Justia Constitutional Law Opinion Summaries

Plaintiff Townsend alleged that she was sexually harassed by defendant, who was the husband of the President of her company, the sole corporate Vice President, as well as a shareholder of the company. Before Plaintiff Grey-Allen, the Human Resources Director of the company, completed an internal investigation of these allegations, she was fired by defendants. On appeal, the parties challenged the decisions of the district court that granted summary judgment dismissing Grey-Allen's Title VII retaliation claim; denied defendants' post-trial motion for judgment as a matter of law or, in the alternative for a new trial; and awarded Townsend attorney's fees and costs. The court considered all of the arguments of the parties and affirmed the judgment of the district court.

Plaintiff appealed from a judgment of the district court dismissing her complaint alleging disparate treatment on the basis of race and gender, retaliation, and sexual harassment by her employer, the State Parole Division, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. On appeal, plaintiff contended that her supervisor's touchings were sufficiently abusive to support her hostile work environment claim and that summary judgment was inappropriate because there were genuine issues of fact to be tried. The court agreed that summary judgment dismissing the hostile work environment claim was inappropriate and vacated so much of the judgment as dismissed that claim, remanding for further proceedings.

Defendant appealed her conviction of one count of mail fraud and three counts of tax evasion for calendar years 1995-1997. On appeal, defendant contended that the trial evidence was insufficient to support her convictions and that the mail fraud and the tax evasion counts were improperly joined. The court agreed with the sufficiency challenges relating to the tax evasion counts for 1996 and 1997 and reversed her convictions on those counts. The court vacated defendant's convictions for mail fraud and tax evasion for 1995 on the ground that those counts were improperly joined, and remanded the case to the district court for further proceedings.

Defendant appealed his conviction following his guilty plea to illegally transporting aliens within the United States; assisting an inadmissible alien in entering the United States; and illegally being present in the United States after having previously been removed. On appeal, defendant contended, inter alia, that the district court miscalculated the applicable sentencing range under the Sentencing Guidelines by adding two points to his criminal history pursuant to U.S.S.G. 4A1.1(d) for his commission of an offense while under a criminal justice sentence. The court held that defendant's knowledge that he was subject to a term of supervised release was not required for the district court to impose an enhancement based on the fact that defendant committed the instant crimes while "under a[] criminal justice sentence." The court declined to reach defendant's ineffective assistance claim and dismissed without prejudice. With regard to defendant's remaining claims, the court found them to be without merit. Accordingly, the court affirmed the judgment.

Defendant, a securities broker, pleaded guilty to charges related to his conduct involving a bribe greater than $70,000. On appeal, defendant contended that the district court erred in calculating restitution insofar as it ordered both restitution and forfeiture in the amount of defendant's gains from the fraudulent scheme underlying his conviction. The court held that it was error for the district court to substitute defendant's gains for the victims' losses in calculating restitution, but declined to exercise the court's discretion to notice the error, as defendant failed to object in the district court, and had failed on appeal to show that the error affected his substantial rights or undermined the fairness, integrity, and public reputation of judicial proceedings.

Plaintiffs, motorcyclists, appealed from a jury verdict finding New York State Troopers not liable for injuries that plaintiffs sustained, including one plaintiff who sustained mortal injuries during a traffic stop. Plaintiffs claimed that the troopers violated plaintiff's Fourth Amendment right to be free from unreasonable seizure through the use of excessive force. The court held that the district court did not err by declining to instruct the jury regarding the use of "deadly force" in addition to a correct instruction on excessive force. Accordingly, the judgment was affirmed.

Petitioner was convicted of Robbery in the Third Degree. The State subsequently appealed from an order of the district court denying the State's motion under Rule 60(b)(6) to vacate the district court's grant of habeas relief to petitioner more than a year earlier. The court found that the State's motion was nothing more than an attempted end-run around the one year time limitation on a Rule 60(b)(1) motion, which allowed the district court to relieve a party from a final judgment or order for mistake, inadvertence, surprise, or excusable neglect. Therefore, the court held that the district court did not abuse its discretion in denying the State's Rule 60(b)(6) motion.

Plaintiff appealed from a judgment from the district court dismissing his 42 U.S.C. 1983 claims. Plaintiff was a convicted sex-offender who had been civilly committed post-release from prison and he alleged that when he was confined in the Manhattan Psychiatric Center, staff seized and withheld his personal DVDs and CDs and his incoming non-legal mail in violation of his due process rights. The court held that the district court did not err in concluding that the complaint failed to state any claim for which relief could be granted. The court also undertook to clarify some applicable principles and affirmed the judgment of the district court because, in any event, it was objectively reasonable for the Center staff to believe that their acts did not violate plaintiff's rights. Accordingly, they were entitled to qualified immunity.

The district court ordered the Governor of the State of New York and various state commissioners and agencies to make certain modifications to the State's mental health system to ensure compliance with 28 C.F.R. 35.130(d) - the so-called "integration mandate" of Title II of the Americans with Disabilities Act, 42 U.S.C. 12132, and Section 504 of the Rehabilitation Act, 29 U.S.C. 794. The court held that DAI, a nonprofit organization contracted to provide services to New York's Protection and Advocacy System under the Protection and Advocacy for Individuals with Mental Illness Act, 42 U.S.C. 10801 et seq., lacked standing under Article III to bring the claim. The court also held that the intervention of the United States after the liability phase of the litigation had concluded was insufficient to cure the jurisdictional defect created by DAI's lack of standing. Therefore, the court vacated the judgment and remedial order and dismissed for want of jurisdiction.

This appeal arose from defendant's judgment of conviction for one count of distributing, and possessing with the intent to distribute, a controlled substance. At his trial, the prosecution introduced, over the defense's objection, testimony from two police detectives that they were familiar with defendant and had spoken to him on numerous occasions prior to his arrest in the instant case. The court held that the admission under Federal Rule of Evidence 404(b) and 403 of trial testimony by the officers was an abuse of discretion where the testimony served no purpose other than to invite jury speculation about defendant's propensity to attract police contact and monitoring. The court further held that such error was not harmless and therefore vacated the conviction and remanded for a new trial.