rejected plaintiff's remaining contentions and affirmed the judgment. View "Kogut v. County of Nassau" on Justia Law

Petitioner appealed the denial of his petition for a writ of habeas corpus under 28 U.S.C. 2241, asserting that the BOP incorrectly calculated his ten-year prison sentence. While serving petitioner's state sentence, he was indicted on federal charges and temporarily transferred to federal custody after the issuance of a writ of habeas corpus ad prosequendum. Petitioner argued that the writ was invalid because it required that he be produced in federal court for arraignment on October 10, 2001, and that when he was not so produced, there was no valid writ ad prosequendum that required him to be produced for arraignment at a later date. The court affirmed the judgment of the district court, holding that even if there was a technical deficiency in connection with the execution of the writ of habeas corpus ad prosequendum that was issued, that deficiency did not invalidate the otherwise valid writ. View "Lugo v. Hudson" on Justia Law

USPA appealed from a contempt order finding USPA in violation of a permanent injunction. The district court held that USPA's Double Horsemen Mark on eyewear products was confusingly similar to the logo used by PRL. The district court concluded that the Fragrance Injunction barred use of the Double Horsemen Mark in every market but that for apparel. The court, however, agreed with USPA that the underlying injunction did not enjoin all uses of the mark. Because of the often unpredictable results of market-by-market analysis, a finding that the Double Horsemen Mark is, when used on eyewear, confusingly similar to PRL’s marks, while sufficient to find liability in an infringement proceeding, is not sufficient to support a contempt finding. The fact that the Apparel Litigation does not shield USPA’s use of a Double Horsemen Mark on eyeglasses from an infringement finding does not, without more, render it liable for infringement in that and all other markets save for apparel. Therefore, the court vacated the contempt order and remanded for further proceedings. View "U.S. Polo Ass'n v. PRL USA Holdings" on Justia Law

Petitioner, convicted of producing child pornography and witness tampering, appealed the denial of his petition for writ of habeas corpus under 28 U.S.C. 2255. At issue was the timeliness of the petition under the one‐year statute of limitations of the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), Pub. L. No. 104‐132, 110 Stat. 1214. The court joined eight of its sister circuits and held that the statute of limitations runs from the denial of certiorari, not from the denial of a rehearing of the certiorari petition. In this case, petitioner filed his petition for a writ of habeas corpus more than one year after the Supreme Court denied his petition for a writ of certiorari. Therefore, the petition is untimely and the court affirmed the judgment of the district court. View "Rosa v. United States" on Justia Law

Defendants Calderon, Sanchez, Cardoza, and DeLeon appealed from convictions of racketeering, narcotics, and obstruction-of-justice. Defendants raised numerous issues on appeal. The court addressed only the sufficiency-of-the-evidence issue in regards to Cardoza's conviction for being an accessory after the fact to a murder. The court held that there was insufficient evidence for a reasonable jury to find Cardoza guilty of that charge where, based on the totality of the circumstances, no rational juror could find that Cardoza knew that the murder victim was dead or dying. Accordingly, the court reversed as to Cardoza's conviction and remanded with instructions for the district court to dismiss that count and resentence. The court affirmed on all other counts. View "United States v. Calderon" on Justia Law

Defendant appealed his conviction for conspiracy to distribute cocaine base. The court concluded that the evidence establishes no more than defendant's role as a mere purchaser from the conspiracy and cannot support an inference that he joined it. Therefore, the court did not address defendant's alternative argument for a new trial as to that count based on juror misconduct. The court reversed defendant's conspiracy conviction, vacated the sentence, and remanded for resentencing. View "United States v. Dickerson" on Justia Law