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

A Turkish graduate student, Rümeysa Öztürk, was lawfully residing in Massachusetts on a student visa when she was arrested by plainclothes officers without warning on March 25, 2025. She was transported across state lines and eventually detained in Louisiana. Her counsel, unaware of her location, filed a habeas petition in the District of Massachusetts, alleging her arrest was based on an op-ed she co-authored. The petition was transferred to the District of Vermont after it was revealed she had been in Vermont during transit.The District of Vermont set a schedule for a bail hearing and to resolve the constitutional claims in the habeas petition. The court ordered the government to transfer Öztürk from Louisiana to Vermont to aid in these proceedings. The government appealed this order, seeking an emergency stay of the transfer.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the government failed to justify a stay. It determined that the District of Vermont was the proper venue for the habeas petition since Öztürk was in Vermont when the petition was filed. The court also found that the government was unlikely to succeed on its arguments that jurisdiction-stripping provisions of the Immigration and Nationality Act deprived the district court of jurisdiction over Öztürk’s detention challenge. Additionally, the court held that the government did not demonstrate irreparable injury absent a stay and that the balance of equities favored Öztürk.The Second Circuit denied the government’s motion for a stay, denied the request for a writ of mandamus, and vacated the administrative stay. The court ordered the government to comply with the district court’s transfer order within one week. View "Öztürk v. Hyde" on Justia Law

Kenneth Michael Sikorsky purchased a property in Newburgh, New York, in 2006 but fell behind on his property taxes, leading to foreclosure by the City of Newburgh in 2012. Sikorsky and the City later agreed on a contract for Sikorsky to repurchase the property, but the sale fell through when Sikorsky failed to make the required payments. The City subsequently sold the property for $350,500, significantly more than the $92,786.24 Sikorsky owed in taxes, but did not return the surplus to Sikorsky.The United States District Court for the Southern District of New York dismissed Sikorsky's pro se complaint, which alleged a constitutional taking and violations of New York state laws. Sikorsky, now represented by counsel, appealed the dismissal, arguing that he had stated a valid claim under the Takings Clause of the Fifth Amendment and that he had a right to recover under new New York state laws enacted during the appeal.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Sikorsky had indeed stated a claim for a constitutional taking against the City of Newburgh and Jeremy Kaufman. The court found that the new New York laws did not provide Sikorsky with a remedy, as they only applied to properties sold on or after May 25, 2023, or to those with active proceedings under N.Y. CPLR § 7803(1) on the effective date of the act. Since Sikorsky's property was sold in June 2021 and he had not initiated an Article 78 proceeding, he lacked a local remedy.The Second Circuit vacated the District Court's dismissal of Sikorsky's constitutional taking claims against the City of Newburgh and Jeremy Kaufman and remanded the case for further proceedings consistent with its opinion. View "Sikorsky v. City of Newburgh" on Justia Law

The plaintiff, Detrina Solomon, a subscriber to a digital video streaming service operated by Flipps Media, Inc. (doing business as FITE), alleged that her rights under the Video Privacy Protection Act (VPPA) were violated when FITE disclosed her streaming history to Facebook (now Meta Platforms, Inc.). The disclosed information included the titles and URLs of the videos she watched and her Facebook ID (FID), which is linked to her Facebook profile.The United States District Court for the Eastern District of New York dismissed Solomon's complaint under Rule 12(b)(6) of the Federal Rules of Civil Procedure, concluding that she failed to plausibly allege that FITE disclosed her personally identifiable information as defined by the VPPA. The district court also denied her leave to amend the complaint, noting that she had multiple opportunities to propose amendments but did not do so.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court adopted the "ordinary person" standard, which holds that personally identifiable information under the VPPA includes information that would allow an ordinary person to identify a consumer's video-watching habits. The court concluded that the information disclosed by FITE, consisting of video titles and FIDs, did not meet this standard because an ordinary person would not be able to use this information to identify Solomon's video-watching habits without additional effort or technological expertise.The court also found no abuse of discretion in the district court's denial of leave to amend, as Solomon's request was made only in a footnote and lacked any proposed amendments to address the deficiencies in her complaint. Thus, the judgment of the district court was affirmed. View "Solomon v. Flipps Media, Inc." on Justia Law

AMTAX Holdings 227, LLC ("AMTAX") filed a lawsuit against CohnReznick LLP ("CohnReznick") in federal court, alleging breach of fiduciary duty, professional negligence, unjust enrichment, and fraud. The dispute arose from CohnReznick's calculation of a purchase price for a property under a right of first refusal agreement, which AMTAX claimed excluded exit taxes required by Section 42 of the Internal Revenue Code. AMTAX argued that this exclusion violated the agreement and federal law.The United States District Court for the Southern District of New York dismissed AMTAX's complaint for lack of subject matter jurisdiction. The court applied the Grable-Gunn test to determine whether the state-law claims presented a substantial federal issue that would warrant federal jurisdiction. The district court concluded that AMTAX's claims did not meet the criteria for federal question jurisdiction, as they did not necessarily raise a substantial federal issue and allowing federal jurisdiction would disrupt the federal-state balance.The United States Court of Appeals for the Second Circuit reviewed the district court's decision de novo. The appellate court agreed with the lower court's application of the Grable-Gunn test, finding that AMTAX's claims were primarily based on contract interpretation rather than federal tax law. The court held that the federal issue was not substantial enough to warrant federal jurisdiction and that exercising jurisdiction would disrupt the balance of state and federal judicial responsibilities. Consequently, the Second Circuit affirmed the district court's dismissal of the case for lack of subject matter jurisdiction. View "AMTAX Holdings 227, LLC v. CohnReznick LLP" on Justia Law

The case involves the Board of Trustees of a multiemployer pension plan primarily benefitting unionized bakery drivers in New York City, which applied for Special Financial Assistance (SFA) in 2022. The Pension Benefit Guaranty Corporation (PBGC) denied the application, citing the plan's termination in 2016 as a disqualifying factor. The Fund, asserting it was in "critical and declining status," sued under the Administrative Procedure Act (APA).The United States District Court for the Eastern District of New York granted summary judgment in favor of the PBGC, agreeing that the plan's termination made it ineligible for SFA. The court also concluded that a terminated plan could not be restored under ERISA, thus affirming the PBGC's denial of the Fund's application.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the SFA statute does not exclude plans based solely on a prior termination. The court found that the statute's reference to "critical and declining status" incorporates the definition from 29 U.S.C. § 1085(b)(6) without importing limitations from other sections. Consequently, the court reversed the district court's judgment and remanded the case with instructions to enter summary judgment for the Fund, vacate the PBGC's denial of the SFA application, and remand to the PBGC for reconsideration. View "Bd. of Trs. of the Bakery Drivers Loc. 550 v. Pension Benefit Guaranty Corporation" on Justia Law

In spring 2020, Czigany Beck, a full-time student at Manhattan College, paid tuition and a comprehensive fee for the semester. Due to the COVID-19 pandemic, the college transitioned to remote learning in March 2020, and Beck received only 46% of her education in person. Beck filed a class action lawsuit against Manhattan College, claiming breach of implied contract and unjust enrichment for not refunding a portion of her tuition and fees.The United States District Court for the Southern District of New York dismissed Beck's claims. The court found that the college's statements were not specific enough to constitute a promise for in-person classes or access to on-campus facilities. The court also ruled that the comprehensive fee was nonrefundable based on the college's terms, and thus Beck's unjust enrichment claim for fees was barred. The court granted summary judgment to Manhattan College on Beck's remaining unjust enrichment claim for tuition, concluding that the college's switch to online instruction was reasonable given the pandemic.Beck appealed to the United States Court of Appeals for the Second Circuit, arguing that the district court's judgment should be reversed based on the decision in Rynasko v. New York University. Manhattan College countered with decisions from the New York Supreme Court's Appellate Division, which supported affirming the district court's judgment. The Second Circuit identified a split between federal and state courts on New York contract-law principles and certified the question to the New York Court of Appeals: whether New York law requires a specific promise to provide exclusively in-person learning to form an implied contract between a university and its students regarding tuition payments. The Second Circuit reserved decision on Beck's appeal pending the New York Court of Appeals' response. View "Beck v. Manhattan College" on Justia Law

In 2019, Xin “Chris” Gu, a protégé of Qing Ming “Allen” Yu, was shot and killed. Yu, angered by Gu's departure from his company and subsequent competition, conspired with Zhe Zhang and others to murder Gu. Yu promised Zhang business connections in exchange for his participation in the murder. Zhang, along with other conspirators, planned and executed the murder, with Zhang acting as the getaway driver. Both Yu and Zhang were charged with conspiracy to commit murder for hire and murder for hire under 18 U.S.C. § 1958(a).The United States District Court for the Eastern District of New York convicted both defendants on both counts and sentenced them to life imprisonment. The defendants appealed, arguing insufficient evidence of an agreement involving pecuniary value, a mid-trial change in the government's theory, failure to disclose exculpatory evidence, and an erroneous interpretation of the mandatory minimum sentence under section 1958(a).The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the promise of business connections constituted something of pecuniary value, thus supporting the jury's finding of guilt. The court found no basis in precedent for the defendants' claim of a due-process right against surprise by the government's theory. The court also determined that the withheld evidence was not material and did not prejudice the defendants. Finally, the court agreed with the district court that section 1958(a) imposes a mandatory minimum sentence of life imprisonment.The Second Circuit affirmed the district court's judgment, upholding the convictions and life sentences of both defendants. View "United States v. Zhang" on Justia Law

Ms. Shela Linton participated in a sit-in protest at the Vermont statehouse on January 8, 2015, against the governor's perceived lack of support for universal healthcare. When the statehouse closed at 8 p.m., law enforcement warned the demonstrators to leave or face arrest. Linton and others remained, linking arms and singing. During her arrest, Sergeant Jacob Zorn used a "rear wristlock" pain compliance technique, causing Linton to cry out in pain and suffer permanent injuries to her left wrist and shoulder. Linton later alleged that she was diagnosed with PTSD, depression, and anxiety due to the incident.The United States District Court for the District of Vermont granted summary judgment in favor of Sergeant Zorn, concluding that he was entitled to qualified immunity. The court found that no clearly established law put Zorn on notice that his actions might violate Linton's Fourth Amendment rights. Linton appealed, arguing that the district court erred in its interpretation of relevant case law and failed to view the facts in the light most favorable to her.The United States Court of Appeals for the Second Circuit reviewed the case and disagreed with the district court's decision. The appellate court held that the case Amnesty America v. Town of West Hartford clearly established that the gratuitous use of pain compliance techniques on a passively resisting protestor constitutes excessive force. The court found that genuine issues of material fact existed regarding the degree of Linton's resistance and the appropriateness of Zorn's use of force. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings to resolve these factual disputes. View "Linton v. Zorn" on Justia Law

Neysha Cruz, on behalf of her son O.F., filed a lawsuit against the New York City Department of Education (DOE) under the Individuals with Disabilities Education Act (IDEA). Cruz rejected the DOE's education plan for O.F., who has multiple disabilities, and sought reimbursement for his private school tuition. Cruz argued that the DOE's placement of O.F. in a twelve-student classroom violated a New York regulation requiring students with highly intensive management needs to be placed in classes of six or fewer students. The DOE acknowledged the regulation but argued that another regulation allowing a maximum of twelve students for those with severe multiple disabilities also applied, giving them discretion in class size placement.An Impartial Hearing Officer (IHO) initially found that the DOE offered O.F. a Free Appropriate Public Education (FAPE) but that the recommended school could not implement the IEP due to scheduling issues. The IHO ordered partial reimbursement for private tuition. The State Review Officer (SRO) reversed the IHO's finding on the school's ability to implement the IEP and concluded that the DOE provided a FAPE, thus denying reimbursement.The United States District Court for the Southern District of New York upheld the SRO's decision, agreeing that the DOE could choose between the two class size regulations. Cruz appealed to the United States Court of Appeals for the Second Circuit.The Second Circuit found that the case hinged on interpreting New York's education regulations and certified the question to the New York Court of Appeals. The court sought clarification on whether the DOE must satisfy both class size regulations or if it can choose between them when both apply to a student. The Second Circuit retained jurisdiction pending the state court's response. View "Cruz v. Banks" on Justia Law

Darrell Robinson was convicted of being a felon in possession of firearms, in violation of 18 U.S.C. § 922(g), after law enforcement officers found six firearms in his vehicle during a search. Robinson pled guilty to the charge and was sentenced to 50 months’ imprisonment and three years of supervised release. The district court also imposed a special condition of supervised release that allowed for the search of Robinson’s electronic devices upon reasonable suspicion of a violation of a condition of supervision.The United States District Court for the Eastern District of New York adopted the Presentence Investigation Report (PSR) without modification and imposed the special search condition as recommended in the PSR. Robinson did not object to the PSR or the special condition during sentencing but later moved to correct the judgment, arguing that the electronic search condition was not orally pronounced at sentencing. The district court denied the motion, finding that it had met its obligation by referencing the PSR.The United States Court of Appeals for the Second Circuit reviewed Robinson’s appeal, where he argued that the electronic search condition was not orally pronounced, was procedurally unreasonable, and violated his Fourth Amendment rights. The court found that the district court’s reference to the PSR was sufficient to impose the special condition, and the need for the condition was self-evident given Robinson’s extensive criminal history and dishonesty with law enforcement. The court also held that the condition, which required reasonable suspicion, did not violate Robinson’s Fourth Amendment rights due to his diminished expectation of privacy while on supervised release.The Second Circuit affirmed the judgment of the district court, upholding the special condition of supervised release allowing for the search of Robinson’s electronic devices. View "United States v. Robinson" on Justia Law