Justia Constitutional Law Opinion Summaries
Articles Posted in U.S. Court of Appeals for the Second Circuit
Davis v. N.Y.C. Dep’t of Edu.
Plaintiff filed suit against her employer, alleging a claim of discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12112-12117, and seeking damages. Plaintiff's claim is based on her employer’s decision to reduce her discretionary bonus after she was absent from work for four months. The district court granted summary judgment for the defendant. The court concluded that the district court erred in ruling that denial or reduction of a bonus could not constitute an adverse employment action solely because the employer had discretion whether to pay a bonus. The court further concluded that, despite this error, the district court correctly determined that, even if plaintiff established an adverse employment action, she failed to present evidence that would support the necessary finding of discriminatory motivation. Accordingly, the court affirmed the judgment. View "Davis v. N.Y.C. Dep’t of Edu." on Justia Law
New York State Rifle & Pistol Ass’n v. Cuomo
These two appeals challenge gun-control legislation prohibiting the possession of certain semiautomatic “assault weapons” and large‐capacity magazines. The district courts granted summary judgment in favor of defendants. The court held that the core provisions of the New York and Connecticut laws prohibiting possession of semiautomatic assault weapons and large‐capacity magazines do not violate the Second Amendment, and that the challenged individual provisions are not void for vagueness; the particular provision of New York’s law regulating load limits, however, does not survive the requisite scrutiny; and Connecticut’s prohibition on the non‐semiautomatic Remington 7615 unconstitutionally infringes upon the Second Amendment right. Accordingly, the court affirmed in part the judgment of the district court insofar as it upheld the prohibition of semiautomatic assault weapons and large-capacity magazines; reversed in part its holding with respect to the Remington 7615; reversed in part certain vagueness holdings; and otherwise affirmed the judgment insofar as it upheld the prohibition of semiautomatic assault weapons and large-capacity magazines and invalidated the load limit. View "New York State Rifle & Pistol Ass’n v. Cuomo" on Justia Law
The Anderson Group v. City of Saratoga Springs
TAG filed suit against the City, arguing that the City's zoning policies perpetuated racial segregation and had a disparate impact, thus violating the Fair Housing Act, 42 U.S.C. 3604. In 2010, a jury returned a verdict in favor of TAG on the disparate impact claim, but the district court granted the City's motion for a new trial. In 2012, a second jury returned a verdict in favor of the City on both TAG's perpetuation of segregation and disparate impact claims. The court held that TAG’s lost upfront economic expenditures on a detailed development proposal for a specific piece of property, coupled with the denial of a necessary special use permit, constitute injuries-in-fact that are fairly traceable to the City’s actions, thus affording TAG standing to maintain this action. The court also held that the City waived its argument regarding the inconsistency of the jury verdict; the district court should not have reached the merits of that argument, and it therefore erred when it ordered a new trial on that ground. Further, having concluded that the district court erred in ordering a new trial, and that the City has waived its remaining claims of error relating to the 2010 trial, the court reinstated the 2010 judgment in favor of TAG on its disparate impact claim; remanded with instructions that the district court grant a new trial limited only to the issue of damages unless TAG agrees to a remittitur reducing its award to $100,000; and denied reassignment on remand. View "The Anderson Group v. City of Saratoga Springs" on Justia Law