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

A patrol-level police officer in Colombia was convicted after a jury trial of conspiracy to import cocaine into the United States. The officer did not dispute that he participated in communications about a proposed cocaine export scheme, but argued that he lacked criminal intent because he believed he was assisting the Colombian National Police in arranging a seizure of the cocaine, rather than joining a drug-trafficking conspiracy. His defense at trial centered on his understanding that he was participating in an anti-narcotics operation and not an illegal export scheme.The United States District Court for the Southern District of New York presided over the jury trial. The prosecution presented evidence of the officer’s participation in meetings and communications with a DEA informant posing as a drug trafficker. The defense sought to introduce evidence that the officer’s colleague, who recruited him into the scheme, had previously assisted the Colombian National Police's anti-narcotics unit in successful drug seizures. The district court excluded this evidence, accepting the government’s argument that it constituted impermissible propensity evidence under Federal Rule of Evidence 404(b). The officer was convicted and sentenced to 165 months in prison, followed by five years of supervised release.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court erred in excluding the challenged evidence. The appellate court found the evidence relevant to corroborate the officer’s account of conversations with his colleague, directly impacting his state of mind, and determined that it was not barred by Rule 404(b). The court further held that the exclusion was not harmless, as the officer’s defense turned on criminal intent and the evidence could have affected the jury’s verdict. Accordingly, the Second Circuit vacated the conviction and remanded for further proceedings. View "U.S. v. Cardenas" on Justia Law

A ceiling collapse at a construction site in New York injured three employees of a subcontractor, Vanquish Contracting Corporation. The general contractor, Reidy Contracting Group, LLC, had required Vanquish to procure insurance coverage that would protect Reidy as an additional insured. Vanquish obtained an excess liability policy from Mt. Hawley Insurance Company, which incorporated the terms of an underlying policy issued by Endurance American Specialty Insurance Company. After the accident, the injured Vanquish employees sued Reidy. Reidy sought defense and indemnification from Mt. Hawley, but Mt. Hawley denied coverage, arguing that Reidy was not an additional insured and that the Employers Liability Exclusion in the policy barred coverage. The United States District Court for the Western District of New York reviewed cross-motions for summary judgment. The district court found that Reidy was an additional insured under the policy and that the Employers Liability Exclusion did not bar coverage. The court reasoned that, based on the policy’s language and the Separation of Insureds clause, “the insured” in the exclusion referred to the party seeking coverage—here, Reidy, which did not employ the injured workers. Alternatively, the court found the exclusion ambiguous and construed it against Mt. Hawley as the drafter. The court also held that Mt. Hawley was precluded from contesting Reidy’s status as an additional insured because it failed to timely raise this argument as required by New York law. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The appellate court held that Reidy qualifies as an additional insured and that the Employers Liability Exclusion is ambiguous; thus, the ambiguity must be resolved in favor of coverage for Reidy. The judgment granting summary judgment to Reidy and Merchants Mutual Insurance Company was affirmed. View "Reidy Contracting Group, LLC v. Mt. Hawley Insurance Company" on Justia Law

A professional photographer discovered that between 2018 and 2022, hundreds of his photographs were uploaded to an online stock photo platform operated by a large digital content marketplace, without his permission. Three contributors to the platform were responsible for uploading these images, and the platform subsequently licensed many of them to customers, generating revenue shared with the uploaders. After being notified by the photographer’s attorney, the platform removed the images and terminated the contributor accounts, but the photographer filed suit alleging both copyright infringement and violations related to the removal and alteration of copyright management information (CMI).The United States District Court for the Southern District of New York granted summary judgment to the platform on all claims. The court concluded that the platform qualified for safe harbor immunity under the Digital Millennium Copyright Act (DMCA) for the copyright infringement claims. For the CMI claims, the court found that the photographer failed to present evidence of the platform's required scienter (knowledge or intent) to sustain a violation under 17 U.S.C. § 1202.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision regarding the CMI claims, agreeing that there was no evidence the platform acted with the necessary scienter under § 1202(a) or (b). However, the appellate court vacated the grant of summary judgment on the copyright infringement claims. It held that factual disputes remained as to whether the infringing activity occurred “by reason of the storage at the direction of a user” and whether the platform had the “right and ability to control” the infringing activity, both critical to safe harbor eligibility under the DMCA. The case was remanded for further proceedings on these factual questions. View "McGucken v. Shutterstock, Inc." on Justia Law

Lanesborough 2000, LLC and Nextres, LLC entered into a loan agreement for the funding of a self-storage facility in Corning, New York. The deal included an arbitration agreement that required disputes to be resolved by binding arbitration. Lanesborough alleged that Nextres breached the agreement by failing to disburse loan funds as promised. An arbitrator found in favor of Lanesborough, awarding consequential damages, declaratory and injunctive relief, and attorney’s fees based on Nextres’s bad faith conduct. The arbitration agreement contained a waiver of the “right to appeal,” but did not specify its scope.The United States District Court for the Southern District of New York partially confirmed the arbitrator’s awards. It confirmed the awards of consequential damages, declaratory relief, and attorney’s fees, finding that the fee award was permissible because it was based on a finding of bad faith. The District Court also granted Lanesborough’s requests for injunctive relief by ordering Nextres to comply with the loan agreement and enjoining Nextres from pursuing foreclosure actions, including a pending state court foreclosure against a related party. The District Court awarded Lanesborough post-award prejudgment interest and stayed enforcement of its judgment pending appeal.On appeal, the United States Court of Appeals for the Second Circuit first held that the parties’ contractual waiver of the “right to appeal” was ambiguous and not sufficiently clear or unequivocal to preclude appellate review. On the merits, the Second Circuit affirmed the district court’s confirmation of the arbitrator’s awards and its grant of post-award prejudgment interest. However, it vacated the district court’s injunction barring the state-court foreclosure action because the lower court had not considered whether the injunction was consistent with the Anti-Injunction Act. The case was remanded for further proceedings on that issue. View "Lanesborough 2000, LLC v. Nextres, LLC" on Justia Law

Several health care facilities and their affiliates faced administrative complaints from the General Counsel of the National Labor Relations Board (NLRB) in 2012 for alleged unfair labor practices. The proceedings were assigned to Administrative Law Judge (ALJ) Kenneth Chu, who developed the factual record over multiple hearings. During this period, the Supreme Court’s decision in NLRB v. Noel Canning invalidated certain NLRB Board appointments, calling into question ALJ Chu’s own appointment. The Board later “ratified” prior actions, including Chu’s appointment, after regaining a lawful quorum. Administrative proceedings were delayed for several years due to interlocutory appeals and COVID-19, and ultimately resumed in 2023. Shortly before resumption, the plaintiffs sought to halt the proceedings, arguing the ALJ was unlawfully appointed and protected from removal in a manner unconstitutional under the separation of powers.The plaintiffs initially sought relief in the United States District Court for the District of New Jersey, which denied a temporary restraining order and transferred the case to the United States District Court for the District of Connecticut. There, the plaintiffs moved for a preliminary injunction, again raising constitutional arguments regarding the ALJ’s appointment and removal protections. The District of Connecticut denied the injunction, finding the plaintiffs had not shown a clear likelihood of success on the merits. Proceedings before ALJ Chu concluded in May 2024, after which Chu retired and the NLRB Board assumed de novo review of the case.The United States Court of Appeals for the Second Circuit reviewed the appeal. It assumed jurisdiction but declined to address the likelihood of success on the merits, instead affirming the district court’s denial of a preliminary injunction on the ground that the plaintiffs could not demonstrate irreparable harm. The court held that, because all proceedings before the challenged ALJ had concluded and the Board (now lawfully constituted) would conduct de novo review, there was no risk of irreparable injury warranting injunctive relief. The order was affirmed. View "Care One, LLC v. NLRB" on Justia Law

In January 2023, Jones J. Woods was charged with depredation against federal property after throwing rocks at windows of the United States Attorney’s Office in Buffalo, New York. Woods exhibited erratic behavior during court appearances in the United States District Court for the Western District of New York, prompting a psychiatric evaluation. In June 2023, the court found him incompetent to stand trial and ordered hospitalization for up to four months to determine if competency could be restored. After delays, Woods was hospitalized in January 2024, but after four months, he remained in custody at FMC Devens. In August 2024, following an evaluation, a Magistrate Judge found no substantial probability Woods would be restored to competency and ordered an additional 45 days of hospitalization, also directing an evaluation of dangerousness.Woods appealed the Magistrate Judge’s order to the United States District Court for the Western District of New York, which affirmed the order in September 2024. Meanwhile, the government filed a certificate of dangerousness, staying Woods’s release and initiating civil commitment proceedings in the District of Massachusetts. Woods challenged the validity of the extension of his hospitalization, arguing the district court lacked authority under the relevant statutes once the initial four-month period had expired and no restoration of competency was likely.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Woods’s appeal was moot as to the dangerousness evaluation, since it had been completed and relief was not available. However, the appeal was not moot regarding the 45-day extension of hospitalization, as vacatur could affect ongoing civil commitment proceedings. On the merits, the Second Circuit affirmed the district court’s authority under 18 U.S.C. § 4241(d)(2)(B) to order continued custodial hospitalization for a reasonable period after the initial four months if charges were not yet disposed of, even when restoration of competency was deemed unlikely. The remainder of Woods’s appeal was dismissed as moot. View "United States v. Woods" on Justia Law

Janet Duke, after retiring from Luxottica U.S. Holdings Corp., elected to receive pension benefits through a joint and survivor annuity (JSA), calculated using actuarial assumptions set by her employer’s defined benefit pension plan. Duke alleged that her plan used outdated assumptions—specifically, a 7% interest rate and life expectancy tables from 1971—to convert single life annuities (SLA) into JSA benefits, resulting in lower monthly payments for her and similarly situated retirees. She claimed this systematic practice violated ERISA’s requirements for actuarial equivalence and compliance, thereby potentially harming the plan’s participants and the plan itself.In the United States District Court for the Eastern District of New York, Duke filed a putative class action seeking relief under ERISA Sections 502(a)(2) and 502(a)(3), including plan reformation and monetary repayments to the plan. The district court initially found Duke lacked standing for Section 502(a)(2) claims but later reversed itself and held that she did have standing for both plan reformation and monetary payments. The court compelled individual arbitration of her Section 502(a)(3) claims under a dispute resolution agreement but held that the “effective vindication” doctrine prevented mandatory arbitration of her Section 502(a)(2) claims. Defendants’ motion for a mandatory stay of litigation pending arbitration was denied.The United States Court of Appeals for the Second Circuit reviewed the district court’s rulings. It held that Duke has Article III standing to pursue plan reformation under Section 502(a)(2) because her alleged injury—reduced benefits due to outdated assumptions—could be redressed by reformation of the plan. However, Duke lacks standing to seek monetary payments to the plan, as such relief would not redress any personal injury she suffered. The Second Circuit also held that the effective vindication doctrine precludes mandatory individual arbitration of her Section 502(a)(2) claim and affirmed the district court’s discretionary denial of a mandatory stay. The order was affirmed in part and reversed in part. View "Duke v. Luxottica U.S. Holdings Corp." on Justia Law

Steve Boria was indicted for leading a gang involved in distributing narcotics and committing violent acts. He distributed crack cocaine and was involved in a firearm discharge. After most co-defendants pleaded guilty, Boria opted to plead guilty as well. On the night before his plea hearing, he took medications for sleeping problems and bipolar disorder. During the plea colloquy before the United States District Court for the Southern District of New York, the magistrate judge inquired about his medication use, confirmed he felt clearheaded, and verified his understanding of the proceedings. Both defense counsel and the government had no objections to Boria’s competence. Boria responded cogently to the court’s questions and the court found his plea voluntary and knowing, subsequently sentencing him to fifteen years.Boria’s counsel failed to file a timely notice of appeal after sentencing. The district court found this constituted ineffective assistance of counsel, vacated the judgment, and re-entered it to allow Boria to appeal. Boria then timely appealed the amended judgment.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not violate Federal Rule of Criminal Procedure 11 or Boria’s constitutional rights. The appellate court found the district court’s inquiry sufficient to ensure Boria’s understanding and voluntariness of the plea, as Boria’s conduct during the hearing raised no concerns regarding his competency. Additionally, the Second Circuit determined that Boria failed to show plain error, as there was no reasonable probability he would not have pleaded guilty but for the alleged procedural error. Accordingly, the Second Circuit affirmed the judgment of the district court. View "United States v. Boria" on Justia Law

GEICO and its subsidiaries brought a lawsuit in the United States District Court for the Eastern District of New York against Dr. Bhargav Patel and his medical practice, alleging that the defendants engaged in a scheme to defraud GEICO by manipulating New York’s no-fault automobile insurance system. GEICO claimed that from 2019 to 2023, defendants submitted approximately $3.4 million in reimbursement claims for treatments that were unnecessary, experimental, excessive, illusory, or not provided at all. These claims allegedly resulted from a fraudulent scheme involving kickbacks for patient referrals and the provision of services by unlicensed individuals or contractors.After GEICO initiated its federal action, the defendants responded by filing over 600 collection actions in New York state courts and arbitration tribunals, seeking recovery for disputed or denied claims totaling more than $2 million. GEICO, facing the prospect of fragmented litigation and the risk of inconsistent judgments, sought a preliminary injunction from the district court to stay all pending state and arbitration proceedings and to prevent the defendants from filing new collection actions until the federal court resolved the RICO claims. The district court granted the injunction, finding that GEICO had demonstrated irreparable harm, serious questions going to the merits, and a balance of hardships tipping in GEICO’s favor. The court also determined it had authority under the “in aid of jurisdiction” exception to the Anti-Injunction Act to enjoin the parallel proceedings.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision for abuse of discretion and found none. The appellate court held that the preliminary injunction was justified by the real risk of irreparable harm to GEICO posed by inconsistent judgments and the inability to fully adjudicate the alleged fraudulent scheme in piecemeal state actions. The Second Circuit further held, consistent with its recent precedent in State Farm Mutual Automobile Insurance Company v. Tri-Borough NY Medical Practice, P.C., that the injunction did not violate the Anti-Injunction Act because it was expressly authorized under RICO. The court affirmed the district court’s order. View "GEICO v. Patel" on Justia Law

An employee of a New York City tour company was terminated in 2012, allegedly for attempting to unionize. The National Labor Relations Board (NLRB) began investigating the termination, and in 2013, its adjudicative body found the discharge violated the National Labor Relations Act (NLRA), ordering the company to reinstate the employee and compensate him for lost earnings. After a brief reinstatement and a second termination, further proceedings led to a backpay judgment against the company and several affiliates, including some of the current appellants. When the judgment debtors failed to pay, the NLRB issued administrative subpoenas seeking documents to determine whether the appellants could be held liable for the judgment. The appellants did not comply with these subpoenas.The United States District Court for the Southern District of New York reviewed the NLRB’s application to enforce the subpoenas. The court rejected the appellants’ arguments concerning lack of subject-matter jurisdiction, personal jurisdiction, and improper venue, holding that the NLRA authorized nationwide service of process and that the inquiry was conducted in the Southern District of New York. The court denied the appellants’ motion to transfer the case to the Southern District of Texas and awarded attorneys’ fees and costs to the NLRB, later specifying the amount.The United States Court of Appeals for the Second Circuit found that the district court had subject-matter and personal jurisdiction to enforce the subpoenas, and that venue was proper. It held that the district court did not abuse its discretion by refusing to transfer the case or by awarding fees and costs based on the appellants’ repeated evasion of service and failure to comply. However, the appellate court lacked jurisdiction to review the district court’s subsequent order fixing the amount of fees and costs, as no timely notice of appeal was filed for that order. The judgment was thus affirmed in part and dismissed in part. View "Nat'l Lab. Rels. Bd. v. Universal Smart Conts., LLC" on Justia Law