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

The case involves a dispute over fees related to contracts between independent solar generators (the plaintiffs) and National Grid USA Services Co., Inc. and its affiliate Niagara Mohawk Power Corporation (the defendants). The plaintiffs are required to pay costs for interconnecting their solar energy projects to the defendants' electric distribution grid, which includes a "tax gross-up adder" to offset the defendants' federal income tax liability. The plaintiffs sought a declaratory judgment that these interconnection payments are not taxable income and also sought to recover the allegedly unlawful tax-related fees through state-law claims for damages.The United States District Court for the Northern District of New York dismissed the case, finding that it lacked subject-matter jurisdiction. The court concluded that the plaintiffs' request for a declaratory judgment was barred by the Declaratory Judgment Act because the federal tax issue would only arise as a defense to a state-law breach of contract claim. The court also found that the plaintiffs' state-law claims did not raise a substantial federal question, as the federal tax issue was not significant to the federal system as a whole.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The appellate court agreed that the plaintiffs' request for declaratory relief did not meet the threshold requirement for federal subject-matter jurisdiction, as the federal tax issue would only arise as a defense in a hypothetical state-law breach of contract claim. The court also found that the federal issue in the plaintiffs' state-law claims was not substantial, as it was fact-bound and situation-specific, and did not have broader significance for the federal government. Therefore, the district court's dismissal for lack of subject-matter jurisdiction was upheld. View "Sunvestment Energy Group NY 64 LLC v. National Grid USA Services Co., Inc." on Justia Law

In this case, three defendants, officers and executives of the Connecticut Municipal Electric Energy Cooperative (CMEEC), were convicted of theft involving a program receiving federal funds. The defendants misappropriated funds from CMEEC in 2015 to pay for personal vacations disguised as corporate retreats. These trips included visits to the Kentucky Derby and the Greenbrier Resort, with expenses charged to CMEEC's accounts.The United States District Court for the District of Connecticut oversaw the trial, where the jury found the defendants guilty of one count of theft involving a program receiving federal funds. The jury determined that CMEEC received more than $10,000 in federal benefits in 2015, satisfying the jurisdictional requirement of 18 U.S.C. § 666(a)(1)(A). The defendants were acquitted on other counts, including conspiracy and theft for the years 2014 and 2016. The district court sentenced the defendants to imprisonment and ordered restitution for the misappropriated funds.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's judgment, rejecting the defendants' claims of insufficient evidence and prosecutorial misconduct. The appellate court held that CMEEC received federal benefits exceeding $10,000 in 2015, as the funds were provided under a federal grant program. The court also found no merit in the defendants' argument that the government misled the grand jury or that the district court erred in setting the restitution amount. Additionally, the court denied CMEEC's petition for mandamus, concluding that the district court did not err in finding that the legal fees advanced to the defendants lacked a sufficient causal relationship to their offense of conviction.The Second Circuit affirmed the district court's judgment of conviction and restitution order, and denied CMEEC's petition for mandamus. View "United States v. Sullivan, Bilda, Rankin" on Justia Law

In 2007, Mohamed Musaid was arrested for the murder of a relative and confessed to the crime. However, his trial was delayed for over eight years due to repeated findings of incompetence to stand trial, attributed to his long history of mental illness. Musaid was found incompetent on ten occasions and competent on five, with his competency dependent on his compliance with antipsychotic medication. Each time he was found competent and transferred to Rikers Island, he would refuse medication and regress to incompetence.The trial court eventually allowed Musaid's trial to proceed nearly ten months after a final finding of competency, without re-evaluating his mental state. During the trial, Musaid exhibited erratic behavior, raising questions about his competency. Despite this, the trial court did not conduct a further inquiry into his mental state. Musaid was convicted and sentenced to 25 years to life for second-degree murder and five years for criminal possession of a weapon.Musaid appealed, arguing that the trial court's failure to reassess his competency before trial violated his due process rights. The Appellate Division affirmed the conviction, stating there was no indication that Musaid was unable to understand the proceedings or assist in his defense. Musaid then sought habeas corpus relief in the United States District Court for the Southern District of New York, which was denied.The United States Court of Appeals for the Second Circuit reviewed the case and found that the trial court's failure to conduct a minimal inquiry into Musaid's competency just before trial was objectively unreasonable, given his history of mental illness and the time elapsed since the last competency evaluation. The court reversed the district court's decision and remanded with instructions to grant a conditional writ of habeas corpus, allowing the state courts to determine whether it is possible to reconstruct Musaid's competency at the time of trial based on evidence proximate to the trial. View "Musaid v. Kirkpatrick" on Justia Law

The case involves Internet Archive (IA), a nonprofit organization that creates digital copies of print books and makes them available online for free through its "Free Digital Library." IA maintains a one-to-one owned-to-loaned ratio, meaning it only allows as many digital checkouts as it has physical copies. In 2020, four major book publishers sued IA, alleging that its practices infringed their copyrights on 127 books. IA claimed its actions were protected under the fair use doctrine of the Copyright Act.The United States District Court for the Southern District of New York granted summary judgment in favor of the publishers, rejecting IA's fair use defense. The court found that IA's use of the books was non-transformative, commercial in nature, and that it usurped the market for the publishers' eBooks, causing market harm.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that IA's use of the books was not transformative because it did not add new expression, meaning, or message to the original works. Instead, it served the same purpose as the originals, making them available to read. The court also found that IA's use was commercial, as it solicited donations and had a partnership with Better World Books, which provided some financial benefit. The court concluded that IA's practices harmed the publishers' market for eBooks and print books, as IA's free digital copies served as a substitute for the originals.The Second Circuit affirmed the district court's decision, holding that IA's Free Digital Library did not qualify as fair use under the Copyright Act. The court emphasized that allowing such widespread copying and distribution without compensation would undermine the incentives for authors to create new works. View "Hachette Book Group, Inc. v. Internet Archive" on Justia Law

The case involves plaintiffs who are individuals and entities harmed by the September 11, 2001 terrorist attacks. They brought claims against the Republic of Sudan under the Foreign Sovereign Immunities Act (FSIA), specifically invoking the state-sponsored terrorism exception under § 1605A. The plaintiffs allege that Sudan provided material support to al Qaeda, which facilitated the attacks. Sudan moved to dismiss the actions, asserting foreign sovereign immunity under the FSIA.The United States District Court for the Southern District of New York denied Sudan’s motion to dismiss. The district court found that Sudan lacked immunity under two terrorism-related exceptions to the FSIA: § 1605A and § 1605B. Sudan then filed a notice of appeal, seeking interlocutory review of the district court’s denial of immunity under § 1605B and the repealed § 1605(a)(7), but not under § 1605A. Sudan argued that the collateral-order doctrine permitted immediate appeals from denials of immunity under the FSIA.The United States Court of Appeals for the Second Circuit reviewed the case. The main issue was whether § 1605A(f) of the FSIA, which limits appeals in actions brought under § 1605A, barred Sudan’s appeal. The court held that § 1605A(f) eliminates all interlocutory appeals under the collateral-order doctrine from orders falling within its scope, including Sudan’s proposed appeal. The court concluded that because the district court’s order was nonfinal and the plaintiffs’ actions were brought under § 1605A, the appellate bar applied. Consequently, the court dismissed Sudan’s appeal for lack of appellate jurisdiction. View "In re: Terrorist Attacks on September 11, 2001" on Justia Law

Robert Guthrie, a former employee of Rainbow Fencing Inc. (RFI), filed a lawsuit seeking unpaid wages and statutory damages for RFI's failure to provide wage notices and wage statements as required by New York law. Guthrie worked as a welder for RFI from 2014 to 2021 and claimed he was not paid for overtime hours. The district court entered a default judgment for the unpaid wages but dismissed Guthrie's claim for statutory damages, ruling that he lacked standing because he did not allege an injury-in-fact resulting from the failure to provide the required notices and statements.The United States District Court for the Eastern District of New York initially reviewed the case. The court granted a default judgment for Guthrie's unpaid wages but dismissed his claim for statutory damages due to lack of standing. The court concluded that Guthrie did not allege a concrete injury-in-fact caused by the absence of wage notices and statements, which is necessary to meet the case-or-controversy requirement of Article III.The United States Court of Appeals for the Second Circuit reviewed the case on appeal. The court affirmed the district court's decision, agreeing that Guthrie lacked standing to pursue statutory damages. The appellate court held that a plaintiff must allege a concrete injury-in-fact resulting from the statutory violation to have standing. Guthrie's general claims about potential harms did not suffice, as he failed to link these potential harms to any actual injury he experienced. Therefore, the court concluded that Guthrie did not meet the requirements for Article III standing and affirmed the dismissal of his claim for statutory damages. View "Guthrie v. Rainbow Fencing Inc." on Justia Law

In November 2005, Derrek Pannell and accomplices robbed a United States Post Office in Brooklyn, New York. Pannell, an employee of the Post Office, used his knowledge of the keypad lock to gain entry. The robbers restrained five employees and held them at gunpoint while demanding money from a safe. They fled with over $65,000 and assaulted a supervisor outside. Pannell was convicted of conspiracy to commit robbery, aggravated robbery, and brandishing a firearm in connection with a crime of violence.Following his conviction, Pannell's direct appeal was unsuccessful. He then sought habeas relief under 28 U.S.C. § 2255, arguing that his conviction for aggravated postal robbery did not qualify as a crime of violence under 18 U.S.C. § 924(c). The United States District Court for the Eastern District of New York denied his motion, concluding that both the base and aggravated offenses of § 2114(a) robbery qualified as crimes of violence. Pannell appealed this decision.The United States Court of Appeals for the Second Circuit reviewed the case. Pannell argued that his § 924(c) conviction was invalid because aggravated postal robbery under § 2114(a) is not a crime of violence, especially when based on a Pinkerton theory of liability. The court rejected this argument, citing precedent that a conviction under a Pinkerton theory does not alter the nature of the substantive offense. The court also held that the base offense of § 2114(a) robbery qualifies as a crime of violence, and thus, the aggravated offense does as well. Consequently, the Second Circuit affirmed the district court's denial of Pannell's § 2255 motion. View "Pannell v. United States" on Justia Law

Sarah Palin filed a defamation lawsuit against The New York Times and its former Opinion Editor, James Bennet, alleging that an editorial falsely linked her political action committee's map to the 2011 shooting of Congresswoman Gabrielle Giffords. The editorial claimed a "clear" and "direct" link between the map and the shooting, which Palin argued was defamatory.Initially, the United States District Court for the Southern District of New York dismissed Palin's complaint under Federal Rule of Civil Procedure 12(b)(6). The Second Circuit Court of Appeals reinstated the case in 2019, finding that Palin had plausibly stated a defamation claim. The case proceeded to trial, where the jury deliberated but the district court dismissed the case again under Federal Rule of Civil Procedure 50, ruling that Palin had not proven actual malice by clear and convincing evidence. Despite this, the jury returned a verdict finding the defendants "not liable."The United States Court of Appeals for the Second Circuit reviewed the case and found that the district court's Rule 50 ruling improperly intruded on the jury's role by making credibility determinations and weighing evidence. The appellate court noted several trial errors, including the exclusion of relevant evidence, an inaccurate jury instruction, and jurors learning of the district court's Rule 50 dismissal during deliberations. These issues undermined the reliability of the jury's verdict.The Second Circuit vacated the district court's Rule 50 judgment and the jury's verdict, remanding the case for a new trial. The appellate court emphasized the importance of the jury's role in determining credibility and weighing evidence, and found that the errors at trial necessitated a retrial. View "Palin v. New York Times Co." on Justia Law

Plaintiffs Moses Lugo and Cheryl Seaton, who use motorized wheelchairs, sued the City of Troy, New York, under the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973 (RA). They alleged that the city failed to maintain accessible pedestrian pathways. After discovery, Plaintiffs moved for summary judgment, while the City of Troy moved to dismiss the complaint for lack of standing or, alternatively, for summary judgment. The district court dismissed the complaint, finding the factual allegations insufficient to establish standing, without considering the full summary-judgment record.The United States District Court for the Northern District of New York dismissed the complaint based on the pleadings, concluding that the allegations were too generic to establish standing for city-wide remedies and that the specific obstacles mentioned had been remedied, thus mooting those claims. The court did not evaluate whether the evidence from discovery could establish standing.The United States Court of Appeals for the Second Circuit reviewed the case. The appellate court found that the district court erred by resolving the standing issue based solely on the pleadings rather than the full summary-judgment record. The appellate court held that the district court should have considered the evidence developed during discovery to determine whether Plaintiffs had standing. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings, instructing the lower court to evaluate the standing issue based on the complete evidentiary record and to determine if summary judgment is warranted or if Plaintiffs should be allowed to amend their complaint. View "Lugo v. The City of Troy, New York" on Justia Law

Samuel Boima, a native of Sierra Leone, was charged with assaulting federal officers at the Buffalo Federal Detention Facility while awaiting deportation. The incident involved Boima spitting a mixture of saliva and blood on the officers. Following his arrest, Boima exhibited uncooperative and erratic behavior, leading to a court-ordered psychological evaluation. Dr. Kari Schlessinger diagnosed Boima with a psychotic disorder, concluding he was incompetent to stand trial. Boima was subsequently committed to the Federal Medical Center in Butner, North Carolina, for further evaluation.The United States District Court for the Western District of New York found Boima incompetent to stand trial and ordered his hospitalization. Dr. Kristina P. Lloyd and Dr. Charles Cloutier at FMC Butner diagnosed Boima with schizophrenia and recommended antipsychotic medication to restore his competency. The government moved for a Sell hearing to authorize involuntary medication. The district court granted the motion but did not address whether the government had an important interest in prosecuting Boima, a necessary finding under Sell v. United States.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court's order authorizing forced medication, noting the lower court's failure to consider whether important governmental interests were at stake, as required by Sell. The appellate court remanded the case for further proceedings to determine if the government’s interest in prosecuting Boima justified involuntary medication, considering factors such as the seriousness of the crime, potential civil commitment, and the time Boima had already spent in custody. View "United States v. Boima" on Justia Law