Justia Constitutional Law Opinion Summaries

Plaintiffs, students who are currently enrolled in the District's public school system, filed suit alleging that a majority of the School Board are of the Orthodox/Hasidic Jewish faith or are sympathetic to the interests of the Orthodox/Hasidic Jewish community. Plaintiffs claim that the Board Defendants have promoted the Hasidic Jewish faith in violation of the First Amendment. Plaintiffs argue that defendants' unconstitutional actions contributed to the defunding of the public school system, which in turn injured plaintiffs by depriving them of educational opportunities and by damaging their psychological and mental well‐being.The court held that plaintiffs lack standing to assert an Establishment Clause claim against defendants because they are only indirectly affected by the conduct alleged to violate the Establishment Clause. Therefore, it is unnecessary to decide whether defendants are entitled to absolute or qualified immunity. View "Montesa v. Schwartz" on Justia Law

Plaintiff filed suit under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and the New Your State Human Rights Law, N.Y. Exec. Law 290 et seq., alleging that she was wrongfully terminated in retaliation for complaining of sexual harassment. The district court dismissed the claims, holding that plaintiff's employer could not have engaged in retaliation because it could not be held responsible for the retaliatory animus of plaintiff's co-worker, a low-level employee with no decisionmaking authority. The court held, however, that an employee’s retaliatory intent may be imputed to an employer where, as alleged here, the employer’s own negligence gives effect to the employee’s retaliatory animus and causes the victim to suffer an adverse employment decision. Accordingly, the court vacated and remanded for further proceedings. View "Vasquez v. Empress Ambulance Serv." on Justia Law

Plaintiff, a New York City taxi driver, filed suit under 42 U.S.C. 1983 against the United States alleging that the New York City Taxi and Limousine Commission (TLC) deprived him of his Fourth Amendment rights in various ways. As relevant to this appeal, plaintiff argued that the TLC’s mandate that all New York City taxicabs install technology systems equipped with Global Positioning System (GPS) tracking abilities amounted to a property‐based search pursuant to United States v. Jones, and that this search violated his Fourth Amendment rights. The district court granted summary judgment to defendants. The court affirmed the judgment, concluding that the record is devoid of evidence as to whether plaintiff had any interest in a taxi at the time of an alleged trespass or physical intrusion, plaintiff failed to make a sufficient showing on an essential element of his property‐based Fourth Amendment claim, and thus defendants are entitled to summary judgment. View "El-Nahal v. Yassky" on Justia Law

Plaintiff filed suit against defendants alleging that she was terminated for exercising her First Amendment right to free speech when she spoke to local leaders about what she saw as a "scam" occurring in the police department. The district court held that the officials had not shown entitlement to summary judgment of qualified immunity because, accepting plaintiff's facts as true and drawing all permissible factual inferences in her favor, she had shown that they had violated her clearly established constitutional rights. The court concluded that, under plaintiff's version of the facts, there was no doubt that under the prevailing decisions, plaintiff's speech was not made "pursuant to" her official duties as a patrol officer. Therefore, defendants failed to show entitlement to fire plaintiff or entitlement to qualified immunity under her version of the facts. Accordingly, the court affirmed the judgment. View "Ricciuti v. Gyzenis" on Justia Law

Plaintiff appealed the district court's partial grant of summary judgment to his former employer, Rockbestos, on his claims of hostile work environment and discriminatory discharge. The court held that it lacked appellate jurisdiction to review so much of the district court's judgment as involves plaintiff's claim under the Connecticut Fair Employment Practices Act, Conn. Gen. Stat. 46a‐60. In regard to plaintiff's discriminatory-discharge claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., the court concluded that, although the district court's explanation of why plaintiff was judicially estopped from asserting that he was qualified for his position was erroneous, the decision was nevertheless correct because plaintiff failed to proffer a sufficient explanation in light of the record why his assertion that he was qualified for his position was consistent with his earlier sworn statement to the SSA that he was “unable to work.” Therefore, the court agreed with the district court that plaintiff failed to establish a prima facie case of discriminatory discharge on summary judgment under the ADA, Title VII, and the ADEA. Finally, the court held that to the extent plaintiff pleaded hostile-work-environment claims in his amended complaint, he has subsequently abandoned these claims. Accordingly, the court affirmed the judgment and dismissed for want of appellate jurisdiction in regard to the CFEPA claim. View "Kovaco v. Rockbestos-Surprenant Cable Corp." on Justia Law

Defendants, the Donziger Firm and others, appealed the district court's grant of certain relief against them in favor of Chevron, in connection with an $8.646 billion judgment obtained against Chevron in Ecuador by the Lago Agrio Plaintiffs represented by the Donziger Firm. The judgment award was for environmental damage in connection with the Texaco oil exploration activities in Ecuador from the 1960s-1990s. On appeal, defendants challenge the district court's judgment, arguing principally that the action should have been dismissed on the ground that Chevron lacks Article III standing, and/or that the judgment should be reversed on the grounds, inter alia, that it violates principles of international comity and judicial estoppel, exceeds any legal authorization for equitable relief, and was entered without personal jurisdiction over defendants other than Donziger and his Firm. The court found no basis for dismissal or reversal in the absence of challenges to the district court's factual findings; considering the express disclaimers by the Ecuadorian appellate courts of their own jurisdiction to "hear and resolve" the above charges of corruption, "preserving the parties' rights" to pursue those charges in actions in the United States; and considering the district court's confinement of its injunction to a grant of in personam relief against the three defendants-appellants without disturbing the Ecuadorian judgment. Accordingly, the court affirmed the judgment. View "Chevron Corp. v. Donziger" on Justia Law

Plaintiff, a Columbia University student, appealed the dismissal of his amended complaint for failure to state a claim. Plaintiff alleged that the University violated Title IX of the Education Amendments of 1972, 20 U.S.C. 1681 et seq., and state law, by acting with sex bias in investigating him and suspending him for an alleged sexual assault. The court concluded that the complaint meets the low standard described in Littlejohn v. City of New York, by alleging facts giving rise to a plausible minimal inference of bias sufficient to survive a motion to dismiss, which the court held applies to Title IX cases. In this case, the complaint alleged that both the investigator and the panel declined to seek out potential witnesses plaintiff had identified as sources of information favorable to him; the investigator and the panel failed to act in accordance with University procedures designed to protect accused students; and the investigator, the panel, and the reviewing Dean reached conclusions that were incorrect and contrary to the weight of the evidence. Accordingly, the court vacated and remanded. View "Doe v. Columbia University" on Justia Law

Defendant, a mobility‐impaired inmate who suffers from cerebral palsy and scoliosis, filed suit against DOCCS under Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act (RA), 29 U.S.C. 794, seeking declaratory and injunctive relief allowing him to use his motorized wheelchair within DOCCS facilities. The court held that the district court erred by granting summary judgment in favor of DOCCS because there is a genuine dispute of material fact as to whether the mobility assistance program provides plaintiff meaningful access to DOCCS services and as to whether allowing him the use of his motorized wheelchair would unduly burden DOCCS. The court also held that DOCCS’s blanket ban on motorized wheelchairs - without an individualized inquiry into the risks of allowing a mobility‐impaired inmate to use his or her motorized wheelchair - violates the ADA and the RA. Accordingly, the court vacated the district court's grant of summary judgment and remanded for further proceedings. View "Wright v. New York State Dep’t of Corr." on Justia Law

Claimants-Appellants appealed an award of summary judgment which forfeited to the United States various claimants’ interests in multiple properties, including a 36‐story office building located at 650 Fifth Avenue in Manhattan, real properties in Maryland, Texas, California, Virginia, and New York, and the contents of several bank accounts. Also at issue is the September 9, 2013 order denying a motion to suppress evidence seized from the Alavi Foundation’s and the 650 Fifth Avenue Company’s office. The court vacated the judgment as to Claimants Alavi Foundation and the 650 Fifth Ave. Co., of which Alavi is a 60% owner because there are material issues of fact as to whether the Alavi Foundation knew that Assa Corporation, its partner in the 650 Fifth Ave. Co. Partnership, continued after 1995, to be owned or controlled by Bank Melli Iran, which is itself owned or controlled by the Government of Iran, a designated threat to this nation’s national security; the district court erred in sua sponte considering and rejecting claimants’ possible statute of limitations defense without affording notice and a reasonable time to respond; in rejecting claimants’ motion to suppress evidence seized pursuant to a challenged warrant, the district court erred in ruling that claimants’ civil discovery obligations obviate the need for any Fourth Amendment analysis; and the district court erred in its alternative ruling that every item of unlawfully seized evidence would have been inevitably discovered. Accordingly, the court vacated and remanded for further proceedings. View "In re 650 Fifth Avenue and Related Properties" on Justia Law

Plaintiff filed suit against Officer Priatno and Gammone under 42 U.S.C. 1983, alleging that the officers violated his Eighth Amendment rights when they brutally beat him for talking back to another officer when he was an inmate at Downstate Correctional Facility. At issue is whether plaintiff exhausted all available administrative remedies prior to filing suit in the district court, as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a). The court concluded that the prison's grievance process was not available to plaintiff because the applicable grievance procedures are “so opaque” and confusing that they were, “practically speaking, incapable of use.” Because plaintiff satisfied the PLRA's exhaustion requirement, the court reversed and remanded. View "Williams v. Correction Officer Priatno" on Justia Law