Justia Constitutional Law Opinion Summaries

Plaintiffs filed a class action suit against defendants, alleging that they charged plaintiffs more than the statutory maximum fees allowed by N.Y. Pub. Health Law 18(2)(d) and (e) for providing copies of plaintiffs' medical records. The district court granted defendants' motions to dismiss the action pursuant to Fed. R. Civ. P. 12(b)(1) on the ground that the complaint alleged that the requested records had been paid for by plaintiffs' attorneys, ruling that the complaint therefore did not plead injury-in-fact to plaintiffs themselves and that plaintiffs lacked Article III standing. The court concluded that, in light of the ordinary principles of agency, the complaint's allegations that each named plaintiff "through [her or his] counsel" "paid" the charges demanded by defendants for providing the records and that "Plaintiffs" bore "the ultimate expense" for those records, plausibly alleged that plaintiffs themselves were injured by the claimed violations of New York law. Because the district court erred in dismissing the suit under Rule 12(b)(1), the court vacated and remanded. View "Carter v. HealthPort Technologies, LLC" on Justia Law

Plaintiff, an inmate at the Attica Correctional Facility, filed suit under 42 U.S.C. 1983, alleging that while he was incarcerated at Attica, defendant corrections officers Dennis Fleckenstein and Chester Kosmowski subjected him to cruel and unusual punishment by depriving him of meals and defendant Fleckenstein physically assaulted him in violation of his Eighth Amendment rights. At trial, the jury found that both defendants violated plaintiff's constitutional right to nutritionally adequate food and awarded him nominal and punitive damages. On appeal, defendants challenged the district court's admission of a prison monitoring report conducted by a private, nonprofit corporation. The court concluded that the report is hearsay that does not fall within the Business Records Exception nor the Public Records Exception. Furthermore, the report was inadmissible because it further contains hearsay in the form of statements from inmates complaining about abuse at Attica. Because admission of the report was not harmless error, the district court abused its discretion in admitting it. Accordingly, the court vacated and remanded for further proceedings. View "Abascal v. Fleckenstein" on Justia Law

Plaintiff, a corrections officer at the Ulster County Jail, filed suit against the County and its officials, alleging that the denial of her request for an accommodation under the County's light duty policy amounted to pregnancy discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., as amended by the Pregnancy Discrimination Act of 1978, 42 U.S.C. 2000e(k). The district court dismissed plaintiff's claim against the County and former Sheriff VanBlarcum. The district court granted defendants’ motion for judgment as a matter of law at the close of plaintiff’s direct case, reasoning that the policy could not be discriminatory because it was facially neutral with respect to pregnancy. While this appeal was pending, the Supreme Court decided Young v. United Parcel Service, Inc., which held that an employer’s facially neutral accommodation policy gives rise to an inference of pregnancy discrimination if it imposes a significant burden on pregnant employees that is not justified by the employer’s non‐discriminatory explanation. In this case, the court concluded that plaintiff has presented sufficient evidence to support a pregnancy discrimination claim under Young and therefore vacated the judgment in part and remanded with instructions to conduct a new trial. The court also vacated the post judgment orders and remanded for further proceedings. View "Legg v. Ulster Cnty." on Justia Law

Plaintiff filed suit against her former employer, alleging that defendant unlawfully retaliated against her for opposing an employment practice proscribed by Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq. The court concluded that the conduct plaintiff opposed - the amendment of internal procedures in a manner that, she believed, would permit political considerations to influence the evaluation of discrimination claims - is not a “practice made an unlawful employment practice” by Title VII. Nor could plaintiff reasonably have believed otherwise. Accordingly, the court affirmed the district court's dismissal of her claims. View "Cooper v. N.Y. State Dep’t of Labor" on Justia Law

Plaintiff appealed the district court's grant of qualified immunity to Defendant Police Officer Patterson. The district court dismissed plaintiff's claim against Patterson by reason of his having seized her for psychiatric evaluation based on her supposed dangerousness to her son. The court found that the record of evidence of what happened consists only of the terse notes of the CPS caseworkers, and those notes lack indicia of, or specific observations substantiating, plaintiff’s “dangerousness". Nor do they show that Patterson reasonably relied on communications from CPS caseworker Jodi Weitzman or others in making the seizure. Moreover, and notably, there is no statement by Patterson in the record. Therefore, without evidence regarding the grounds of Patterson's decision, the court is unable to determine whether his actions were contrary to clearly established law. Accordingly, the court vacated and remanded for further expansion of the record as to the basis on which the arrest was made, and for reevaluation of Patterson’s entitlement to qualified immunity on the basis of an expanded record. View "Johnson v. Patterson" on Justia Law

Garden City appealed from a final judgment finding it liable for violations of the Fair Housing Act, 42 U.S.C. 3601 et seq.; 42 U.S.C. 1981; 42 U.S.C. 1983; and the Equal Protection Clause. Plaintiffs cross-appealed from the 2012 grant of summary judgment by the same district court in favor of Nassau County. The court held that plaintiffs have Article III standing and plaintiffs' claims are also not moot; the district court did not commit clear error in finding that Garden City’s decision to abandon R‐M zoning in favor of R‐T zoning was made with discriminatory intent, and that defendants failed to demonstrate they would have made the same decision absent discriminatory considerations; the court affirmed the judgment insofar as it found plaintiffs had established liability under 42 U.S.C. 3604(a) of the FHA based on a theory of disparate treatment; the court held that 24 C.F.R. 100.500(c) abrogated the court's prior precedent as to the burden‐shifting framework of proving a disparate impact claim; the court vacated the judgment insofar as it found liability under a disparate impact theory, and remanded for further proceedings; the court held that the district court properly dismissed plaintiffs’ disparate treatment claims against Nassau County at the summary judgment stage because plaintiffs have not raised a genuine issue of material fact as to whether the County had legal responsibility for Garden City’s adoption of R‐T zoning; the court affirmed the dismissal of plaintiffs' disparate treatment claims against Nassau County at the summary judgment stage; and the court remanded with respect to plaintiffs' claims under Section 804(a) and Title VI relating to Nassau County’s “steering” of affordable housing. View "MHANY Mgmt., Inc. v. City of Nassau" on Justia Law

After plaintiff was terminated for taking time off work to care for her sons, plaintiff filed suit against the CIA and two of her supervisors under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(b)(4), alleging that she had been wrongfully denied leave, retaliated against for taking leave, and discriminated against on the basis of her association with a disabled individual. The district court granted summary judgment to defendants on all claims. The court concluded that a rational jury could find that Shaynan Garrioch, CIA's Director of Human Resources, exercised sufficient control over plaintiff's employment to be subject to liability under the FMLA and the court vacated the district court's dismissal of plaintiff's FMLA claims against her; plaintiff has presented sufficient evidence to present genuine disputes of material fact in regard to her interference and retaliation claims under the FMLA; but, in regard to plaintiff's ADA claim, she failed to present evidence that she was fired because her employer suspected distraction or concern for her son would cause her to perform her work inadequately. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Graziadio v. Culinary Inst. of America" on Justia Law

Plaintiff, a former inmate at Bedford Hills Correctional Facility, filed suit alleging claims related to her period of incarceration at Bedford Hills. Plaintiff alleged that three female officers grabbed her, threw her to the ground, lifted her smock, and forcibly opened her legs to allow a male officer to visually inspect her genitalia for cotton. The district court granted summary judgment to defendants. The court concluded that the district court's analysis of this claim rested on an incomplete assessment of the law, particularly the Fourth Amendment’s protection of an inmate’s right to bodily privacy. Because there are genuine disputes of material fact, the court vacated and remanded for further proceedings. View "Harris v. Fischer" on Justia Law

Plaintiff, a former inmate on Rikers Island, filed suit against several correction officers and prison officials, as well as the City, claiming that the officers used excessive force against him and then fabricated evidence, leading to his prosecution and prolonged detention. The court concluded that the district court erred by dismissing plaintiff's malicious prosecution claim on summary judgment where, as here, actual malice can be inferred when a plaintiff is prosecuted without probable cause. Therefore, the court vacated the district court's dismissal of the malicious prosecution claim and remanded for further proceedings. The court concluded that the district court erred in excluding the officers' reports from evidence where plaintiff offered the reports into evidence to show that defendants submitted false reports in an effort to justify their use of force and deny plaintiff a fair trial; the reports were not cumulative; and the district court's error was not harmless. Therefore, the court vacated the judgment as to the fair trial, excessive force, and failure to intercede claims, remanding for a new trial. The court need not consider plaintiff's remaining arguments, but provided guidance to the district court with regards to further trial proceedings. In regard to Captain Ruffin's cross-appeal, the court affirmed the district court's denial of the Rule 50 motion on his claim of intentional infliction of emotional distress. View "Rentas v. Ruffin" on Justia Law

AFDI, a pro‐Israel advocacy organization known for its criticism of Islam, submitted an advertisement for display on the back of MTA buses. The MTA, invoking the provision in its advertising standards barring the display of any advertisement reasonably likely to incite violence, refused to display the Ad. AFDI filed suit against MTA, claiming that the application of the incitement prohibition to the Ad violated the First Amendment, and moved for a preliminary injunction. In this appeal, AFDI appealed from the district court's order dissolving the preliminary injunction on the ground that the claim underlying the injunction became moot. The MTA’s Board of Directors had voted to amend the MTA’s advertising standards, announcing an intention to convert the MTA’s property from a designated public forum to a limited public forum and, to accomplish that goal, included a prohibition on any advertisement that is “political in nature.” The court concluded that the district court did not abuse its discretion in finding AFDI’s claim moot and dissolving the preliminary injunction because the MTA has altered its conduct in a manner sufficient to present a fundamentally different controversy. Further, the MTA has carried its “heavy burden of persuasion” with respect to the two prongs of the voluntary cessation doctrine. Finally, the court rejected AFDI’s alternative argument that its claim is not moot because it has a “vested right” to display the Ad. Accordingly, the court affirmed the judgment. View "American Freedom v. Metropolitan Transport" on Justia Law