Justia Constitutional Law Opinion Summaries

Articles Posted in U.S. Court of Appeals for the Second Circuit

by
Plaintiff filed suit against MTBank, alleging violations of various state and federal statues by not allowing her to work remotely when she became pregnant. The magistrate judge ruled as a matter of law against plaintiff on a number of claims and the jury found for MTBank on the remaining claims. The court held that the district court abused its discretion in admitting evidence of the reinstatement offer because the offer was, as a matter of law, not unconditional; the district court erred in sua sponte disqualifying the attorneys for both parties, because the disqualification depended on the erroneous admission of evidence relating to the reinstatement offer; the jury instructions were not erroneous; and the court lacked jurisdiction over plaintiff's challenge to the district court's New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq., ruling. Accordingly, the court vacated in part in regard to the jury's verdict and the disqualification order, dismissed in part in regard to claims under the NYSHRL, and remanded for further proceedings. View "Jia Sheng v. MTBank Corp." on Justia Law

by
Plaintiff, an inmate confined in solitary confinement for the last twenty-two years, filed suit under 42 U.S.C. 1983 against current and former prison officials, alleging that his solitary confinement under Administrative Segregation violates his Fourteenth Amendment rights to procedural and substantive due process of law. The district court granted defendants' motion for summary judgment on plaintiff's procedural due process claim, and sua sponte awarded summary judgment on the substantive due process claim. The court concluded that the record presents triable issues of fact regarding plaintiff's procedural due process claim. In this case, although there exists on the record a substantial amount of evidence for a jury to conclude that officials where methodical in their approach to conducting periodic Administrative Segregation reviews, the court concluded that plaintiff has nonetheless produced evidence to raise a fair question about the meaningfulness, and thus procedural sufficiency, of his reviews. The court also concluded that the district court violated Federal Rule of Civil Procedure 56(f) in awarding summary judgment sua sponte on plaintiff's substantive due process claim. Accordingly, the court vacated and remanded for further proceedings. View "Proctor v. LeClaire" on Justia Law

by
This appeal requires the court to determine whether Battery Park City Authority (BPCA) has the capacity to challenge a New York State claim-revival statute as unconstitutional under the New York State Constitution. The court certified the following questions to the New York Court of Appeals: (1) Before New York State’s capacity‐to‐sue doctrine may be applied to determine whether a State‐created public benefit corporation has the capacity to challenge a State statute, must it first be determined whether the public benefit corporation “should be treated like the State,” see Clark‐Fitzpatrick, Inc. v. Long Island R.R. Co., 516 N.E.2d 190, 192 (N.Y. 1987), based on a “particularized inquiry into the nature of the instrumentality and the statute claimed to be applicable to it,” see John Grace & Co. v. State Univ. Constr. Fund, 375 N.E.2d 377, 379 (N.Y. 1978), and if so, what considerations are relevant to that inquiry?; and (2) Does the “serious injustice” standard articulated in Gallewski v. H. Hentz & Co., 93 N.E.2d 620 (N.Y1950), or the less stringent “reasonableness” standard articulated in Robinson v. Robins Dry Dock & Repair Co., 144 N.E. 579 (N.Y. 1924), govern the merits of a due process challenge under the New York State Constitution to a claim‐revival statute? View "In re: World Trade Center Lower Manhattan Disaster Site Litigation" on Justia Law

by
After plaintiffs' convictions for rape and murder were vacated and they had served eighteen years in prison, plaintiff filed suit alleging, inter alia, malicious prosecution and denial of fair trial claims. Defendant, as executrix of the Estate of Joseph Volpe, appealed the district court's judgment for plaintiffs. Volpe was a homicide detective that investigated the rape and murder case. The court concluded that the district court did not abuse its discretion in determining that a new trial was warranted; the court rejected defendant's evidentiary challenges; the court rejected defendant's argument that a conflict of interest deprived Volpe of a fair trial; the district court correctly denied Volpe's request for a setoff; the court denied Volpe's motion for remittitur and concluded that the district court did not abuse its discretion in holding that the jury award did not shock the conscience or materially deviate from what would be reasonable compensation; and the court affirmed the district court's award of attorney fees. Because the court found no basis for reversal, the court affirmed the judgment. View "Restivo v. Hessemann" on Justia Law

by
Plaintiff was arrested for speeding wildly while drunk and high, and his Ferrari was impounded. After a neutral magistrate ordered that the vehicle be retained by the County, plaintiff filed a claim under 42 U.S.C. 1983, alleging that Suffolk County, in retaining his vehicle pendente lite, deprived him of due process. The district court agreed. The court concluded that, at a post‐seizure hearing to determine whether a vehicle should be returned to a title owner pendente lite pursuant to Suffolk County’s DWI Seizure Law, the Due Process Clause permits Suffolk County, after making out a prima facia case that retention is necessary to protect the County’s interests in the financial value of the vehicle and/or in protecting the public from continued unsafe and illegal driving, to shift the burden of going forward to the title owner to identify an alternative measure that would satisfy the County’s interests. Therefore, the court reversed the district court's grant of summary judgment to plaintiff and remanded with instructions to enter judgment in favor of the County. View "Ferrari v. County of Suffolk" on Justia Law

by
Jarquez Dancy and Jayvon Elting, two high school students, were stopped by Police Officer Gregg McGinley while they were walking on Main Street in Poughkeepsie, New York. A confrontation ensued that left Elting bruised, scraped, and swollen, and Dancy with a broken jaw. Elting and Dancy brought a civil rights action in federal district court alleging, inter alia, false arrest and use of excessive force. The district court entered judgment as a matter of law in favor of Elting on liability as to his claims against McGinley for false arrest and use of excessive force, and thereafter the jury awarded him $215,000, which the district court remitted to $196,500. The jury found in favor of Williams on Dancy's claim for false arrest, but was unable to reach a verdict on Dancy's excessive force claim. At a second trial, the jury found in favor of Williams on Dancy's excessive force claim. The district court denied Dancy's motion for a new trial. The court affirmed the judgment in favor of Elting and the amount of damages. However, the court vacated the judgment in favor of Williams and remanded for a new trial on Dancy's excessive force claim. In this case, the court concluded that there was a lack of clarity in the district court's instructions that improperly placed the burden on Dancy to prove intent, not only as to the seizure but as to the injury as well. The error was not harmless. View "Dancy v. McGinley" on Justia Law

by
Plaintiff, a union employee, filed suit alleging that his employer discriminated against him on the basis of his race and/or national origin, and retaliated against him. At issue on appeal is whether the collective bargaining agreement (CBA), which requires arbitration of disputes over discrimination, requires arbitration of statutory claims. The court concluded that the CBA’s arbitration requirement does not encompass statutory discrimination or retaliation claims with wording that is “clear and unmistakable.” Therefore, the court vacated the district court's grant of defendants' motion to compel arbitration and dismissed the complaint, remanding for further proceedings. View "Lawrence v. Sol G. Atlas Realty Co., Inc." on Justia Law

by
Plaintiffs filed suit alleging 42 U.S.C. 1983 claims for false arrest, malicious prosecution, abuse of process, and excessive force. Plaintiffs were arrested at a party after officers suspected that plaintiffs were trespassing, loitering for the purpose of using narcotics, and endangering the welfare of a child because there was a 12 year-old child present. Charges against plaintiffs were later dropped. The court held that there is a genuine dispute of material fact as to whether the defendant police officers had probable cause to arrest plaintiffs for trespass. Therefore, the court vacated the judgment. The court remanded the false arrest claim and defendants' claim of qualified immunity related to the false arrest. Finally, the court affirmed the dismissal of the malicious prosecution, abuse of process, and municipal liability claims. View "Mitchell v. The City of New York" on Justia Law

by
Plaintiff and Undercover Officer C0039’s (UC 39) appeal from the district court's judgment finding UC 39 liable for denying plaintiff his right to a fair trial by fabricating evidence in connection with criminal charges against plaintiff, and awarding plaintiff $1 in nominal damages and $20,000 in punitive damages. The district court held that UC 39’s allegedly fabricated account of his own observations could provide the basis for a claim of denial of the right to a fair trial due to an officer’s provision of false information to a prosecutor following Ricciuti v. N.Y.C. Transit Authority. The court held that the district court did not err in denying UC 39’s motion for judgment as a matter of law or in denying plaintiff's motion for a new trial.The court held that Ricciuti, along with the limiting standard therein, applies to false information contained in an officer’s own account of his or her observations of alleged criminal activity giving rise to an arrest which he or she then conveys to prosecutors. Accordingly, the court affirmed the judgment. View "Garnett v. Undercover Officer C0039" on Justia Law

by
Plaintiffs, individually and on behalf of their respective daughters J.C. and T.H., filed suit against District Defendants and NYSED Defendants. Plaintiffs claim that the district court erred in concluding that plaintiffs did not make a prima facie showing of discrimination against District Defendants pursuant to the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act (Section 504), 29 U.S.C. 794 et seq. In this case, plaintiffs' disparate impact claim relies exclusively on data concerning students with disabilities under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court concluded that, aside from their receipt of special education services, the record is devoid of any evidence as to whether the students included in the data qualify as disabled under the ADA or Section 504. Because, as a matter of law, an IDEA disability does not necessarily constitute a disability under the ADA or Section 504, the court concluded that plaintiffs’ data does not establish “a significantly adverse or disproportionate impact on persons of a particular type produced by the defendant’s facially neutral acts or practices.” Therefore, the court concluded that plaintiffs failed to make their prima facie showing that District Defendants’ academic intervention services (AIS) policy adversely impacted individuals protected by the ADA and Section 504. The court concluded that the district court properly entered summary judgment in favor of District Defendants as to the ADA and Section 504 claims. Likewise, the district court properly entered summary judgment on their derivative Section 1983 claim against the District Defendants. The court affirmed the judgment. View "B.C. v. Mount Vernon Sch. Dist." on Justia Law