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

John Wilson, the plaintiff-appellant, made several requests under the Freedom of Information Act (FOIA) to the Federal Bureau of Investigation (FBI), the defendant-appellee, to release records concerning him. Dissatisfied with the FBI's response, Wilson filed a suit in the Southern District of New York, alleging that the FBI failed to conduct an adequate search. The District Court ruled in favor of Wilson, partially granting his motion for summary judgment by ordering the FBI to conduct a search of an additional database. However, the search did not yield any new disclosures to Wilson. Subsequently, Wilson filed a motion seeking attorneys’ fees and costs under FOIA's fee-shifting provision, arguing that he was a substantially prevailing party. The District Court denied his motion, applying the criteria set by the United States Court of Appeals for the Second Circuit in a previous case, Pietrangelo v. United States Army. Wilson appealed this decision.On appeal, the Second Circuit Court affirmed the decision of the District Court, concluding that the District Court correctly applied the Pietrangelo factors and did not abuse its discretion in ruling that those factors weighed against an award of attorneys’ fees and costs. The Second Circuit Court found that the public benefit derived from Wilson's case was minimal, Wilson's interest in the records was personal rather than public, and the FBI had a reasonable basis for withholding the requested information. As such, it concluded that the District Court did not err in denying Wilson's motion for attorneys’ fees and costs. View "Wilson v. Federal Bureau of Investigation" on Justia Law

The United States Court of Appeals for the Second Circuit addressed a dispute involving the Triborough Bridge and Tunnel Authority (TBTA) and several plaintiffs who had been fined for failing to pay tolls at TBTA crossings. The plaintiffs claimed that the fines were unconstitutional under the Eight Amendment’s Excessive Fines Clause and that TBTA was unjustly enriched under New York law. The court considered the case on appeal from the United States District Court for the Southern District of New York, which had granted summary judgment in favor of TBTA. The Court of Appeals affirmed the lower court's decision.The plaintiffs had failed to pay their tolls for various reasons, such as receiving bills at old addresses or having malfunctioning transponders. They then received substantial fines, which they eventually paid at reduced amounts. The main issue was whether these fines were excessive in relation to the seriousness of the offenses. The court applied the four-factor test from United States v. Bajakajian, which considers the nature of the offense, whether the defendant fits into the class of persons the law was designed for, the maximum potential sentence and fine, and the harm caused by the defendant's conduct.The court found that the fines were not excessive. It pointed out that the plaintiffs' violations were not willful or fraudulent, and that the fines were in line with those for similar offenses in other states. The court also noted that the fines helped TBTA prevent the harms it would suffer if people did not pay their tolls.Regarding the unjust enrichment claim, the court concluded that the plaintiffs had not shown that it was inequitable for TBTA to retain the fines. The plaintiffs' non-payment of tolls had violated TBTA regulations, and it was not inequitable for such violations to result in fines. Therefore, the court affirmed the lower court's grant of summary judgment in favor of TBTA on the unjust enrichment claims as well. View "Reese v. Triborough Bridge and Tunnel Authority" on Justia Law

In this case, the plaintiff, William Loomis, a truck driver who was injured in a car accident in New York, sought recovery from his employer's insurance company, ACE American Insurance Company, for his remaining damages after the underinsured driver's insurer paid out their policy limit. Loomis claimed that ACE failed to comply with both New York and Indiana laws requiring an insurer to provide underinsured motorist coverage.The United States Court of Appeals for the Second Circuit had to determine whether New York's laws requiring insurers to offer optional supplemental uninsured/underinsured motorist coverage could make an insurer liable when it fails to offer this coverage, and whether Indiana law requires an insurer to provide underinsured motorist coverage when the insured suffers damages in excess of the tortfeasor’s policy limit and has no other underinsured motorist coverage to cover damages up to a certain limit.The court concluded that under New York law, Loomis was not entitled to relief. While insurers are required to offer supplemental uninsured/underinsured motorist coverage in New York, this coverage is optional. Even if ACE violated New York law by failing to offer this coverage, Loomis's claim seeking to reform the insurance contract to include this coverage was not supported by New York law. Therefore, the court affirmed the lower court's grant of summary judgment on this claim.In terms of the claim under Indiana law, the court could not confidently predict how the Indiana Supreme Court would interpret the relevant statute, and therefore, certified questions to the Indiana Supreme Court. View "Loomis v. ACE American Insurance Company" on Justia Law

The United States Court of Appeals for the Second Circuit has decided an appeal from The Resource Group International Limited, TRG Pakistan Limited, Mohammed Khaishgi, and Hasnain Aslam against Muhammad Ziaullah Khan Chishti. The appellants sought to avoid arbitration proceedings initiated by the appellee, arguing that a later-executed release agreement superseded the arbitration agreement in the original Stock Purchase Agreement. The appellants also sought a preliminary injunction to halt the ongoing arbitration, but the District Court denied their request, asserting that they failed to show a likelihood of success on their claims and that they would suffer irreparable harm without the injunction.On appeal, the Circuit Court held that it had jurisdiction over the case, finding that the parties had chosen New York law to govern the arbitration proceedings, thereby bypassing the restrictions on appellate review under the Federal Arbitration Act. The court also held that the District Court had relied on an erroneous view of the law in concluding that the appellants failed to show a likelihood of success on the merits of their claims and that they would suffer irreparable harm. The court found that the release agreement, which contained a forum selection clause, superseded the Stock Purchase Agreement's arbitration clause. The court also clarified that being forced to arbitrate a non-arbitrable claim could constitute irreparable harm, particularly where attorneys' fees and arbitration costs could not adequately compensate the harm.As a result, the court vacated the District Court's decision and remanded the case for further proceedings. View "The Resource Group International Limited v. Chishti" on Justia Law

In the dispute between fashion designer and social media influencer Hayley Paige Gutman and her former employer, JLM Couture, Inc., the United States Court of Appeals for the Second Circuit considered the preliminary injunction and contempt order issued by the United States District Court for the Southern District of New York. The lower court had awarded JLM control of two social media accounts previously managed by Gutman and enforced a five-year restrictive covenant that prohibited Gutman from identifying herself as a designer of certain goods. The court also held Gutman in civil contempt for posts on Instagram that it deemed as marketing, violating an earlier version of the preliminary injunction.The Court of Appeals dismissed Gutman's appeal from the contempt order due to lack of appellate jurisdiction. It affirmed the district court's refusal to dissolve the preliminary injunction based on the law of the case. However, the Court of Appeals vacated the district court’s order that modified its preliminary injunction. The court found fault in the lower court's determination of the ownership of the disputed social media accounts and its failure to evaluate the reasonableness of the five-year noncompete restraint on Gutman. The case was remanded for further proceedings consistent with the opinion of the Court of Appeals. View "JLM Couture, Inc. v. Gutman" on Justia Law

In the case involving the Restaurant Law Center and the New York State Restaurant Association against the City of New York and the Commissioner of the City’s Department of Consumer and Worker Protection, the plaintiffs challenged a New York City law prohibiting the wrongful discharge of fast-food restaurant employees. The plaintiffs argued that the law was preempted by federal law and violated the dormant Commerce Clause of the United States Constitution.The United States Court of Appeals for the Second Circuit affirmed the decision of the United States District Court for the Southern District of New York, which had granted the defendants’ motions for summary judgment. The appellate court concluded that the city's Wrongful Discharge Law did not violate federal law nor the United States Constitution.The court held that New York’s Wrongful Discharge Law was not preempted by the National Labor Relations Act (NLRA) because it established minimum labor standards that regulated the substance, rather than the process, of labor negotiations. The court also held that the law did not violate the dormant Commerce Clause of the U.S. Constitution, which acts as a safeguard against economic protectionism. The court found that the law did not discriminate against interstate commerce either on its face, in its purpose, or in its practical effect. View "Restaurant Law Center v. City of New York" on Justia Law

Plaintiff Joseph Kasiotis filed a class action lawsuit on behalf of himself and other similarly situated New York consumers against the New York Black Car Operators’ Injury Compensation Fund, Inc. (the “Fund”). The lawsuit alleged that the Fund improperly collected a surcharge on noncash tips paid by passengers to drivers providing livery or “black car” services from January 2000 until February 1, 2021. The United States District Court for the Southern District of New York ruled in favor of Kasiotis and the class, granting summary judgment on the unjust enrichment claim. On appeal, the United States Court of Appeals for the Second Circuit held that the Fund was statutorily permitted to collect a surcharge on noncash tips. The court's ruling was based on Article 6-F of the New York Executive Law, which unambiguously authorizes the Fund to impose a surcharge on noncash tips paid in connection with covered black car services. As such, the Second Circuit Court reversed the district court's order granting summary judgment in favor of Kasiotis and the class, and remanded the case with instructions to dismiss the unjust enrichment claim. View "Kasiotis v. N.Y. Black Car Operators' Inj. Comp. Fund, Inc." on Justia Law

In the case of Veronica-May Clark, an incarcerated transgender woman, against corrections officers who allegedly sexually assaulted her, the United States Court of Appeals for the Second Circuit affirmed the decision of the United States District Court for the District of Connecticut. The District Court had dismissed Clark's case as untimely, denying her claim for equitable tolling of the statute of limitations due to the effects of the abuse. The Court of Appeals found that the District Court did not err in holding an evidentiary hearing to resolve Clark’s equitable tolling claim and did not make any factual findings that infringed the Seventh Amendment. The court also found no abuse of discretion in the District Court's determination that Clark had failed to demonstrate circumstances that would warrant equitable tolling. In effect, the court ruled that Clark had not sufficiently proven that her trauma and fear of retaliation prevented her from filing the lawsuit within the required time frame. View "Clark v. Hanley" on Justia Law

In a putative securities-fraud class action, Union Asset Management Holding AG and Teamsters Local 710 Pension Fund (the “Investors”), co-lead plaintiffs, alleged that Philip Morris International Inc. (“PMI”) and several of its current and former executives (the “Defendants”) made false and misleading statements about PMI’s “IQOS” smoke-free tobacco products. The United States Court of Appeals for the Second Circuit affirmed the district court's dismissal of the Investors' complaints. The court found that PMI's statements about its scientific studies complied with a methodological standard and were properly analyzed as statements of opinion, rather than fact. The court also determined that the Defendants' interpretation of scientific data, which was ultimately endorsed by the Food and Drug Administration (FDA), was per se reasonable as a matter of law. Further, the court held that the Investors had either failed to plead material falsity or abandoned their challenges on appeal regarding PMI’s statements about its projections for IQOS’s performance in Japanese markets. Finally, the court concluded that the Investors' claim for control-person liability under section 20(a) of the Exchange Act also failed because they had not established a primary violation by the controlled person. View "In re Philip Morris Int'l Inc. Sec. Litig." on Justia Law

The United States Court of Appeals for the Second Circuit dismissed an interlocutory appeal from the City of New Haven and three of its police officers (collectively, "the City"), who sought to challenge the district court's denial of their motion for summary judgment on the claims of Solomon Maye. Maye alleged that the City violated his constitutional rights by evicting him from his place of business. The district court had denied the City's motion for summary judgment, which was based on the defense of qualified immunity, because the motion was filed more than six months after the court's deadline for dispositive motions. The Court of Appeals held that a district court's denial of a motion for summary judgment as untimely is not a "denial of a claim of qualified immunity" that turns on an issue of law and is thus not subject to immediate appeal under the collateral order doctrine. Consequently, the Court of Appeals found no jurisdiction to hear the City's interlocutory appeal and dismissed it. View "Maye v. City of New Haven" on Justia Law