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

Scott Lupia, a locomotive engineer for New Jersey Transit Rail Operations, Inc. (NJT), was injured when the air conditioning (A/C) unit in his cab malfunctioned, causing the temperature to rise to 114 degrees Fahrenheit. Despite notifying his supervisors, Lupia was instructed to operate the train, leading to his collapse from heat exhaustion and subsequent permanent injuries. Lupia filed a lawsuit under the Federal Employers’ Liability Act (FELA), alleging that NJT violated the Locomotive Inspection Act (LIA) by failing to maintain the locomotive's parts and appurtenances, including the A/C unit, in safe operating condition.The United States District Court for the Southern District of New York denied NJT's motion for summary judgment, holding that a temperature control system, including an A/C unit, is considered a "part and appurtenance" of a locomotive under the LIA. The court found sufficient evidence that NJT's failure to maintain the A/C unit in proper condition posed an unnecessary danger of personal injury. During the trial, the court allowed Lupia to introduce a report to impeach NJT’s witness and permitted arguments regarding noneconomic damages. The jury awarded Lupia significant damages for lost earnings and pain and suffering.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the District Court's judgment. The appellate court agreed that a temperature control system is an integral part of a locomotive and that NJT was required to maintain the A/C unit in safe operating condition once it chose to use it as part of its temperature control system. The court also found no abuse of discretion in the District Court's evidentiary rulings and its decision to allow arguments on noneconomic damages. View "Lupia v. New Jersey Transit Rail Operations, Inc." on Justia Law

Carlos Martinez, a former federal prison guard, was convicted of multiple charges related to the repeated rape of an inmate, referred to as "Maria," at the Metropolitan Detention Center in Brooklyn, New York. Maria testified that Martinez raped her on five occasions, using both physical force and threats to coerce her. The jury found Martinez guilty of several counts, including sexual abuse by threats or fear, deprivation of civil rights, and aggravated sexual abuse for one of the rapes.The United States District Court for the Eastern District of New York sentenced Martinez to ten years in prison. Martinez challenged the sufficiency of the evidence for two counts, arguing that the jury's acquittals on other counts indicated they did not believe Maria's testimony. The government cross-appealed, arguing that the ten-year sentence was procedurally and substantively unreasonable.The United States Court of Appeals for the Second Circuit reviewed the case. The court rejected Martinez's sufficiency challenge, affirming that the jury was entitled to credit Maria's testimony that Martinez physically restrained her during one of the rapes. The court also noted that inconsistent verdicts do not undermine a conviction.The court found the district court's sentence procedurally unreasonable due to several errors: relying on clearly erroneous factual findings, misapprehending the law, and failing to sentence Martinez based on all his convictions. The district court had improperly treated the convictions for sexual abuse by threats or fear as equivalent to sexual abuse of a ward, and it had given undue weight to its doubts about the jury's guilty verdicts.The Second Circuit held that the ten-year sentence was also substantively unreasonable because it did not adequately reflect the seriousness of Martinez's offenses. The court affirmed the judgment of conviction, ordered that a specific paragraph in the Presentence Investigation Report be stricken, and remanded the case for resentencing consistent with its opinion. View "United States v. Martinez" on Justia Law

In December 2020, Steve Rosado was arrested after attempting to meet with a woman he believed to be the mother of two young girls, with the intent to engage in illegal sexual activity. The woman was actually an undercover law enforcement agent. Rosado, a registered sex offender with prior convictions involving minors, was charged with attempted enticement of a minor and attempted receipt of child pornography. He pled guilty to both charges.The United States District Court for the Southern District of New York sentenced Rosado to 240 months in prison, followed by a lifetime of supervised release. During sentencing, the court orally pronounced several conditions of supervised release. However, the written judgment included additional conditions that were not mentioned during the oral pronouncement. Rosado appealed, arguing that these additional conditions should have been pronounced at sentencing.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that the district court had failed to pronounce the seven additional conditions at sentencing, as required by Federal Rule of Criminal Procedure 43(a). The appellate court held that the oral pronouncement of the sentence controls over the written judgment. Consequently, the court vacated the written judgment and remanded the case to the district court with instructions to remove the unpronounced conditions from the written judgment. The appellate court affirmed the district court’s judgment on other challenges raised by Rosado in a concurrently issued summary order. View "United States of America v. Rosado" on Justia Law

George Moses was convicted of mail and wire fraud, money laundering, lying to the FBI, and other charges for defrauding two nonprofit community organizations he led. He used funds from these organizations for personal expenses, including a timeshare, cruise tickets, and other personal items. Moses was sentenced to 78 months of imprisonment.The United States District Court for the Western District of New York (Wolford, C.J.) handled the initial trial. Moses was convicted on 28 counts, but he appealed 14 of these counts. He argued that the district court improperly excluded a document he claimed was his employment contract, gave erroneous jury instructions, and that the evidence was insufficient for his convictions. He also claimed procedural errors at sentencing.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that the district court did not abuse its discretion in excluding the employment contract because Moses failed to authenticate it. The jury instructions were deemed proper, including those on fraud by omission and the lack of a need for a specific instruction on ratification by an authorized agent. The appellate court also found sufficient evidence to support Moses's convictions on the challenged counts, including detailed schemes of fraud and misuse of funds.The Second Circuit affirmed the district court's judgment, rejecting all of Moses's arguments on appeal. The court upheld the 78-month sentence, finding no procedural errors in the district court's sentencing process. View "United States v. Moses" on Justia Law

In the early hours of August 21, 2017, the M/V ALNIC, a Liberian-flagged oil-and-chemical tanker, collided with the U.S.S. JOHN S. MCCAIN, a Navy destroyer, in the Singapore Strait. The collision resulted in the deaths of ten Navy sailors and injuries to dozens more. Both vessels sustained significant damage. Energetic Tank, Inc., the owner of ALNIC, sought exoneration from or limitation of liability for the collision. Forty-one Navy sailors or their representatives, along with the United States, filed claims for damages against Energetic. Energetic counterclaimed against the United States. The parties agreed on the monetary value of the damages to ALNIC and MCCAIN as $442,445 and $185 million, respectively.The United States District Court for the Southern District of New York concluded that Singapore law would govern the determination of liability and the calculation of damages. After a Phase 1 bench trial, the district court denied Energetic’s petition for exoneration or limitation of liability, allocating 80% of the fault to the United States and 20% to Energetic. The court indicated it would proceed to a Phase 2 trial to determine damages to the Sailor-Claimants. Energetic appealed, and while the appeal was pending, the district court dismissed Energetic’s claims for contribution or indemnity against the United States for any damages awarded to the Sailor-Claimants, citing sovereign immunity. Energetic also appealed this order. The district court retroactively certified its earlier opinion on the apportionment of liability as a final judgment as to the United States. Several Sailor-Claimants cross-appealed, challenging the application of Singapore law to the calculation of damages.The United States Court of Appeals for the Second Circuit found no error in the district court’s apportionment of liability under Singapore law or its sovereign immunity ruling, affirming the district court’s judgment and order on Energetic’s appeals. However, the court dismissed the Sailor-Claimants’ cross-appeals for lack of jurisdiction, as the choice-of-law ruling was a non-appealable collateral order. View "In the Matter of Energetic Tank, Inc." on Justia Law

Windward Bora LLC purchased a junior promissory note signed by Constance and Royston Browne, secured by a junior mortgage on real property. Windward's predecessor had already obtained a final judgment of foreclosure on the junior mortgage. Without seeking leave from the court that issued the foreclosure, Windward filed a diversity action to recover on the promissory note. Both parties moved for summary judgment.The United States District Court for the Southern District of New York granted the Brownes' motion for summary judgment and denied Windward's. The court found diversity jurisdiction by comparing the national citizenship of the Brownes with that of Windward’s sole member, a U.S. lawful permanent resident, and concluded that state domiciles were irrelevant. It also held that the suit was precluded by New York’s election-of-remedies statute because Windward did not seek leave before suing on the note after its predecessor had already sued on the mortgage. The court found no special circumstances to excuse Windward’s failure.The United States Court of Appeals for the Second Circuit reviewed the case. It agreed with the district court that diversity jurisdiction was present but clarified that the state domiciles of the parties were relevant. The court resolved a divide among district courts, stating that there is no diversity jurisdiction in a suit between U.S. citizens and unincorporated associations with lawful permanent resident members if such jurisdiction would not exist in a suit between the same U.S. citizens and those permanent resident members as individuals. The court also affirmed the district court’s decision to grant summary judgment for the Brownes under New York’s election-of-remedies statute, finding no special circumstances to excuse Windward’s failure to seek leave. The judgment of the district court was affirmed. View "Bora v. Browne" on Justia Law

Neu Cloud, a joint venture between IBM, TeamSun, and Zhuangyan Hao, alleged that IBM misappropriated its trade secrets. Neu Cloud claimed that IBM used confidential customer information, obtained through special bids submitted by Neu Cloud, to benefit a competing joint venture, INSPUR Power. This alleged misappropriation occurred between 2015 and 2018, leading to a significant decline in Neu Cloud's business.Neu Cloud initially filed a lawsuit in New York state court, asserting state-law claims such as unfair competition and breach of contract. The New York Supreme Court dismissed the state complaint on various grounds, including timeliness and lack of personal jurisdiction over IBM China. Shortly after, Neu Cloud filed a federal lawsuit in the United States District Court for the Southern District of New York, asserting a single cause of action under the Defend Trade Secrets Act (DTSA). The district court dismissed the federal complaint, ruling that the DTSA claim was both untimely and inadequately pleaded, and that there was no personal jurisdiction over IBM China.On appeal, the United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's dismissal, but on the alternative ground of res judicata. The Second Circuit held that the New York Supreme Court's prior judgment barred Neu Cloud from asserting its DTSA claim in federal court. The court concluded that the state and federal claims arose from the same series of transactions and that the state court was competent to adjudicate the DTSA claim. Therefore, the judgment of the district court was affirmed on the basis of res judicata. View "Beijing Neu Cloud v. IBM Corp." on Justia Law

Laurie Weinlein was convicted of bank fraud and embezzlement from an employee benefit plan, resulting in a sentence of sixty-three months in prison, five years of supervised release, and over $2 million in restitution payments. The crimes were committed in 1994 and 1995. At that time, the Victim and Witness Protection Act (VWPA) stipulated that restitution obligations terminated twenty years from the date of judgment. In 1996, the Mandatory Victims Restitution Act (MVRA) extended the enforcement period for restitution orders. In 2021, Weinlein moved to terminate her restitution obligation, arguing that the VWPA’s enforcement period had expired and that applying the MVRA retroactively violated the Ex Post Facto Clause of the Constitution.The United States District Court for the Northern District of New York denied Weinlein’s motion to terminate her restitution obligation. The court held that retroactive application of the MVRA’s enforcement period did not violate the Ex Post Facto Clause. Weinlein then appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The court held that retroactively applying the MVRA’s longer enforcement period did not violate the Ex Post Facto Clause. The court reasoned that the MVRA did not increase the punishment for Weinlein’s crime but merely extended the time period over which the government could collect the restitution. The court concluded that the punishment imposed by the restitution order remained the same, and the extension of the enforcement period did not constitute a greater punishment than what was originally imposed. View "United States v. Weinlein" on Justia Law

The case involves nine lawsuits filed in Connecticut state court, each asserting state-law personal injury claims related to the use of Zantac. The plaintiffs, represented by the same firm, structured their complaints to avoid federal jurisdiction by including fewer than 100 plaintiffs per suit and ensuring that each suit included a Connecticut plaintiff. The plaintiffs filed a motion to consolidate these actions, citing Connecticut Practice Book § 9-5, which the defendants argued proposed a joint trial, thus triggering federal jurisdiction under the Class Action Fairness Act (CAFA).The United States District Court for the District of Connecticut remanded the cases to state court, finding that the plaintiffs' motion to consolidate was intended only for pretrial purposes, not for a joint trial. The district court noted that the plaintiffs' motion cited authority that could be used for either pretrial management or a joint trial but concluded that the context indicated a pretrial purpose, especially given the plaintiffs' efforts to avoid federal jurisdiction.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court held that CAFA requires a determination of whether the plaintiffs intended to seek a joint trial. The court found that the plaintiffs' motion, when read in context, proposed only pretrial consolidation. The court emphasized that the plaintiffs' consistent efforts to avoid federal jurisdiction supported this interpretation. Thus, the appellate court concluded that the defendants did not meet their burden to demonstrate that federal jurisdiction existed under CAFA. View "Bacher v. Boehringer Ingelheim Pharmaceuticals, Inc." on Justia Law

T.W., a Harvard Law School graduate with disabilities, sued the New York State Board of Law Examiners for denying her requested accommodations on the New York State bar exam in 2013 and 2014. She alleged violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. T.W. claimed that the Board's actions caused her to fail the bar exam twice, resulting in professional and financial harm.The United States District Court for the Eastern District of New York initially denied the Board's motion to dismiss, finding that the Board had waived its sovereign immunity under the Rehabilitation Act. However, the United States Court of Appeals for the Second Circuit reversed this decision, holding that the Board was immune from suit under Section 504. On remand, the district court granted the Board's motion to dismiss T.W.'s Title II claim, ruling that the Board was an "arm of the state" and entitled to sovereign immunity. The court also held that Title II did not abrogate the Board's sovereign immunity for money damages and that T.W. could not seek declaratory and injunctive relief under Ex parte Young.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the Board is an arm of the state and thus entitled to sovereign immunity. It further concluded that Title II of the ADA does not validly abrogate sovereign immunity in the context of professional licensing. Additionally, the court found that the declaratory relief sought by T.W. was retrospective and therefore barred by the Eleventh Amendment. The court also ruled that the injunctive relief sought by T.W. was not sufficiently tied to an ongoing violation of federal law, making it unavailable under Ex parte Young. Consequently, the court affirmed the dismissal of T.W.'s claims for compensatory, declaratory, and injunctive relief. View "T.W. v. New York State Board of Law Examiners" on Justia Law