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

A dispute arose between a manufacturer of construction equipment and its distributor over a 2012 distribution agreement. The distributor alleged that the manufacturer breached the agreement by selling covered equipment directly to third parties, bypassing the distributor. The manufacturer, in turn, counterclaimed that the distributor failed to pay amounts due under a 2016 rental agreement and for various purchases made between 2016 and 2017. Both parties sought damages and prejudgment interest related to their respective claims and counterclaims.The United States District Court for the Southern District of New York, after the completion of discovery, granted summary judgment for the distributor on liability for its breach-of-contract claim, leaving damages to be determined by a jury. The court also granted summary judgment for the manufacturer as to both liability and damages on its breach-of-contract counterclaim. A jury awarded the distributor substantial damages for the manufacturer’s breach. The district court denied the manufacturer’s post-trial motions for judgment as a matter of law and for a new trial or remittitur, and later awarded prejudgment interest to the distributor, despite the manufacturer’s objection that the request was untimely under Federal Rule of Civil Procedure 59(e).On appeal, the United States Court of Appeals for the Second Circuit addressed whether the distributor’s motion for prejudgment interest was timely. The court held that the initial judgment entered by the district court was not sufficiently final, as it omitted reference to the manufacturer’s successful counterclaim and the award of prejudgment interest. As a result, the 28-day deadline for a Rule 59(e) motion was not triggered until a later, comprehensive, final judgment was entered. The Second Circuit affirmed the district court’s award of prejudgment interest to the distributor. View "Alessi Equip., Inc. v. Am. Piledriving Equip., Inc." on Justia Law

A wealthy bond trader from New York, through a network of assistants, recruited women from across the United States to travel to his New York penthouse for what was represented as consensual sadomasochistic sexual encounters in exchange for money. The women were enticed with promises of cash, luxury experiences, and travel. However, once there, while some anticipated rough consensual sex, they were subjected to violent, nonconsensual acts, including severe physical abuse, sexual assault, and use of force far beyond what had been described or agreed to. The trader required the women to sign non-disclosure and purported consent agreements, often after they had used alcohol or drugs, and none received copies. The plaintiffs, six women, alleged lasting physical and psychological harm.The United States District Court for the Eastern District of New York conducted a jury trial on claims under the Trafficking Victims Protection Act (TVPA) and state tort law. After deliberation, the jury found the defendant liable under the TVPA and awarded each plaintiff $500,000 in compensatory damages. Five plaintiffs received $120,000 in punitive damages each, and one plaintiff received $250,000. The jury did not find the defendant’s assistants liable, except for one minor battery claim. The defendant’s post-trial motions for judgment as a matter of law or a new trial were denied.On appeal, the United States Court of Appeals for the Second Circuit reviewed challenges to the sufficiency of the evidence, the district court’s jury instructions, and the availability of punitive damages under the TVPA. The court held that sufficient evidence supported the jury’s verdict, the instructions properly conveyed the applicable law, and punitive damages are available under the TVPA. The Second Circuit affirmed the district court’s judgment in all respects. View "Moore v. Rubin" on Justia Law

Adam Gomez was charged with receiving and possessing a firearm that had an obliterated serial number. He moved to dismiss the indictment, arguing that the statute under which he was charged, 18 U.S.C. § 922(k), was unconstitutional. After the United States District Court for the Northern District of New York denied his motion, Gomez pleaded guilty to the offense. His appeal centers on the claim that the statute is facially unconstitutional in light of the Supreme Court’s decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, which clarified the scope of the Second Amendment.The United States District Court for the Northern District of New York denied Gomez’s motion to dismiss the indictment, rejecting his constitutional challenge to § 922(k). Following this denial, Gomez entered a guilty plea and was convicted. He then appealed the judgment, arguing that the statute violates the Second Amendment as interpreted by the Supreme Court in Bruen.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The Second Circuit held that 18 U.S.C. § 922(k) is facially constitutional. The court reasoned that the statute does not infringe upon the right to bear arms because it does not prevent anyone from possessing any type of firearm, and firearms with obliterated serial numbers are not weapons in common use for lawful purposes. The court also noted that Gomez’s facial challenge failed because he did not demonstrate that the statute is unconstitutional in all its applications or that it lacks a plainly legitimate sweep. Accordingly, the Second Circuit affirmed the conviction. View "United States v. Gomez" on Justia Law

A trade association representing the dietary supplement industry challenged a New York law that prohibits the sale of dietary supplements marketed for weight loss or muscle building to individuals under eighteen. The law was enacted in response to concerns about health risks to minors from such supplements. The statute defines covered products based on how they are labeled or marketed, and authorizes the Attorney General to seek injunctions against violators. The association argued that the law violates the First Amendment, is unconstitutionally vague, and is preempted by federal law.The United States District Court for the Southern District of New York denied the association’s motion for a preliminary injunction, finding that the association was unlikely to succeed on the merits of its claims, had not shown irreparable harm, and that the balance of equities and public interest weighed against granting relief. The District Court later dismissed the vagueness and preemption claims but allowed the First Amendment claim to proceed.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court’s denial of a preliminary injunction. The Second Circuit held that the law satisfies intermediate scrutiny under the Central Hudson test for commercial speech, finding that New York has a substantial interest in protecting minors’ health, that the law directly advances that interest, and that it is not more extensive than necessary. The court also concluded that the age verification requirement does not unconstitutionally compel speech, that the statute is not unconstitutionally vague or overbroad, and that it is not preempted by federal law. The court further found that the association failed to demonstrate irreparable harm or that the public interest favored an injunction. The order denying the preliminary injunction was affirmed. View "Council for Responsible Nutrition v. James" on Justia Law

Thomas Cole brought suit against his former employer, Foxmar, Inc., alleging unlawful retaliation in violation of the Vermont Occupational Safety and Health Act (VOSHA) and the Vermont Earned Sick Time Act (VESTA). At trial, a jury found in Cole’s favor on both claims, initially awarding him over $3 million in damages, including punitive damages. However, after the District Court determined the punitive damages were excessive and ordered a new trial on damages, the second jury awarded Cole $55,000 in compensatory damages and no punitive damages. Cole then sought attorney’s fees under the relevant Vermont statutes.The United States District Court for the District of Vermont found Cole entitled to reasonable attorney’s fees but imposed two across-the-board reductions: a twenty-five percent reduction for what it deemed excessive hours billed by Cole’s attorney, and a further thirty percent reduction based on the perceived disproportionality between the attorney’s fees requested and the damages ultimately awarded. This resulted in a total fee award significantly lower than Cole’s request. Cole appealed, arguing that both reductions were improper and that the overall award was unreasonably low.The United States Court of Appeals for the Second Circuit reviewed the District Court’s decision for abuse of discretion. The appellate court held that the twenty-five percent reduction for excessive hours was within the District Court’s discretion and consistent with Vermont law. However, the court concluded that the thirty percent reduction based on proportionality between fees and damages was not permitted under Vermont law, which does not require fee awards to be proportional to damages in cases involving fee-shifting statutes like VOSHA and VESTA. The Second Circuit therefore vacated the District Court’s fee award and remanded the case for recalculation of a reasonable fee consistent with Vermont law. View "Cole v. Foxmar, Inc." on Justia Law

In March 2023, a New York State grand jury indicted a former President on thirty-four counts of falsifying business records in the first degree. The indictment alleged that he orchestrated a scheme to influence the 2016 presidential election by directing his personal lawyer to pay $130,000 to an adult film star to prevent disclosure of an alleged sexual encounter. The payments were disguised as legal fees in business records. After arraignment, the defendant sought to remove the case to federal court under the federal officer removal statute, arguing the conduct was within the color of his office and involved federal defenses. The federal district court remanded the case to state court, finding the prosecution fell outside the scope of federal officer removal jurisdiction. A state court jury subsequently convicted the defendant on all counts.After conviction but before sentencing, the United States Supreme Court issued a decision in Trump v. United States, holding that the President is absolutely immune from criminal prosecution for conduct within his exclusive constitutional authority and that evidence of immunized official acts is inadmissible even when an indictment alleges only unofficial conduct. The defendant then sought leave to file a second, untimely notice of removal in federal court, arguing that the Supreme Court’s decision provided new grounds for removal and established good cause for the delay. The United States District Court for the Southern District of New York denied leave, concluding that good cause had not been shown and that the hush money payments were private, unofficial acts.The United States Court of Appeals for the Second Circuit reviewed the district court’s denial. The Second Circuit held that the district court had not adequately considered issues relevant to the good cause inquiry, including the impact of the Supreme Court’s decision and whether evidence admitted at trial related to immunized official acts. The Second Circuit vacated the district court’s order and remanded for reconsideration of the motion for leave to file a second notice of removal, instructing the district court to address these issues. View "New York v. Trump" on Justia Law

Lavellous Purcell operated a commercial sex business from 2012 to 2017, recruiting women from across the United States to work as prostitutes and coordinating their interstate travel. He resided primarily on Long Island, New York, and the women involved traveled to at least fourteen states. The government’s case focused on documentary evidence regarding one victim, Samantha Vasquez, showing her work for Purcell in various locations, but not in the Southern District of New York.Purcell was indicted in 2018 in the United States District Court for the Southern District of New York on five counts related to sex trafficking. After a jury trial, he was convicted on all counts and sentenced to 216 months’ imprisonment. On direct appeal to the United States Court of Appeals for the Second Circuit, his conviction on Count One (enticement to engage in unlawful sexual activity) was reversed for lack of venue in the Southern District of New York, but his conviction on Count Two (transporting a victim in interstate commerce to engage in prostitution) was affirmed because his appellate counsel did not challenge venue for that count. The district court reimposed the original sentence after remand. Purcell then filed a habeas petition under 28 U.S.C. § 2255, which the district court denied, finding appellate counsel’s performance reasonable.The United States Court of Appeals for the Second Circuit reviewed the denial of Purcell’s habeas petition de novo. The court held that Purcell’s appellate counsel was constitutionally ineffective for failing to challenge venue as to Count Two, as the omitted argument was significant and obvious and likely would have resulted in reversal of that conviction. The court declined to apply the concurrent sentence doctrine and found Purcell was prejudiced by counsel’s omission. The Second Circuit reversed the district court’s denial of Purcell’s § 2255 petition and remanded for further proceedings. View "Purcell v. United States" on Justia Law

Steven Douglas Coleman, a well-known jazz saxophonist, brought a defamation claim under New York law against his former pupil, Maria Kim Grand. The dispute arose from a seven-page letter Grand circulated privately to friends and colleagues in the music industry, describing her complex sexual and professional relationship with Coleman from 2011 to 2016. In the letter, Grand recounted various incidents and interactions, characterizing Coleman’s conduct as sexual harassment and describing situations where she felt pressured to be intimate with him in exchange for mentorship and professional opportunities. Grand used a pseudonym for Coleman and stated her intent was to contribute to the broader conversation about sexism in the music industry.The United States District Court for the Eastern District of New York reviewed cross-motions for summary judgment. The district court granted summary judgment in favor of Grand, finding that Coleman failed to present facts from which a reasonable jury could conclude that Grand acted with actual malice. The court also determined that the statements in Grand’s letter were non-actionable opinions rather than demonstrably false factual assertions, and that the letter disclosed the underlying facts supporting Grand’s opinions.On appeal, Coleman argued that the district court misapplied New York law, erred in finding no genuine issue of material fact regarding actual malice, and incorrectly classified the challenged statements as non-actionable opinion. The United States Court of Appeals for the Second Circuit reviewed the case de novo and affirmed the district court’s judgment. The Second Circuit held that the statements Coleman challenged were Grand’s subjective opinions supported by disclosed facts, and thus not actionable as defamation under New York law. The court concluded that none of the statements at issue were defamatory and affirmed the dismissal of Coleman’s claim. View "Coleman v. Grand" on Justia Law

A man committed several felonies in New York and Virginia between 2000 and 2001. After serving his prison sentences, he was subject to both state and federal post-release supervision. He repeatedly violated the terms of his supervision, resulting in multiple periods of reincarceration. In 2006, the United States Court of Appeals for the Second Circuit held in Earley v. Murray that New York’s practice of administratively imposing post-release supervision without a judicial pronouncement was unconstitutional. The state legislature responded in 2008 by authorizing corrections officials to initiate resentencing proceedings. The plaintiff was incarcerated in New York from June 2007 to February 2008 for violating post-release supervision, and again in 2010, before being resentenced without post-release supervision.The United States District Court for the Eastern District of New York dismissed the plaintiff’s claims for damages related to his 2010 incarceration, finding the defendants acted reasonably at that time, but allowed claims related to the 2007-08 incarceration to proceed to trial. At trial, the defendants were barred from introducing evidence that legal and administrative obstacles prevented them from initiating resentencing for the plaintiff during 2007-08. The jury awarded the plaintiff $100,000 in compensatory and $750,000 in punitive damages. The district court denied the defendants’ motion for a new trial and rejected their qualified immunity defense for the 2007-08 period.The United States Court of Appeals for the Second Circuit held that the district court abused its discretion by excluding evidence of impediments to resentencing and erred in denying a new trial for the 2007-08 period. The court reversed the denial of a new trial for that period, vacated the dismissal of the 2010 claims on qualified immunity grounds, and remanded for further proceedings. The court also held that qualified immunity was properly denied for both periods under existing precedent. View "Santiago v. Fischer" on Justia Law

A high school senior in New York posted a photo on social media after school hours and off school grounds, depicting a friend kneeling on his neck with the caption “Cops got another.” The image resembled the murder of George Floyd, and although the student claimed he did not intend this resemblance, he removed the post within minutes after receiving negative reactions. However, another student took a screenshot and shared it more widely, leading to public outcry, in-school discussions, a student demonstration, and a school investigation. The school superintendent suspended the student and barred him from extracurricular activities for the rest of the school year.The student initially filed suit in New York State Supreme Court, alleging that the school’s disciplinary actions violated his First Amendment rights. After the state court granted limited injunctive relief allowing him to attend graduation, the defendants removed the case to the United States District Court for the Southern District of New York. Following discovery, the district court granted summary judgment for the school district, finding that the student’s off-campus speech caused substantial disruption in school and thus was not protected by the First Amendment.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision. Applying the standards from Tinker v. Des Moines Independent Community School District and Mahanoy Area School District v. B.L., the Second Circuit held that the school’s disciplinary actions violated the student’s First Amendment rights. The court found that the off-campus nature of the speech, its lack of threatening content, and the school’s interests did not justify the punishment imposed. The Second Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Leroy v. Livingston Manor Central School District" on Justia Law