Justia Constitutional Law Opinion Summaries

Plaintiffs filed suit alleging that BOE is failing to provide them with meaningful access to its voting program, in violation of Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794(a), and Title II of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12132. The district court concluded that pervasive and recurring barriers existed at poll sites operated by BOE and granted plaintiffs' motion for summary judgment. The district court later ordered a remedial plan after the parties had the opportunity to develop and propose a joint plan of relief. The court concluded that the district court correctly held that BOE failed to grant voters with disabilities meaningful access to its voting program. The court also found that the district court's remedial order was a proper exercise of the district court's authority to grant equitable relief. Accordingly, the court affirmed the judgment of the district court. View "Disabled in Action, et al. v. Bd. of Elections in the City of New York, et al." on Justia Law

Plaintiff's ex-wife, intoxicated and strung out, called the police and falsely accused plaintiff of assaulting her. Plaintiff was charged with assault and resisting arrest. After the charges were dismissed with prejudice, plaintiff filed suit against his ex-wife, the arresting officers, and the City, alleging claims under 42 U.S.C. 1983. On appeal, plaintiff challenged the district court's grant of defendants' motions to dismiss the complaint. The court held that because arguable probable cause existed to arrest plaintiff, his claims for false arrest, false imprisonment, abuse of process, and malicious prosecution were properly dismissed; plaintiff's claim for denial of his right to a fair trial was properly dismissed because he failed to meet the required pleading standards; and plaintiff's claims against the ex-wife were properly dismissed because she did not act under the color of state law. Accordingly, the court affirmed the judgment of the district court. View "Betts v. Shearman, et al." on Justia Law

Plaintiff filed suit against OCCC, alleging claims of discrimination on the basis of a "perceived disability" and retaliation in violation of Title II of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. The district court concluded that plaintiff, who was enrolled in OCCC's medical Laboratory Technology program, failed to establish that OCCC perceived his shaking hands to substantially limit a major life activity, and granted the motion for summary judgment in favor of OCCC as to the ADA discrimination claim. The district court also granted summary judgment in favor of OCCC on the retaliation claim because plaintiff had not presented any evidence that OCCC's good faith belief that plaintiff had falsified documents was a legitimate, non-discriminatory reason for the disciplinary referral. The court concluded that plaintiff failed to demonstrate that OCCC perceived him as having an impairment that substantially limited a major life activity; plaintiff failed to demonstrate that OCCC's explanation for its decision to bring disciplinary proceedings against him was pretext for retaliation; and plaintiff's remaining arguments were without merit. Accordingly, the court affirmed the judgment of the district court. View "Widomski v. Orange County Community College" on Justia Law

Plaintiff filed suit against APIC, a nondomiciliary risk retention group, under New York's direct action statute, N.Y. Ins. Law 3420, to recover an unsatisfied state court judgment that had been entered against APIC's insured. The insured was a chiropractor that plaintiff had sought treatment from and who had pled guilty to third-degree assault for his inappropriate touching of plaintiff. At issue was whether the Liability Risk Retention Act of 1986, 15 U.S.C. 3901 et seq., preempted the application of section 3420(a)(2) to APIC, which was domiciled in Arizona, but issued insurance policies in New York. The court held that any construction of New York law that would impose section 3420's direct action requirements on foreign risk retention groups was preempted by section 3902(a)(1) of the LRRA. View "Wadsworth v. Allied Professionals Ins." on Justia Law

The Board and School District appealed from the district court's grant of summary judgment permanently enjoining defendants from enforcing Reg. I.Q. Reg. I.Q. governs the "extended use" of school facilities outside of school hours by outside organizations and individuals. The district court found that enforcement of Reg. I.Q. to exclude religious worship services would violate the Free Exercise and Establishment Clauses. The court concluded that the Free Exercise Clause did not entitle Bronx Household to a grant from the Board of a subsidized place to hold religious worship services; the Supreme Court's ruling in Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah that invidiously discriminatory ordinances targeting a religious practice of a particular religion were subject to strict scrutiny had no application to Reg. I.Q.; if the Board has a reasonable, good faith concern that making its school facilities available for the conduct of religious worship services would give rise to a substantial risk of violating the Establishment Clause, the permissibly of the Board's refusal to do so did not turn on whether such use of school facilities would in fact violate the Establishment Clause; and therefore, Reg. I.Q. did not violate plaintiffs' rights to free exercise of religion, whether or not it was subject to strict scrutiny. The court also concluded that the district court erred in concluding that Reg. I.Q. violates the Establishment Clause because it compelled the Board to become excessively entangled with religion by deciding what were religious worship services. The court considered Bronx Household's other arguments and found them to be without merit. Accordingly, the court reversed the judgment of the district court and vacated the injunction barring enforcement of Reg. I. Q. View "Bronx Household v. Board of Education" on Justia Law

Plaintiff filed discrimination and retaliation claims against the Bank under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq., as well as state and local laws. At issue was whether an employee's inability to sit for a prolonged time may constitute a disability under the ADA. The court held that impairments that limit the ability to sit for long periods of time do not categorically fail to qualify as disabilities under the ADA. The court vacated the district court's judgment relating to plaintiff's claim of discrimination under the ADA and leave for the district court to determine in the first instance on remand if the record reflected a genuine dispute of fact as to whether plaintiff's inability to sit for a prolonged period of time constituted a substantial limitation of a major life activity, and to address remaining arguments advanced by the Bank in its summary judgment motion. The court affirmed the district court's judgment with respect to plaintiff's claim under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., as well as her claim of retaliation under the ADA. The court vacated the district court's judgment with respect to plaintiff's claim of discrimination under the ADA and her claims under state law, remanding for further proceedings. View "Parada v. Banco Industrial de Venezuela, C.A." on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, alleging, among other things, that defendants violated their First Amendment and substantive due process rights by closing down Royal Crown's day care facility in retaliation for a letter of complaint that Royal Crown sent to a New York State senator. On appeal, the individually named defendants challenged from the district court's denial of their motion for summary judgment on qualified immunity grounds and from the denial of their motion to reconsider. The court concluded that defendants were not entitled to qualified immunity solely because closing down Royal Crown may have been justified under the Health Code; defendants' motivation in closing down Royal Crown was material to Royal Crown's First Amendment and substantive due process claims and the court did not have jurisdiction to consider whether the dispute about defendants' motivation was genuine; properly assuming on this interlocutory appeal that defendants retaliated against Royal Crown for speech protected by the First Amendment, defendants' action was not objectively reasonable; Royal Crown's First Amendment and substantive due process rights to be free from retaliation and irrational government action in response to its letter to the Senator were clearly established at the time that defendants closed down plaintiff's day care facility; and therefore, defendants were not entitled to summary judgment on the basis of qualified immunity. The court affirmed the judgment of the district court. View "Royal Crown Day Care LLC v. Dept. of Health and Mental Hygiene" on Justia Law

After plaintiff sought to obtain records from the SSA related to his father's disability status in order to support his efforts to obtain proceeds of his father's life insurance policy, plaintiff filed suit pro se alleging that the failure to provide the requested records violated the Privacy Act of 1974, 5 U.S.C. 552a, and the Freedom of Information Act (FOIA), 5 U.S.C. 552. The SSA eventually voluntarily provided the requested records to plaintiff. On appeal, plaintiff challenged the dismissal of his claim for damages and litigation fees under the Privacy Act and FOIA. The court affirmed the dismissal of plaintiff's claim for damages under the Privacy Act because the Act guarantees access only to an individual's own records and does not require federal agencies to provide information that pertains to a requesting individual, but is contained in another individual's records. However, because FOIA allows for fee shifting where, as here, a federal agency voluntarily complies with a requested disclosure following the filing of a FOIA lawsuit, the court vacated that portion of the district court's judgment denying plaintiff's request for $350 in litigation costs and remanded with instructions. View "Warren v. Colvin" on Justia Law

Plaintiffs placed their son in a specialized private school designed to educate children with learning disabilities and filed suit against the District for tuition reimbursement under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. An Impartial Hearing Officer (IHO) awarded tuition reimbursement but the State Review Officer (SRO) reversed. The court held that the SRO's decision was insufficiently reasoned to merit deference and deferred to the IHO's decision, which was more thorough and carefully considered. The court affirmed the dismissal of plaintiff's claim under Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, where the parents had not presented sufficient evidence of bad faith or gross misjudgment. View "C.L. v. Scarsdale Union Free Sch. Dist." on Justia Law

Plaintiff appealed from the dismissal of her state-law tort claims as time-barred, arguing that the statute of limitations applicable to her tort claims was tolled by her filing of a charge of discrimination with the EEOC. The court joined the Seventh and Ninth Circuits in holding as a matter of federal law that filing an EEOC charge did not toll the limitations period of state-law tort claims, even if those claims arose out of the same factual circumstances as the discrimination alleged in the EEOC charge. Accordingly, the court affirmed the dismissal of plaintiff's tort claims. View "Castagna v. Luceno" on Justia Law