Justia Constitutional Law Opinion Summaries

A healthcare provider, Neurological Surgery Practice of Long Island, PLLC, provides out-of-network medical services governed by the No Surprises Act. This Act requires out-of-network providers to seek compensation from the patient’s healthcare plan rather than billing patients directly. If a provider and a healthcare plan cannot agree on a compensation amount, an independent dispute resolution (IDR) process is used. Neurological Surgery alleges that a backlog of disputes has resulted in unpaid or delayed reimbursements due to the Departments of Health and Human Services, Treasury, and Labor failing to implement the Act properly, violating the Administrative Procedure Act (APA) and the Due Process Clause of the Fifth Amendment.The United States District Court for the Eastern District of New York dismissed Neurological Surgery’s claims. The court concluded that the claims were moot due to the reopening of the IDR portal, Neurological Surgery lacked standing to compel the Departments to enforce the Act’s deadlines on third parties, and the claims regarding the Departments’ failure to certify a sufficient number of arbitrators and provide guidance on New York’s surprise billing law were foreclosed by the APA.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court’s judgment, agreeing that the challenge to the pause of the IDR portal was moot since the portal was operational. The court also held that Neurological Surgery lacked standing to compel the Departments to enforce deadlines on healthcare plans and IDR entities, as the injury was caused by third parties, not the Departments. Additionally, the court found that the challenge to the Departments’ failure to certify a sufficient number of IDR entities was foreclosed by the APA, as the Act did not specify discrete actions required by the Departments. Lastly, the court held that the challenge to the Departments’ failure to issue guidance on New York’s surprise billing law failed to state a claim under the APA. View "Neurological Surgery v. Department of Health & Human Services" on Justia Law

Defendants Jibril Adamu and Jean-Claude Okongo Landji were involved in an international narcotics trafficking conspiracy, using a private aircraft to transport cocaine from South America to Africa and Europe. Landji owned an aviation charter business and Adamu was his co-pilot. They were arrested in Croatia in 2018 after flying a test shipment of cocaine. Their cell phones, containing incriminating evidence, were seized. Both defendants were extradited to the United States and charged with conspiracy to distribute and possess with intent to distribute cocaine.The United States District Court for the Southern District of New York convicted both defendants following a jury trial. They were sentenced to 120 months’ imprisonment and five years’ supervised release. The defendants appealed, arguing that the government lacked jurisdiction under 21 U.S.C. § 959, violated their Sixth Amendment rights by using privileged information, and erred in admitting data extracted from their cell phones.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that 21 U.S.C. § 959 applies extraterritorially, affirming the government’s jurisdiction. It also found no Sixth Amendment violation, as the district court correctly determined that the government did not use privileged information in its prosecution. The court concluded that the cell phone data was properly authenticated and its admission did not violate the Confrontation Clause. The court noted that any potential error in admitting the cell phone data was harmless given the overwhelming evidence of guilt.The Second Circuit affirmed the judgment of the district court, upholding the convictions and sentences of both defendants. View "United States v. Adamu" on Justia Law

The case involves the National Rifle Association of America (NRA) suing Maria T. Vullo, the former Superintendent of the New York State Department of Financial Services (DFS), alleging that Vullo violated its First Amendment rights. The NRA claimed that Vullo engaged in coercive and retaliatory actions against the NRA by pressuring financial institutions and insurers to sever ties with the NRA, thereby infringing on its free speech and equal protection rights. Vullo argued that she was entitled to qualified immunity.The United States District Court for the Northern District of New York denied Vullo's motion to dismiss the NRA's First Amendment claims, finding that the NRA had sufficiently stated a claim and that Vullo was not entitled to qualified immunity at that stage. Vullo appealed the decision.The United States Court of Appeals for the Second Circuit initially reversed the district court's decision, holding that the NRA failed to state a First Amendment claim and that Vullo was entitled to qualified immunity. The NRA then petitioned the Supreme Court, which granted certiorari to address whether the NRA had stated a plausible First Amendment claim. The Supreme Court concluded that the NRA had plausibly alleged a First Amendment violation and remanded the case to the Second Circuit to reconsider the issue of qualified immunity.Upon reconsideration, the Second Circuit concluded that Vullo was entitled to qualified immunity. The court reasoned that, although the general principle that a government official cannot coerce a private party to suppress disfavored speech was well established, it was not clearly established that Vullo's conduct—regulatory actions directed at the nonexpressive conduct of third parties—constituted coercion or retaliation in violation of the First Amendment. Therefore, the court reversed the district court's denial of qualified immunity and remanded the case for the district court to enter judgment dismissing the remaining claims against Vullo. View "Nat'l Rifle Ass'n of Am. v. Vullo" on Justia Law

The case involves a challenge to New York's gun-related public nuisance statute, N.Y. General Business Law § 898-a–e, by the National Shooting Sports Foundation, Inc. and fourteen of its members. The statute imposes liability on gun industry members who knowingly or recklessly endanger public safety through the sale or marketing of firearms. The plaintiffs argue that the statute is unconstitutional, claiming it is preempted by the federal Protection of Lawful Commerce in Arms Act (PLCAA), violates the dormant Commerce Clause, and is unconstitutionally vague under the Due Process Clause of the Fourteenth Amendment.The United States District Court for the Northern District of New York dismissed the plaintiffs' complaint, ruling in favor of New York's Attorney General, Letitia James. The district court found that the statute was not preempted by PLCAA, did not violate the dormant Commerce Clause, and was not unconstitutionally vague. The plaintiffs then appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the plaintiffs did not meet their burden in this facial, preenforcement challenge to demonstrate that the statute is unenforceable in all its applications. The court concluded that the statute falls within PLCAA's predicate exception clause and is therefore not preempted. Additionally, the court found that the statute does not violate the principles of interstate commerce and is not void for vagueness. The judgment of the district court was affirmed. View "National Shooting Sports Foundation, Inc. v. James" on Justia Law

Kenneth Thompson was convicted of being a felon in possession of a firearm and ammunition, following a guilty plea. The United States District Court for the Eastern District of New York sentenced him to thirty-seven months of imprisonment and two years of supervised release. The court also imposed special conditions of supervised release, including submitting to searches, complying with sex offender registration requirements, and undergoing a mental health evaluation and treatment if necessary.Thompson appealed, arguing that the district court erred in imposing the special conditions without an individualized assessment and explanation. He also claimed ineffective assistance of counsel and that his guilty plea was involuntary. Additionally, he challenged the district court's Sentencing Guidelines calculation and argued that 18 U.S.C. § 922(g)(1) violated the Second Amendment.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that Thompson waived any challenge to the mental health treatment condition by consenting to it. The court held that the district court made an individualized assessment and adequately explained its reasons for imposing the special conditions, which were supported by the record. The court declined to consider Thompson's ineffective assistance of counsel claim, noting that it was not raised in the district court and lacked sufficient factual development. The court also held that Thompson's remaining challenges to his conviction and sentence were barred by the appellate waiver in his plea agreement.The Second Circuit affirmed the judgment of the district court. View "United States v. Thompson" on Justia Law

In 2021, the Federal Reserve Bank of New York implemented a policy requiring all employees to be vaccinated against Covid-19, with exemptions for religious or medical reasons. Lori Gardner-Alfred and Jeanette Diaz, employees of the Federal Reserve, applied for religious exemptions, claiming that the vaccine conflicted with their religious beliefs. The Federal Reserve denied their requests and subsequently terminated their employment for non-compliance with the vaccination policy. Gardner-Alfred and Diaz filed a lawsuit, alleging that the Federal Reserve's actions violated their religious liberties under the Free Exercise Clause of the First Amendment and various federal statutes.The United States District Court for the Southern District of New York granted summary judgment in favor of the Federal Reserve on all federal claims. The court found no genuine dispute of fact regarding the sincerity of Gardner-Alfred's religious objections and concluded that the vaccination policy did not conflict with Diaz's professed religious beliefs. Additionally, the district court imposed discovery sanctions on Gardner-Alfred and Diaz for repeatedly neglecting their discovery obligations, withholding relevant documents, and violating court orders.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's summary judgment on Gardner-Alfred's claims, agreeing that she failed to provide sufficient evidence of sincerely held religious beliefs. However, the court vacated the summary judgment on Diaz's claims, finding that there were disputed issues of material fact regarding the sincerity of her religious beliefs and whether the vaccination policy burdened those beliefs. The court also upheld the district court's imposition of discovery sanctions, finding no abuse of discretion. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gardner-Alfred v. Federal Reserve Bank of New York" on Justia Law

Plaintiff SeanPaul Reyes, who frequently posts videos of his interactions with police on YouTube, challenged a New York City Police Department (NYPD) policy that prohibits video recording inside police facilities. Reyes, who had been arrested twice for recording inside police stationhouses, argued that the policy violated his rights under the First Amendment and the New York State and New York City Right to Record Acts (RTRAs). He sought a preliminary injunction to prevent the City from enforcing the policy and to remove signs stating the policy.The United States District Court for the Southern District of New York granted Reyes a preliminary injunction based on his state and local law claims, despite finding that he was unlikely to succeed on his First Amendment claim. The court concluded that Reyes demonstrated a likelihood of success on the merits of his RTRAs claims, irreparable harm, and that the public interest favored an injunction.The City of New York appealed to the United States Court of Appeals for the Second Circuit, arguing that the district court erred in exercising supplemental jurisdiction over the state and local claims and in finding that Reyes met the requirements for a preliminary injunction. The Second Circuit found no abuse of discretion in the district court's exercise of supplemental jurisdiction or its determination of irreparable harm. However, the court noted that the resolution of whether Reyes is likely to succeed on the merits and whether the public interest favors an injunction depends on the interpretation of the RTRAs.Given the lack of clear guidance from New York courts on whether the RTRAs afford a right to record inside police stationhouses, the Second Circuit certified the following question to the New York Court of Appeals: Does either N.Y. Civ. Rights Law § 79-p or N.Y.C. Admin. Code § 14-189 afford individuals the right to video record law enforcement activities inside public facilities, specifically inside the publicly accessible lobbies of police stationhouses, notwithstanding the NYPD policy forbidding such recording? The decision on the appeal is reserved pending the response from the New York Court of Appeals. View "Reyes v. City of New York" on Justia Law

William Hines was convicted in the United States District Court for the Northern District of New York for receipt and possession of child pornography found on his cellphone and laptop. Hines had pleaded guilty but reserved the right to appeal the denial of his motion to suppress evidence obtained from the search of his cellphone. Hines argued that his girlfriend, K.S., acted as an agent of the police when she used his password to unlock his cellphone, observed child pornography, and showed the images to a police officer, thus violating his Fourth Amendment rights.The district court held an evidentiary hearing and found that K.S. acted independently and not as a government agent when she unlocked the phone and showed the images to the police officer. The court concluded that the private search did not implicate the Fourth Amendment and denied the motion to suppress the evidence obtained from the subsequent search warrant.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the burden lies with the defendant to show that a private search constituted governmental action implicating the Fourth Amendment. The court found no error in the district court's determination that Hines failed to meet this burden. The court concluded that K.S. acted independently and not as a government agent, and thus, the private search did not violate the Fourth Amendment. Consequently, the evidence obtained from the search warrant was admissible. The Second Circuit affirmed the judgment of the district court. View "United States v. Hines" on Justia Law

Selim Zherka, a convicted felon, challenged the constitutionality of 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms. Zherka argued that because his felony was nonviolent, Congress could not deprive him of his Second Amendment right to bear arms. He also claimed a due process right to an individualized assessment of dangerousness before being deprived of this right. Zherka sought a declaration that the statute was unconstitutional as applied to him and an injunction preventing the government from enforcing it against him.The United States District Court for the Southern District of New York dismissed Zherka’s claims. The court held that § 922(g)(1) was constitutional as applied to him and that he had no right to a hearing before the application of a categorical prohibition. The court relied on the Supreme Court’s assurance in District of Columbia v. Heller that longstanding prohibitions on the possession of firearms by felons are presumptively lawful. The court also rejected Zherka’s due process claim, citing Connecticut Department of Public Safety v. Doe, which held that procedural due process does not require a hearing to prove or disprove facts irrelevant under the challenged statute.The United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The court held that the Second Amendment does not prohibit Congress from disarming convicted felons, including those convicted of nonviolent felonies. The court found that there is a historical tradition of legislative disarmament of classes of people perceived as dangerous, which supports the constitutionality of § 922(g)(1). The court also concluded that Zherka had no procedural due process right to an individualized assessment of dangerousness before being disarmed under the statute. View "Zherka v. Bondi" on Justia Law

In this case, the defendant met a sixteen-year-old runaway in the Bronx and, along with two associates, lured her to their apartment. There, they gave her drug-laced alcohol, sexually assaulted her, and began prostituting her over a period of three weeks. The group took explicit photos, posted online advertisements, arranged clients, and used violence and threats to control the victim. Although the victim initially claimed to be eighteen, the defendant and his associates became suspicious of her age and eventually learned she was sixteen, but continued the operation. The defendant left the group after being injured in a shooting, but remained in contact with his co-conspirators. The victim was eventually rescued by law enforcement, and the defendant was arrested after several months as a fugitive.The United States District Court for the Southern District of New York presided over the trial. The government charged the defendant with sex trafficking conspiracy, sex trafficking a minor, and conspiracy to use interstate commerce to promote unlawful activity. After a jury trial, the defendant was convicted on all counts. The defendant moved for acquittal on the sex trafficking count, arguing that the government failed to prove he knew the victim was underage, and objected to the jury instructions, claiming the relevant statutory language was unconstitutionally vague.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that 18 U.S.C. § 1591(c), which allows conviction for sex trafficking a minor if the defendant had a “reasonable opportunity to observe” the victim, is not unconstitutionally vague. The court also found no error in the district court’s use of a general verdict form rather than a special verdict form. The Second Circuit affirmed the judgment of the district court. View "United States v. Concepcion" on Justia Law