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

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

In 2008, Charles Anthony Giovinco pleaded guilty to enticement of a minor and possession of child pornography. He received concurrent sentences of 235 months for enticement and 120 months for possession. The First Step Act of 2018 (FSA) allows eligible prisoners to earn time credits for participating in certain programs, but excludes those serving sentences for specific offenses, including possession of child pornography.Giovinco argued that he should be eligible for FSA time credits after completing the sentence for the ineligible offense. The Bureau of Prisons (BOP) denied his request, stating that his entire term of imprisonment must be considered as a single, aggregated sentence, making him ineligible for FSA time credits. Giovinco filed a habeas petition, which the United States District Court for the District of Connecticut denied, deferring to the BOP's interpretation.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that under 18 U.S.C. § 3584(c), multiple terms of imprisonment must be treated as a single, aggregate term for administrative purposes, including the administration of FSA time credits. Therefore, a prisoner serving any part of an aggregated sentence for an ineligible offense is not eligible to earn FSA time credits. The court affirmed the district court's judgment, agreeing that the BOP correctly aggregated Giovinco's sentences and determined his ineligibility for FSA time credits. View "Giovinco v. Pullen" on Justia Law

The case involves a challenge to New York City's Guaranty Law, which was enacted in response to the COVID-19 pandemic. The law rendered personal guaranties of commercial lease obligations arising between March 7, 2020, and June 30, 2021, permanently unenforceable and identified efforts to collect on such guaranties as proscribed commercial tenant harassment. Plaintiffs, a group of New York City landlords, argued that the law violated the Contracts Clause of the U.S. Constitution.Initially, the United States District Court for the Southern District of New York dismissed the plaintiffs' constitutional challenges, but the United States Court of Appeals for the Second Circuit reversed the dismissal of the Contracts Clause challenge and remanded the case for further consideration. On remand, the district court granted summary judgment in favor of the plaintiffs, finding that the Guaranty Law was unconstitutional.The City of New York appealed, arguing that the plaintiffs lacked standing because the City did not enforce the Guaranty Law. The Second Circuit found that while the plaintiffs had standing at the pleadings stage due to the presumption of enforcement, they failed to meet the heightened burden on summary judgment to show a credible threat of imminent enforcement by the City. The City had unequivocally disavowed any intent to enforce the Guaranty Law against the plaintiffs.The United States Court of Appeals for the Second Circuit vacated the district court's award of summary judgment and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. The court denied the City's request to vacate its earlier judgment reversing the dismissal of the Contracts Clause challenge and denied the City costs on the appeal due to its negligent delay in raising the enforcement-based standing challenge. View "Bochner v. City of New York" on Justia Law

A former public school principal in Brooklyn, New York, brought a lawsuit against the New York City Department of Education (DOE) and its former chancellor, alleging retaliation after she complained about racially segregated sports teams at her school. The principal claimed that the DOE's investigation into her was a retaliatory action for her complaints about race discrimination affecting her students.The United States District Court for the Southern District of New York dismissed the principal's Title VI claim, reasoning that her challenge was related to an employment practice and that the primary objective of the federal funds received by the DOE was not to provide employment. The court also denied her motion for leave to amend her complaint, even after reconsidering its initial decision.The United States Court of Appeals for the Second Circuit reviewed the case and held that the principal's retaliation claim was not an action "with respect to any employment practice" under Title VI because her underlying protected activity was unrelated to the DOE’s employment practices. The court concluded that Title VI does provide a private right of action for retaliation claims when the retaliation is for opposing non-employment-related race discrimination. The court affirmed the dismissal of the claim against the former chancellor but vacated the dismissal of the Title VI claim against the DOE and remanded the case for further proceedings. View "Bloomberg v. N.Y.C. Department of Education" on Justia Law