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

Hamilton Reserve Bank, the beneficial owner of $250,490,000 in Sri Lankan government bonds, sued the Democratic Socialist Republic of Sri Lanka in the United States District Court for the Southern District of New York after Sri Lanka defaulted on the bonds. Over a year later, Jesse Guzman, Ultimate Concrete LLC, and Intercoastal Finance Ltd. sought to intervene, claiming Hamilton defrauded them by using their deposited funds to purchase the bonds and then refusing to allow them to withdraw their money.The district court denied the motion to intervene, holding that it lacked jurisdiction over the intervenors' claims. The court found that the claims did not derive from a "common nucleus of operative fact" with Hamilton's breach of contract claim against Sri Lanka, as required for supplemental jurisdiction under 28 U.S.C. § 1367(a).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 the district court applied the correct "common nucleus of operative fact" standard for evaluating supplemental jurisdiction under Section 1367(a). The court concluded that the intervenors' claims, which involved a banking dispute with Hamilton, did not share substantial factual overlap with Hamilton's breach of contract claim against Sri Lanka. Therefore, the district court correctly determined it lacked jurisdiction over the intervenors' claims and denied their motion to intervene. View "Hamilton Reserve Bank v. Sri Lanka" on Justia Law

Defendant-Appellant Alexander Arguedas pled guilty in the United States District Court for the Southern District of New York to charges of racketeering conspiracy, narcotics conspiracy, and using and carrying firearms in furtherance of a narcotics conspiracy. The district court imposed a below-Guidelines sentence of 390 months of imprisonment, followed by five years of supervised release, and a special assessment of $300. The court also imposed mandatory, standard, and special conditions of supervised release. Arguedas appealed, and his appellate counsel moved to be relieved and for the appointment of substitute counsel, submitting a brief in accordance with Anders v. California.The government moved to dismiss the appeal based on an appeal waiver in the plea agreement or, alternatively, for summary affirmance. The United States Court of Appeals for the Second Circuit found that the Anders brief was incomplete because it did not address Arguedas’s conditions of supervised release, which fall outside the scope of the appeal waiver. The court held that such a deficiency in an Anders brief is not necessarily fatal if it is harmless. The court concluded that there were no non-frivolous issues with respect to the mandatory, standard, and five of the seven special conditions of supervised release, making the deficiency harmless in those respects.However, the court identified potential non-frivolous issues regarding two special conditions concerning financial disclosure and new lines of credit. As a result, the court deferred decision on the motions and ordered the parties to file supplemental briefing to address these conditions. The court directed appellate counsel to determine whether Arguedas wishes to appeal these conditions and to discuss any non-frivolous issues they might raise. The government was also directed to respond to the supplemental briefing. View "United States v. Arguedas" on Justia Law

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

Isaac Poole, while on supervised release for prior drug offenses, tested positive for cocaine, and probation officers found drugs and drug paraphernalia in his home. The United States District Court for the Northern District of New York revoked his supervised release and sentenced him to eight months of imprisonment followed by ninety-six months of supervised release. As a condition of his supervised release, the court required Poole to submit to suspicionless searches by probation officers or law enforcement officers assisting them. Poole appealed this condition, arguing it was unsupported by the record and involved a greater deprivation of liberty than necessary.The United States District Court for the Northern District of New York initially handled Poole's case. After his release from prison, Poole began his supervised release in Syracuse, New York. Following a positive drug test and the discovery of drugs and paraphernalia in his home, the court modified his supervised release conditions to include suspicionless searches. Poole admitted to possessing and using illegal drugs, leading to the revocation of his supervised release and the imposition of the new conditions.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court acted within its discretion in imposing the suspicionless search condition. The court found that Poole's pattern of illegal drug activity, including while on supervised release, justified the condition. The court concluded that the condition served the purposes of deterrence, public protection, and rehabilitation, and enabled probation officers to fulfill their statutory duties. The court affirmed the judgment of the district court, upholding the suspicionless search condition as both procedurally and substantively reasonable. View "United States v. Poole" on Justia Law

Kenneth Darrah exchanged messages with an undercover law enforcement officer posing as the mother of a nine-year-old girl. During these exchanges, Darrah sent an audiovisual file of child pornography through the Kik Messenger application, expecting to receive a picture of the child in return. He pled guilty to distributing child pornography in violation of 18 U.S.C. §2252A(a)(2)(A) and was sentenced by the United States District Court for the Northern District of New York to 106 months in prison and 20 years of supervised release.Darrah appealed, challenging the procedural reasonableness of a five-level increase for distribution of child pornography under U.S.S.G. §2G2.2(b)(3)(B), the substantive reasonableness of his 106-month sentence, and a special condition of supervised release limiting him to one internet-capable device. The district court had calculated a total offense level of 34 and a criminal history category of I, resulting in a Guidelines range of 151 to 188 months. Despite objections, the court imposed a below-Guidelines sentence of 106 months.The United States Court of Appeals for the Second Circuit reviewed the case. It found that the district court erred in applying the five-level increase because there was no evidence of an agreement to exchange anything of value, as required under the amended U.S.S.G. §2G2.2(b)(3)(B). However, this error was deemed harmless since the district court indicated it would have imposed the same sentence regardless. The court also found the 106-month sentence substantively reasonable, considering the nature of Darrah's offense and his background.The appellate court vacated the judgment regarding the special condition of supervised release, which limited Darrah to one internet-capable device, as it constituted an impermissible delegation of judicial authority to the Probation Office. The case was remanded for resentencing consistent with this opinion. View "U.S. v. Darrah" on Justia Law

A pretrial detainee, Alexandra Grimaldi, died after attempting suicide during acute heroin withdrawal while in a County jail. Her mother, Nancy Lara-Grimaldi, filed a lawsuit seeking damages under 42 U.S.C. § 1983 and New York State law against the County of Putnam and various County employees, alleging deliberate indifference to Grimaldi's health and safety.The United States District Court for the Southern District of New York granted summary judgment in favor of the defendants, dismissing the § 1983 claims against correction employees Karen Jackson, Steven Napolitano, and Michelle Nigro, as well as a Monell claim against the County. The court concluded that no reasonable jury could find that these defendants knew or should have known that there was an excessive risk that Grimaldi would attempt suicide. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the dismissal of the § 1983 claims against Jackson and Napolitano, finding that the record did not support a finding of deliberate indifference on their part. However, the court vacated the dismissal of the § 1983 claim against Nigro, concluding that there was sufficient evidence for a reasonable jury to find that Nigro knew or should have known about Grimaldi's risk factors and failed to provide adequate supervision. The court also vacated the dismissal of the state-law claims against Nigro, Jackson, Napolitano, and the County, and remanded for further proceedings on those claims. View "Lara-Grimaldi v. County of Putnam" on Justia Law

Monika Kapoor, an Indian citizen, faces extradition from the United States to India to face criminal charges. The United States District Court for the Eastern District of New York determined that Kapoor was extraditable under the bilateral extradition treaty between the U.S. and India. The Secretary of State issued a surrender warrant, rejecting Kapoor’s claims that she would likely be tortured if returned to India, which would violate the Convention Against Torture (CAT). Kapoor filed a petition for a writ of habeas corpus, challenging the Secretary’s decision, but the district court denied her petition, citing 8 U.S.C. § 1252(a)(4) from the REAL ID Act of 2005, which divested the court of jurisdiction to hear her claim. Kapoor appealed.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed with the district court, stating that the Convention is not a self-executing treaty and that courts can review claims under it only as authorized by Congress. The court referenced the Supreme Court’s test in I.N.S v. St. Cyr, noting that Section 1252(a)(4) clearly states that claims under the Convention can only be raised in petitions for review of immigration removal orders and specifically bars judicial review of such claims in habeas proceedings, except in limited circumstances not applicable here.The Second Circuit held that this interpretation does not violate the Suspension Clause in the extradition context due to the longstanding rule of non-inquiry, which precludes American habeas courts from considering the anticipated treatment of an extraditee in the receiving country. Consequently, the court affirmed the district court’s decision, denying Kapoor’s petition. View "Kapoor v. DeMarco" on Justia Law

In 2020, Article 13 LLC filed a quiet title action against LaSalle National Bank Association (now U.S. Bank) to discharge a mortgage as time-barred, arguing that the statute of limitations had expired since a foreclosure action was commenced in 2007. U.S. Bank contended that the statute of limitations had not expired because the 2007 foreclosure action was invalid to accelerate the mortgage debt. The district court found a disputed issue of material fact regarding the validity of the 2007 foreclosure action and denied both parties' motions for summary judgment.Following the district court's ruling, New York enacted the Foreclosure Abuse Prevention Act (FAPA), which bars the defense of the invalidity of prior accelerations of mortgages in quiet title actions. Article 13 LLC moved for reconsideration, and the district court applied FAPA retroactively, granting summary judgment in favor of Article 13 LLC. U.S. Bank appealed, arguing that FAPA should not be applied retroactively and that such retroactivity would be unconstitutional under both the New York and U.S. Constitutions.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the questions of FAPA's retroactivity and its constitutionality under the New York Constitution were novel and essential to the resolution of the appeal. Consequently, the Second Circuit certified two questions to the New York Court of Appeals: whether Section 7 of FAPA applies to foreclosure actions commenced before the statute's enactment, and whether FAPA's retroactive application violates substantive and procedural due process under the New York Constitution. The Second Circuit deferred its resolution of the appeal pending the New York Court of Appeals' response. View "Article 13 LLC v. Lasalle Nat'l Bank Ass'n" on Justia Law

Angel Tudor, a teacher with post-traumatic stress disorder (PTSD), worked for Whitehall Central School District for approximately 20 years. Tudor had an accommodation allowing her to leave campus for 15-minute breaks during her prep periods to manage her PTSD symptoms. In 2016, Whitehall prohibited teachers from leaving school grounds during prep periods, leading Tudor to take medical leave. Upon her return, Whitehall provided inconsistent accommodations, which Tudor claimed were insufficient. For the 2019-20 school year, Tudor's schedule included a study hall period during which she was not guaranteed her requested break, leading her to take unauthorized breaks.The United States District Court for the Northern District of New York granted summary judgment in favor of Whitehall, holding that Tudor's ability to perform her job without accommodation was fatal to her failure-to-accommodate claim under the Americans with Disabilities Act (ADA). The court assumed Tudor had a qualifying disability but found that she could not establish the third element of her claim because she could perform her job's essential functions without accommodation.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court erred. The appellate court held that an employee may qualify for a reasonable accommodation under the ADA even if they can perform the essential functions of their job without it. The court emphasized that the ADA requires employers to provide reasonable accommodations, not just necessary ones. The judgment of the district court was vacated, and the case was remanded for further proceedings consistent with this opinion. View "Tudor v. Whitehall Central School District" on Justia Law

Willie Dennis was convicted of three counts of cyberstalking under 18 U.S.C. § 2261A(2)(B) for sending repeated abusive electronic communications to his former partners at the law firm K&L Gates LLP after his ouster from the partnership. Dennis argued that the statute was unconstitutional as applied to his case because the trial evidence was insufficient to prove that his communications constituted "true threats" of physical harm, which would fall outside the First Amendment's protection of free speech. He also contended that erroneous jury instructions allowed the jury to find him guilty without proof of true threats and that he was unduly prejudiced by trial rulings and the trial judge's statements about his pro se status.The United States District Court for the Southern District of New York convicted Dennis on three counts of cyberstalking. Dennis appealed, arguing that the evidence was insufficient to prove true threats and that the jury instructions were erroneous. He also claimed that he was prejudiced by the exclusion of certain evidence and by the trial judge's comments.The United States Court of Appeals for the Second Circuit reviewed the case and found that the evidence was sufficient to permit a reasonable jury to find true threats in Dennis's communications to two of the victims, Bicks and Bostick, but insufficient as to the third victim, Cottle. The court held that Dennis's conviction on Count Two must be reversed due to insufficient evidence of true threats. The court also found that Dennis's failure to raise a true-threat challenge to the jury instructions in the district court limited appellate review to plain error, which was not evident. The court concluded that Dennis's other arguments were without merit.The Second Circuit affirmed Dennis's conviction on Counts One and Four but reversed the conviction on Count Two. View "United States v. Dennis" on Justia Law