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

In this case, the United States Court of Appeals for the Second Circuit heard an appeal from Ezrasons, Inc., a company engaged in the garment trade, against The Travelers Indemnity Company. Ezrasons suffered a loss of insured goods exceeding $600,000 due to a fire at a warehouse owned by Chamad Warehouse, Inc., in Marion, North Carolina. Travelers paid $250,000, but declined to pay more, asserting that the policy's coverage was limited to $250,000 because the warehouse where the goods were destroyed was not an "Approved Location" under the policy. The district court ruled in favor of Travelers, finding that the warehouse was unambiguously not an "Approved Location" under the policy.On appeal, the Second Circuit Court found that the policy was ambiguous as to whether the warehouse where the destruction occurred was an "Approved Location." It further held that the district court erroneously excluded admissible evidence by which Ezrasons sought to prove that the warehouse was an "Approved Location." As the extrinsic evidence did not provide a basis for favoring either possible meaning of "Approved Location," the ambiguity should be resolved in favor of Ezrasons under New York law. Accordingly, the judgment was vacated and the case remanded with instructions to enter judgment in favor of Ezrasons. View "Ezrasons, Inc. v. Travelers Indemnity Co." on Justia Law

The United States Court of Appeals for the Second Circuit considered an appeal from a judgment of the United States District Court for the Southern District of New York, which dismissed a plaintiff's 2019 complaint against art dealers for fraud, negligent misrepresentation, breach of warranty, and rescission in connection with his 2001 purchase of an allegedly forged painting. The district court dismissed the plaintiff's claims as time-barred and ruled that the plaintiff's fraud claim could not be granted relief. The plaintiff appealed, arguing that the district court erred in concluding that he was on inquiry notice of the alleged fraud before bringing the suit. The appellate court agreed with the district court that claims for breach of warranty, negligent misrepresentation, and rescission were time-barred under New York law. However, the court concluded that the district court erred in ruling that the fraud claims were time-barred and in denying the plaintiff's request for leave to amend his complaint. The case was affirmed in part, vacated in part, and remanded for further proceedings. View "Meyer v. Seidel" on Justia Law

In 2011, Veronica-May Clark, an incarcerated transgender woman, was repeatedly sexually assaulted by corrections officer Thomas Hanley. More than seven years after the abuse, Clark filed a lawsuit against Hanley and other officers, alleging violations of her Eighth Amendment rights and seeking equitable tolling of the statute of limitations due to the traumatic effects of the abuse. After holding an evidentiary hearing on the issue of equitable tolling, the United States District Court for the District of Connecticut (Meyer, J.) denied Clark's claim for equitable tolling and dismissed her case as untimely. Clark appealed, claiming that the court improperly conducted factfinding at the pleading stage and violated her Seventh Amendment rights. The United States Court of Appeals for the Second Circuit affirmed the district court's ruling, finding that the court properly resolved Clark's equitable tolling claim and did not infringe her Seventh Amendment rights. View "Clark v. Hanley" on Justia Law

The United States Court of Appeals for the Second Circuit ruled that a group of non-transgender female athletes have legal standing to challenge a policy that allows transgender girls to compete in girls' high school sports. The athletes had sued the Connecticut Association of Schools and several school districts, claiming that the policy violated Title IX by depriving them of equal athletic opportunity. The court held that the athletes had established Article III standing because they had plausibly stated a concrete, particularized, and actual injury in fact - the alleged denial of equal athletic opportunity and concomitant loss of publicly recognized titles and placements during track and field competitions in which they competed against and finished behind transgender athletes. The court also held that the injury was plausibly redressable by monetary damages and an injunction ordering defendants to alter certain athletic records. The court did not rule on the merits of the athletes' Title IX claim, instead remanding the case to the district court for consideration of whether the athletes have plausibly stated a claim under Title IX. View "Soule ex rel. Stanescu v. Connecticut Association of Schools, Inc." on Justia Law

In the case under review, the plaintiff, Antonio Martinez, acting as executor of the estate of Naomi Gonzales, filed a lawsuit against Agway Energy Services, LLC, alleging breach of contract and violations of New York General Business Law. The case arose from a contract Gonzales had with Agway, an energy supply company, which provided her with a one-month promotional rate and subsequently a variable monthly rate. Gonzales maintained this contract for about two years. After canceling the agreement, she sued Agway, alleging that its monthly variable rate was consistently higher than that charged by the local utility and that Agway had breached its agreement by failing to charge competitive rates and by charging customers for the cost of an included service, EnergyGuard.The United States Court of Appeals for the Second Circuit concluded that Agway had fulfilled the terms of the contract. The court held that the contract language allowed Agway to exercise its discretion to set a variable monthly rate based on several factors, including its costs, expenses, and margins, and that the company was entitled to include the cost of providing the EnergyGuard service in its monthly variable rate. Gonzales' argument that Agway had promised to provide competitive rates was found to be unsupported by the contract's language. The court, therefore, affirmed the district court's decision to grant summary judgment in favor of Agway. View "Martinez v. Agway Energy Services, LLC" on Justia Law

In a defamation lawsuit brought by E. Jean Carroll against former President Donald Trump, the United States Court of Appeals for the Second Circuit ruled that presidential immunity can be waived and that Trump had waived his presidential immunity by failing to raise it as an affirmative defense in his original response to Carroll's complaint. Carroll sued Trump for defamation after he publicly denied her accusation of sexual assault in the mid-1990s. The court affirmed the lower court's decision to deny Trump's motion for summary judgment and his request to amend his answer to include presidential immunity as a defense. The court also upheld the lower court's decision to strike Trump's presidential immunity defense from his answer to Carroll's amended complaint. The case was remanded back to the lower court for further proceedings. View "Carroll v. Trump" on Justia Law

In this case, a joint venture between Watershed Ventures, LLC and Patrick M. McGrath failed, leading to bankruptcy and litigation. McGrath and two investment vehicles he controlled sought coverage from Watershed's insurer, Scottsdale Insurance Company, under a directors and officers liability policy. Scottsdale denied coverage and sought a declaratory judgment as to its coverage obligations. McGrath countered with claims against Scottsdale and third-party claims against Watershed. The district court issued two summary judgment decisions. The first ruled that McGrath is an insured under the policy, while the second dismissed one of McGrath's counterclaims. The parties agreed to a "Stipulated Conditional Final Judgment Subject to Reservation of Rights of Appeal," which would become void if either of the district court’s two summary judgment rulings were partly vacated or reversed on appeal. The parties appealed, but the U.S. Court of Appeals for the Second Circuit dismissed both Scottsdale's appeal and McGrath's cross-appeal for lack of appellate jurisdiction, concluding that the Stipulated Conditional Final Judgment was not a "final decision" under 28 U.S.C. § 1291. The court reasoned that the Stipulated Conditional Final Judgment did not resolve all claims of all parties, was not entered under Federal Rule of Civil Procedure 54(b), and did not finally resolve whether Scottsdale breached its duty to defend under the policy. View "Scottsdale Ins. Co. v. McGrath" on Justia Law

In Carpenter v. Allen, the United States Court of Appeals for the Second Circuit examined a case involving a dispute over the return of seized property following the completion of a criminal case. The plaintiff, Grist Mill Capital LLC ("GMC"), filed a motion for return of property under Federal Rule of Criminal Procedure 41(g) against the government. The property in question consisted of financial documents seized by the Department of Labor during a criminal investigation and prosecution of Daniel E. Carpenter.The district court granted GMC's motion in part, ruling that the government failed to demonstrate a need to keep the seized materials given that Carpenter's criminal conviction had been affirmed and his petition for certiorari denied by the Supreme Court. The district court ordered the government to destroy the materials rather than return them to GMC, citing the presence of third parties' personal identifying information used by Carpenter in his fraudulent scheme.The government appealed the district court's order, arguing that it needed to retain the materials due to Carpenter's pending collateral attack on his criminal convictions. The Second Circuit vacated the district court's order, finding that the government had demonstrated a legitimate need to retain the property to defend against Carpenter's pending Section 2255 motion and to preserve evidence for a potential retrial if the motion succeeded. The court remanded the case for further proceedings consistent with its opinion and dismissed GMC's cross-appeal as moot. View "Carpenter v. Allen" on Justia Law

In the case before the United States Court of Appeals for the Second Circuit, Ateres Bais Yaakov Academy of Rockland (ABY) sued the Town of Clarkstown, George Hoehmann, CUPON Inc., and Citizens United to Protect Our Neighborhoods of Greater Nanuet Inc. ABY, a religious educational institution, planned to purchase property in Clarkstown, New York, to establish an Orthodox Jewish school. It alleged that the Defendants manipulated an ostensibly neutral building permit application and zoning appeals process to block this construction. The district court dismissed the complaint for lack of subject matter jurisdiction, concluding that ABY's religious discrimination and civil rights claims were not ripe as it had not received a final decision from the town’s Zoning Board of Appeals (ZBA) and that the lost-contract injury underpinning ABY’s tortious interference claim was not traceable to the Town Defendants.In this appeal, the Second Circuit disagreed with the district court. The Second Circuit found that the ZBA's refusal to adjudicate ABY's appeal of its permit application constituted a final decision for ripeness purposes. The court also determined that ABY had plausibly alleged a causal connection between the Town Defendants’ actions and the injuries resulting from ABY's lost contract with Grace Church. Therefore, the Second Circuit reversed the district court's judgment and remanded the case for further proceedings. View "Ateres Bais Yaakov Academy of Rockland v. Town of Clarkstoawn" on Justia Law

In a class action suit brought by George Mandala and Charles Barnett against NTT Data, Inc., the plaintiffs argued that NTT's policy of not hiring individuals with a felony conviction disproportionately impacted Black applicants, constituting disparate impact discrimination under Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed the plaintiffs' complaint, and that decision was affirmed by the United States Court of Appeals for the Second Circuit. The plaintiffs then filed a motion to vacate the dismissal judgment and sought leave to file a first amended complaint, which the district court denied as untimely under Federal Rule of Civil Procedure 60(b)(1).On appeal, the Second Circuit reversed the district court's decision, holding that the plaintiffs' motion should have been evaluated under Rule 60(b)(6) rather than Rule 60(b)(1). Rule 60(b)(6) allows for relief from a judgment under "extraordinary circumstances," which the court found to be present in this case. The court reasoned that the plaintiffs had not previously had a chance to amend their complaint, and that their decision to stand by their initial complaint was not unreasonable given that its sufficiency had been a point of dispute. Additionally, the court found that the proposed amendments to the complaint were not futile. Consequently, the Second Circuit ordered the case to be remanded to the district court for further proceedings consistent with its opinion. View "Mandala v. NTT Data, Inc." on Justia Law