Justia Constitutional Law Opinion Summaries

Plaintiff sued her former employer asserting claims of gender discrimination and retaliation under the New York City Human Rights Law (NYCHRL), N.Y.C. Admin. Code 8-107(1)(a), (7). The district court granted summary judgment to the employer and dismissed the complaint. The court concluded, however, that the district court erred in granting summary judgment because the record presented genuine disputes of material fact regarding both plaintiff's claims under the NYCHRL. Accordingly, the court vacated the judgment and remanded for trial. View "Mihalik v. Credit Agricole Cheuvreux N. Am., Inc." on Justia Law

Plaintiff filed suit under Title VII and the New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq., alleging that an affair that one of her brothers had with another worker in their family business created a hostile work environment and that both of her brothers retaliated against her for complaining about the affair. On appeal, plaintiff challenged the dismissal of her retaliation claim. The court examined all of plaintiff's arguments on appeal and found them to be without merit. Because there was no indication that plaintiff believed that her sex had anything to with her treatment or that defendants could have understood her statements as such, she failed to establish a prima facie case for retaliation under Title VII and the NYSHRL. Accordingly, the court affirmed the district court's judgment. View "Kelly v. Howard I. Shapiro & Assocs. Consulting Eng'rs., P.C." on Justia Law

Plaintiff, a New York State prisoner who had been administratively confined since 2003, appealed the district court's dismissal of his amended complaint. The complaint, brought pursuant to 42 U.S.C. 1983, alleged that plaintiff's due process rights have been violated because the decisions to continue his confinement in a Special Housing Unit (SHU) have been based on evidence that should have been expunged from his record, the periodic reviews have been perfunctory and meaningless, and the reasons given for his continued confinement have been false or misleading. Because plaintiff had previously lost a similar suit, the district court dismissed the complaint on the grounds that the present action was barred by principles of res judicata and collateral estoppel. The court concluded that the district court's applications of claim preclusion and issue preclusion, which the court reviewed de novo and in light of Computer Associates International, Inc. v. Altai, Inc., were in large part erroneous. Accordingly, the court vacated and remanded for further proceedings. View "Proctor v. LeClaire" on Justia Law

NOM, a nonprofit advocacy organization, appealed the district court's dismissal of its amended complaint for lack of subject-matter-jurisdiction. NOM was seeking declaratory and injunctive relief, arguing that New York Election Law 14-100.1, which defined the term "political committee" for the purposes of state elections, violated the First Amendment. The court determined that NOM's case presented a live controversy that was ripe for consideration and vacated the district court's determination that it lacked jurisdiction. Because that conclusion prevented the district court from reaching the merits of NOM's claims, the court declined to comment on the substance of NOM's claims in the first instance. Therefore, the court remanded for further proceedings. View "National Organization for Marriage, Inc. v. Walsh" on Justia Law

Plaintiff was convicted of attempted murder in the second degree and subsequently pled guilty to a lesser charge for which the penalty was a one-year sentence - a jail term that he had already served. Plaintiff then brought the instant action under 42 U.S.C. 1983, alleging Brady violations against the officials who conducted his original investigation and prosecution. The district court granted defendants' motion for summary judgment, ruling that plaintiff's section 1983 claims were barred under Heck v. Humphrey. The court concluded, however, that because plaintiff was no longer in custody, and therefore could no longer bring a federal habeas suit, Heck's narrow exception to section 1983's otherwise broad coverage did not apply. Plaintiff may bring suit under section 1983 regardless of any defenses which might arise based on his subsequent guilty plea to the lesser charge. Accordingly, the court vacated the district court's decision granting summary judgment and remanded for further proceedings. View "Poventud v. City of New York" on Justia Law

Plaintiff appealed the district court's dismissal of her claims of employment discrimination and retaliation under federal, state, and New York City law. Plaintiff claimed that defendants unfairly reprimanded her, observed her classroom with unusual frequency, evaluated her classroom performance negatively, and gave her less desirable classroom assignments and duties. She argued that these actions were unwarranted and motivated by discriminatory and retaliatory animus. Defendants acknowledged that they increased their supervision of and attention toward plaintiff, but they contended that they did so to address her performance and behavioral issues. The court concluded that the district court properly granted summary judgment in favor of defendants for substantially the reasons articulated by the district court. With respect to plaintiff's retaliation claims, even if the court assumed that defendants' actions resulted in adverse employment action, no reasonable jury could find that such actions were motivated by a retaliatory animus. Accordingly, the court affirmed the judgment in its entirety. View "Sotomayor v. City of New York" on Justia Law

Plaintiff, formerly a participant in the Justice Department's Witness Security Program, brought suit pursuant to Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, alleging that he was terminated from the Program without being afforded procedural due process. Plaintiff also alleged that following his termination he was placed in a Segregated Housing Unit (SHU) for 188 days and that this confinement violated due process and constituted cruel and unusual punishment. The court held that the district court properly dismissed plaintiff's claim concerning his termination based on lack of subject matter jurisdiction in light of 18 U.S.C. 3521(f). However, with respect to SHU detention, the district court should have sua sponte granted plaintiff leave to replead before sua sponte dismissing the complaint. Accordingly, the court affirmed in part and vacated in part, remanding for further proceedings. View "J.S. v. T'Kash" on Justia Law

MES claimed that the Corps unfairly terminated three of its construction/renovation contracts. On appeal, MES and its President contended that the district court erred as a matter of law in ruling that their Bivens action was precluded by the Contract Disputes Act of 1978 (CDA), 41 U.S.C. 7101 et seq. The court held as a preliminary matter that it lacked jurisdiction to review MES's President's claim because the text and caption of the original timely notice of appeal failed to identify MES's President as a party appealing from the judgment. Accordingly, the court dismissed MES's President's appeal and only address MES's challenge to the judgment of dismissal. The court concluded that, in enacting the CDA, Congress created a comprehensive scheme for securing relief from the United States for any disputes pertaining to federal courts. The existence of that statutory scheme precluded MES from pursuing Bivens claims against federal employees in their individual capacities for alleged violations of due process or the First Amendment in terminating MES's federal construction contracts with the Corps. Accordingly, the court affirmed the judgment. View "M.E.S., Inc. v. Snell" on Justia Law

The Companies, Cookson and Vesuvius, appealed the district court's judgment denying their motion for summary judgment and granting the cross-motion of the Union. After the Companies closed a facility that Vesuvius had operated, Vesuvius and the Union entered into a Facility Closure Agreement (FCA). Both parties subsequently disputed whether the agreement required Vesuvius to pay a retiree medical allowance (RMA) to certain eligible employees. The district court held that the FCA imposed such a requirement. The court affirmed, holding that the district court correctly interpreted the parties' agreement and that the Union, as party to that agreement, had standing to enforce it even where the benefits of enforcement accrued to third-party retirees. View "United Steel v. Cookson America, Inc." on Justia Law

A jury found that plaintiff failed to prove her claim that the shooting of her family's dog by a law enforcement officer during the execution of a search warrant of her home was an unconstitutional seizure in violation of the Fourth Amendment. On appeal, plaintiff contended that defendants' failure to train its officers regarding non-lethal means to secure dogs and to formulate a plan to restrain plaintiff's dog using non-lethal means rendered the officer's shooting of her dog unconstitutional as a matter of law. The court concluded that a reasonable jury could have found that no amount of planning or training would have changed the outcome in this case. Plaintiff offered no evidence that any non-lethal means of controlling her dog would have allowed the officer to quickly escape the "fatal funnel" and effectively execute the no-knock warrant. Accordingly, the court affirmed the district court's judgment. View "Carroll v. County of Monroe" on Justia Law