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

In 2014, Ed Sheeran and Amy Wadge wrote the song "Thinking Out Loud," which became a global hit. Structured Asset Sales, LLC (SAS), which owns a portion of the royalties for Marvin Gaye's 1973 song "Let’s Get It On," alleged that Sheeran's song infringed on the copyright of Gaye's song. SAS claimed that the chord progression and syncopated harmonic rhythm in "Thinking Out Loud" were copied from "Let’s Get It On."The United States District Court for the Southern District of New York initially denied Sheeran's motion for summary judgment but later granted it upon reconsideration. The court concluded that the combination of the chord progression and harmonic rhythm in "Let’s Get It On" was too commonplace to warrant copyright protection. The court also excluded evidence and expert testimony related to musical elements not present in the sheet music deposited with the Copyright Office in 1973, which defined the scope of the copyright under the Copyright Act of 1909.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court agreed that the scope of the copyright was limited to the elements in the deposited sheet music and that the combination of the chord progression and harmonic rhythm was not original enough to be protectable. The court also found that no reasonable jury could find the two songs substantially similar as a whole, given their different melodies and lyrics. Thus, the court held that Sheeran did not infringe on the copyright of "Let’s Get It On" and affirmed the summary judgment in favor of Sheeran. View "Structured Asset Sales, LLC v. Sheeran" on Justia Law

Justine Ferreira sought reimbursement from the New York City Department of Education (DOE) for her disabled son's private education during the 2019-2020 school year, claiming the DOE failed to provide a free appropriate public education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA). The DOE had developed an individualized education plan (IEP) for her son, but Ferreira disagreed with it and enrolled him in a private school, iBrain. She alleged that the DOE's proposed public school placement was inadequate.The Impartial Hearing Officer (IHO) and the State Review Officer (SRO) both found that Ferreira's conduct impeded the DOE's efforts to develop a suitable IEP, as she failed to cooperate and provide necessary information. They concluded that the balance of equities did not favor reimbursement. The United States District Court for the Southern District of New York (Judge Torres) granted summary judgment in favor of the DOE, agreeing with the IHO and SRO that Ferreira's actions frustrated the DOE's attempts to fulfill its obligations under the IDEA.On appeal, the United States Court of Appeals for the Second Circuit held that a district court must independently evaluate the equities in IDEA reimbursement cases without deferring to the state administrative agency's conclusions. However, the court found that the district court had indeed conducted an independent review and did not abuse its discretion in denying reimbursement. The court affirmed the district court's judgment, concluding that Ferreira's lack of cooperation and obstruction justified the denial of reimbursement for her son's private school tuition. View "Ferreira v. Aviles-Ramos" on Justia Law

The case involves Ryan M. Maher, who was convicted in the United States District Court for the Northern District of New York for receiving and possessing child pornography. Maher uploaded a digital file to his Google email account, which Google identified as containing child pornography based on a hash value match to a previously identified image. Google reported this to the National Center for Missing and Exploited Children (NCMEC), which forwarded the report to the New York State Police. Without obtaining a warrant, a police investigator opened and visually examined the file, confirming it contained child pornography.The district court denied Maher's motion to suppress the evidence obtained from the warrantless search, relying on the "private search" doctrine. The court held that Google's hash match search was sufficient to justify the police's warrantless visual examination of the file. Alternatively, the court ruled that the good faith exception to the exclusionary rule applied because the police reasonably believed no warrant was required.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed with Maher that the district court erred in applying the private search doctrine. The court held that Google's hash match did not justify the police's warrantless visual examination of the file, as it exceeded the scope of Google's search. However, the court affirmed the conviction based on the good faith exception to the exclusionary rule. The court concluded that at the time of the search, the police had a reasonable basis to believe that no warrant was required, given the existing legal precedents.Thus, the Second Circuit affirmed Maher's conviction, holding that while the warrantless search violated the Fourth Amendment, the good faith exception applied, preventing the suppression of the evidence. View "U.S. v. Maher" on Justia Law

Three practicing Muslim men alleged that federal agents asked them to serve as informants in Muslim communities. When they refused, the agents placed or retained them on the "No Fly List" and suggested they could be removed from the list if they agreed to work as informants. The plaintiffs sought damages under the Religious Freedom Restoration Act (RFRA), claiming that their religious beliefs precluded them from serving as informants and that the agents substantially burdened their exercise of religion by conditioning their removal from the No Fly List on actions that violated those beliefs.The United States District Court for the Southern District of New York dismissed the complaint on qualified immunity grounds, concluding that the agents were entitled to qualified immunity because there was no clearly established right not to be pressured to inform on members of one's religious community through the coercive or retaliatory use of the No Fly List.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court held that the agents were entitled to qualified immunity because a reasonable person in their position would not have understood that their conduct implicated the plaintiffs' religious beliefs. The court noted that the plaintiffs did not disclose their religious objections to the agents, and there were no facts plausibly supporting the conclusion that the agents knew the plaintiffs' objections were grounded in their religious beliefs. Therefore, the agents were entitled to qualified immunity from damages in their personal capacities. View "Tanvir v. Tanzin" on Justia Law

State Farm Mutual Automobile Insurance Company and State Farm Fire and Casualty Insurance Company (collectively, “State Farm”) provide automobile insurance in New York and are required to reimburse individuals injured in automobile accidents for necessary health expenses under New York’s No-Fault Act. State Farm alleges that several health care providers and related entities engaged in a scheme to fraudulently obtain No-Fault benefits by providing unnecessary treatments and services, and then pursued baseless arbitrations and state-court proceedings to seek reimbursement for unpaid bills.The United States District Court for the Eastern District of New York granted State Farm’s motion for a preliminary injunction in part, enjoining the defendants from proceeding with pending arbitrations and from initiating new arbitrations and state-court proceedings, but denied an injunction of the pending state-court proceedings. The district court found that State Farm demonstrated irreparable harm due to the fragmented nature of the proceedings, which obscured the alleged fraud, and the risk of inconsistent judgments and preclusive effects.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s decision to grant the preliminary injunction in part. The appellate court held that the district court did not abuse its discretion in finding that State Farm demonstrated irreparable harm, serious questions going to the merits, a balance of hardships tipping in its favor, and that the injunction was in the public interest. The court also concluded that the Federal Arbitration Act did not bar the injunction of the arbitrations because the arbitrations would prevent State Farm from effectively vindicating its RICO claims.Additionally, the appellate court reversed the district court’s decision not to enjoin the pending state-court proceedings, finding that the Anti-Injunction Act’s “expressly-authorized” exception applied. The court determined that the state-court proceedings were part of a pattern of baseless, repetitive claims that furthered the alleged RICO violation, and that enjoining these proceedings was necessary to give RICO its intended scope. The case was remanded for further proceedings consistent with this opinion. View "State Farm Mutual v. Tri-Borough" on Justia Law

A group of skilled nursing facilities in New York and Rhode Island challenged a rule promulgated by the U.S. Department of Health and Human Services (HHS). The rule allowed certain inspections of these facilities without the presence of a registered nurse, which the plaintiffs argued contradicted the Medicaid Act's requirement for a registered nurse to be part of the survey teams. The dispute arose after an incident at Avon Nursing and Rehabilitation, where a resident was injured, leading to an inspection by a team that did not include a registered nurse. The plaintiffs contended that the rule violated the statutory requirement.The United States District Court for the Southern District of New York granted summary judgment in favor of the government. The court concluded that the Medicaid Act's registered nurse requirement applied only to surveys conducted under 42 U.S.C. § 1396r(g)(2) and not to activities under 42 U.S.C. § 1396r(g)(4), which were the subject of the challenged rule. The court also determined that even if the statute were ambiguous, the agency's interpretation was reasonable and entitled to deference under Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the registered nurse requirement did not extend to complaint investigations and other enforcement activities under 42 U.S.C. § 1396r(g)(4). The court reasoned that the term "survey" in the statute referred specifically to annual standard surveys, extended surveys, and validation surveys, and not to the investigatory activities described in § 1396r(g)(4). Consequently, the rule allowing inspections without a registered nurse did not contradict the Medicaid Act. View "Avon Nursing & Rehabilitation v. Becerra" on Justia Law

Michael Salazar filed a putative class action against the National Basketball Association (NBA) alleging violations of the Video Privacy Protection Act (VPPA). Salazar claimed that he signed up for the NBA’s free online newsletter, provided personal information, and watched videos on NBA.com. He alleged that the NBA disclosed his video-watching history and Facebook ID to Meta Platforms, Inc. without his consent, violating the VPPA.The United States District Court for the Southern District of New York dismissed Salazar’s complaint. The court concluded that while Salazar had standing to sue, he did not plausibly allege that he was a “consumer” under the VPPA. The court reasoned that the VPPA only applies to consumers of audiovisual goods or services, and the NBA’s online newsletter did not qualify as such. The court also found that signing up for the newsletter did not make Salazar a VPPA “subscriber.”The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Salazar’s alleged injuries were sufficiently concrete to confer Article III standing. It also found that the district court erred in holding that Salazar was not a “subscriber of goods or services” under the VPPA. The appellate court concluded that the VPPA’s definition of “goods or services” is not limited to audiovisual materials and that Salazar’s exchange of personal information for the NBA’s online newsletter made him a “subscriber.” Consequently, the Second Circuit vacated the district court’s judgment and remanded the case for further proceedings. View "Salazar v. NBA" on Justia Law

The State of New York, through its Attorney General, sued the Niagara-Wheatfield Central School District, alleging that school officials failed to address repeated complaints of student-on-student sexual assault, harassment, and gender-based violence and bullying. The complaint detailed incidents involving four students who suffered from such misconduct and claimed that the school district ignored at least thirty similar incidents. The State argued that the school district's inaction affected not only the victims but also the broader school community, creating an unsafe environment.The United States District Court for the Western District of New York dismissed the case, concluding that the State lacked parens patriae standing. The court reasoned that the incidents were factually distinct and did not demonstrate a broader policy or practice of discrimination by the school district. Without such a policy or practice, the court held that the State could not show that the school district's conduct affected a substantial segment of the population, which is required for parens patriae standing.The United States Court of Appeals for the Second Circuit reviewed the case and reversed the district court's decision. The appellate court held that showing an injurious policy or practice is not necessary to satisfy the substantial-segment prong of the parens patriae standard. The court concluded that the State of New York had met its burden of pleading parens patriae standing at this stage of the litigation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "New York v. Niagara-Wheatfield Central School District" on Justia Law

Joe Baltas, a Connecticut state prisoner, was transferred to the Virginia Department of Corrections (VADOC) under the Interstate Corrections Compact. While at Red Onion State Prison (ROSP) in Virginia, Baltas alleges he was threatened by VADOC officials for filing a grievance and was later attacked by inmates, resulting in his placement in restrictive housing. He also claims that Connecticut Department of Corrections (CTDOC) officials failed to review his administrative segregation (Ad Seg) status as required, violating his due process rights under the Fourteenth Amendment. Additionally, he alleges violations of his First, Sixth, and Eighth Amendment rights due to his treatment at ROSP.The United States District Court for the District of Connecticut granted summary judgment in favor of the Defendants. The court found that CTDOC had adequately reviewed Baltas’s Ad Seg classification and dismissed his due process claim. It also dismissed his First, Sixth, and Eighth Amendment claims, concluding that Baltas failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the District Court’s ruling that CTDOC’s periodic reviews of Baltas’s Ad Seg classification satisfied due process requirements. However, it found that a genuine dispute of fact existed regarding whether VADOC’s administrative remedies were available to Baltas, making summary judgment inappropriate for his First, Sixth, and Eighth Amendment claims. The court vacated the summary judgment on these claims and remanded the case for further proceedings. The court also affirmed the dismissal of Baltas’s remaining claims in a concurrently issued summary order. View "Baltas v. Maiga" on Justia Law

The case involves a dispute between two companies, 1-800 Contacts, Inc. (Plaintiff-Appellant) and JAND, Inc., doing business as Warby Parker (Defendant-Appellee). 1-800 Contacts alleged that Warby Parker used its trademarks in keyword search advertisements, violating the federal Lanham Act and New York State common law. Specifically, 1-800 Contacts claimed that Warby Parker purchased keywords consisting of 1-800 Contacts' trademarks to divert customers searching for 1-800 Contacts to Warby Parker's website. However, 1-800 Contacts did not allege that Warby Parker used its trademarks in any other way beyond purchasing them as keywords.The United States District Court for the Southern District of New York granted Warby Parker's motion for judgment on the pleadings, dismissing the case. The district court applied the Polaroid test to determine the likelihood of consumer confusion and found that although 1-800 Contacts' trademarks were strong and there were indications of bad faith by Warby Parker, these factors were insufficient to establish a likelihood of consumer confusion. The court emphasized that Warby Parker's advertisements and landing pages clearly displayed Warby Parker's own mark, which was substantially different from 1-800 Contacts' marks.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the mere act of purchasing a competitor's trademarks as keywords does not constitute trademark infringement. It found that 1-800 Contacts failed to plausibly allege any likelihood of consumer confusion under the Polaroid test. The court noted that Warby Parker's advertisements and landing pages did not use 1-800 Contacts' trademarks and were clearly marked with Warby Parker's own branding, making it unlikely that consumers would be confused about the source or affiliation of the advertisements. View "1-800 Contacts, Inc. v. JAND, Inc." on Justia Law