Justia Constitutional Law Opinion Summaries

Plaintiff, pro se, filed suit against defendants under the Fourteenth Amendment for deliberate indifference. After plaintiff was beaten by police officers, he was taken to the emergency room where was evaluated doctors. Plaintiff alleged that Defendant Rabin, one of the doctors, allowed herself to be influenced by the officers who told Rabin that plaintiff had attacked a female police officer and that he should be ignored and left alone. The district court concluded that plaintiff's complaint did not state a claim for deliberate indifference because he did not adequately allege that Rabin acted with a sufficiently culpable state of mind. The court concluded that if plaintiff's complaint were amended to include the allegations in his opposition to the motion to dismiss, the complaint would sufficiently set forth the mental state element of his deliberate indifference claim. Accordingly, the court reversed the district court's denial of leave to amend and remanded for further proceedings where amendment in this instance would not be futile. View "Nielsen v. Bloomberg" on Justia Law

Plaintiff appealed the district court's dismissal of his complaint for failure to state a claim, arguing that the procedures employed by the Commission in investigating, evaluating, and resolving his claim of discrimination violated due process. As defendants did not have a duty to perform any activity that they allegedly failed to perform, the court agreed with the district court that not performing such actions was not a violation of the process to which plaintiff was entitled. Further, the court rejected plaintiff's argument that the Commission's procedures facially violated due process. The court held that the procedures of the Commission, which included administrative and judicial review, satisfied due process and affirmed the judgment of the district court. View "Rosu v. City of New York, et al." on Justia Law

A Vermont statute requires all "health insurers" to file with the State reports containing claims data and other "information relating to health care." Liberty Mutual sought a declaration that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted the Vermont statute and regulation. The district court granted summary judgment in favor of Vermont. The court held that the reporting requirements of the Vermont statute and regulation have a "connection with" ERISA plans and were therefore preempted as applied. The court's holding was supported by the principle that "reporting" is a core ERISA function shielded from potentially inconsistent and burdensome state regulation. Accordingly, the court reversed and remanded with instructions to enter judgment for Liberty Mutual. View "Liberty Mutual Ins. Co. v. Donegan" on Justia Law

This litigation arose out of the failure of WaMu and the assumption of WaMu's assets and liabilities by Chase from the FDIC, acting in its capacity as WaMu's receiver. On appeal, the FDIC and Chase challenged the district court's grant of summary judgment in favor of Hillside. The district court concluded that Hillside, which owned premises leased by WaMu before the financial crisis, had third-party standing to enforce the alleged assignment of WaMu's real estate lease to Chase under a purchase agreement between the FDIC and Chase, even though the FDIC validly repudiated the lease under section 212(e) of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989, 12 U.S.C. 1821(e), and the parties to the purchase agreement asserted that it did not in fact assign the lease. The court held that Hillside lacked prudential standing to litigate whether WaMu's liabilities were assigned to Chase under the agreement because it was neither a contracting party nor a third-party beneficiary under the agreement. Accordingly, the court vacated and remanded with instructions to dismiss the complaint. View "Hillside Metro Associates, LLC v. JPMorgan Chase Bank, N.A." on Justia Law

Plaintiff, a prisoner serving a New York State sentence, filed suit under 42 U.S.C. 1983, alleging that defendants violated his constitutional rights by failing to provide him with necessary medical treatment during his incarceration at a correctional facility and by punishing him for his efforts to secure such treatment. The district court dismissed the action with prejudice. The court concluded that the district court did not abuse its discretion by imposing the sanction of dismissal with prejudice, nor did it err in its underlying finding that plaintiff acted in bad faith such that no other sanction would suffice. The court clarified that the offending conduct for which the sanction was imposed was not plaintiff's accusations that the Magistrate Judge was biased against him, but rather his offensive, abusive, and insulting language. Accordingly, the court affirmed the judgment of the district court. View "Koehl v. Bernstein" on Justia Law

The City appealed the district court's grant of plaintiffs' motion for a preliminary injunction enjoining Local Law 17. Local Law 17, inter alia, requires pregnancy services centers to make certain disclosures regarding the services that the centers provide. The court concluded that the law was not impermissibly vague; plaintiffs failed to demonstrate a likelihood of success on the merits with respect to one of the challenged disclosures, which requires pregnancy services centers to disclose if they have a licensed medical provider on staff; plaintiffs have demonstrated a likelihood of success on the merits with respect to other provisions challenged by plaintiffs that require other forms of disclosure and impermissibly compel speech; and because the provisions are severable, the court severed the enjoined provisions from the rest of Local Law 17. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "The Evergreen Association, Inc v. City of New York" on Justia Law

These consolidated appeals arose out of a permanent injunction entered by the Bankruptcy Court and affirmed by the district court, enjoining state law tort actions asserted by appellants, two of Madoff's defrauded investors, against the estate of one of Madoff's alleged co-conspirators and related defendants (Picower defendants). The court concluded that appellants' complaints impermissibly attempted to "plead around" the Bankruptcy Court's injunction barring all claims "derivative" of those asserted by the Trustee. The court also concluded that the Bankruptcy Court operated within the confines of Article III, as recently interpreted by the Supreme Court in Stern v. Marshall. Accordingly, the court held that the Bankruptcy Court did not exceed the bounds of its authority under the Bankruptcy Code or run afoul of Article III. View "In Re: Bernard Madoff" on Justia Law

Plaintiff filed suit against defendants alleging, inter alia, unlawful discrimination and hostile work environment. The court concluded, inter alia, that the jury was precluded from finding that plaintiff had not actually engaged in the conduct charged against him in the section 75 of the New York State Civil Service Law hearing. Inasmuch as the district court did not expressly instruct the jury that its fact-findings were cabined in this regard, the jury charge was in error. The court affirmed the judgment of the district court with respect to the state law claims and its award of backpay to plaintiff; affirmed the judgment as to plaintiff's 42 U.S.C. 1983 claim against the ECWA and the concomitant award of punitive damages against the ECWA; reversed the judgment imposing liability against the individual defendants on plaintiff's section 1983 claims against them, and therefore also reversed the judgment insofar as it awarded punitive damages against the individual defendants; and affirmed the district court's attorney's fee award. View "Matusick v. Erie Cnty Water Auth., et al." on Justia Law

Plaintiff, a prison inmate, filed suit alleging that three masked correction officers (COs) sprayed him while he was in his cell with an unknown substance, apparently a mixture of fecal matter, vinegar, and machine oil. The COs were retaliating against plaintiff for reporting several prior assaults. The district court dismissed for failure to state a claim under Rule 12(b)(6) and 12(c). The court was unwilling to accept, as a matter of law, the proposition that spraying an inmate with a mixture of feces, vinegar, and machine oil constituted a de minimis use of force. Even assuming arguendo that the physical force allegedly used was de minimis, spraying an inmate with the mixture was undoubtedly "repugnant to the conscience of mankind" and therefore violated the Eighth Amendment. The court vacated and remanded, concluding that the complaint plausibly alleged violations of his constitutional rights and that the applicable statute of limitations did not preclude plaintiff from amending his complaint to name certain John Doe defendants. View "Hogan v. Fischer" on Justia Law

Plaintiffs appealed from the district court's order denying their Rule 60(b) motion to reopen the district court's judgment dismissing sovereign defendants under the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1330 1602 et seq. Plaintiffs moved for relief from judgment in order to appeal the district court's alternative ground for finding sovereign immunity - a ground that the court declined to reach in its prior opinion. The district court denied the motion under the impression that the court would be able to consider that unreviewed issue on appeal from the denial. But the court could not. Accordingly, the court concluded that this was an error of law and that "extraordinary circumstances" existed warranting relief under Rule 60(b). The court reversed and remanded for further proceedings. View "In Re: Terrorist Attacks on September 11, 2001" on Justia Law