Justia Constitutional Law Opinion Summaries

Plaintiff appealed from a partial final judgment of the district court dismissing his Connecticut state law claims for defamation and tortious interference with contract against Defendant, who accused Plaintiff of sexual assault in 2015 while the two were students at Yale University. Plaintiff argued that the district court erred in finding (1) Defendant to enjoy absolute quasi-judicial immunity for statements made at the 2018 Yale disciplinary hearing that resulted in Plaintiff’s expulsion from the university and (2) Plaintiff’s tortious interference claims based on Defendant’s original 2015 accusations to be untimely. On preliminary review, the Second Circuit was unable to determine whether Connecticut would recognize the Yale disciplinary hearing at issue as a quasi-judicial proceeding supporting absolute immunity in this case. Accordingly, the court certified questions pertinent to that determination to the Connecticut Supreme Court. That court responded that absolute immunity does not apply in this case because Yale’s disciplinary hearing was not a quasi-judicial proceeding in that it lacked procedural safeguards associated with judicial proceedings.   In response, The Second Circuit affirmed in part, vacated in part, and remanded. The court explained that while the Connecticut Supreme Court recognized the possibility for participants in such a hearing to be shielded by qualified immunity, the Connecticut Supreme Court concluded that Defendant is not presently entitled to dismissal on that ground because Plaintiff’s complaint sufficiently pleads the malice necessary to defeat such immunity. With this guidance as to Connecticut law, the court concluded on this appeal that Plaintiff’s complaint should not have been dismissed against Defendant except as to his tortious interference claim based on 2015 statements, which is untimely. View "Khan v. Yale Univ." on Justia Law

This case presents the questions of what Defendant must prove to establish affirmative defenses to pay-discrimination claims under federal and state laws: the Equal Pay Act (“EPA”) and New York Labor Law Section 194(1). Plaintiff alleged that Defendant Culinary Institute of America, violated these equal-pay laws by compensating her less than a male colleague. The Culinary Institute responded that a “factor other than sex”—its sex-neutral compensation plan, which incorporates a collective bargaining agreement—justifies the pay disparity. Plaintiff argued that the compensation plan cannot qualify as a “factor other than sex” because it creates a pay disparity unconnected to differences between her job and her colleague’s job. The district court did not consider the divergent requirements imposed by the EPA and Section 194(1) when assessing Plaintiff’s claims and the Culinary Institute’s defense.   The Second Circuit affirmed in part, vacated in part, and remanded insofar as the district court granted summary judgment for Defendant on the Section 194(1) claim. The court explained that Plaintiff’s position that a “factor other than sex” must be job-related is incorrect as to the EPA. The plain meaning of the EPA indicates the opposite. The court held that to establish the EPA’s “factor other than sex” defense, a defendant must prove only that the pay disparity in question results from a differential based on any factor except for sex. But Plaintiff’s position is correct as to New York Labor Law Section 194(1). A recent amendment to Section 194(1) explicitly added a job-relatedness requirement. View "Eisenhauer v. Culinary Institute of America" on Justia Law

Defendant challenged the procedural and substantive reasonableness of the forty-five-year sentence imposed by the district court following her guilty plea to one count of conspiracy to sexually exploit a child and two substantive counts of sexual exploitation of a child. On appeal, Defendant argues that the district court erred when it (1) predetermined her sentence at the outset of the sentencing proceeding, (2) failed to verify at sentencing whether she and her counsel had read and discussed the presentence investigation report, (3) miscalculated her offense level under the United States Sentencing Guidelines, and (4) imposed a substantively unreasonable term of imprisonment.   The Second Circuit affirmed. The court rejected Defendant’s contentions that the district court predetermined her sentence and imposed a substantively unreasonable term of imprisonment. The court also rejected Defendant’s claim that the district court’s purported miscalculation of her offense level under the Guidelines warrants remand in this case. With respect to Defendant’s remaining argument, the court agreed that the district court failed to verify whether she and her counsel had read and discussed the PSR in advance of sentencing, as is required by Federal Rule of Criminal Procedure 32(i)(1)(A). The court concluded that the error was not prejudicial. View "United States v. Gates" on Justia Law

Petitioners appealed from orders of the district court denying their petitions for habeas relief pursuant to 28 U.S.C. Section 2255, following their 2012 convictions for conspiracy to commit Hobbs Act robbery and use of a firearm in furtherance of a crime of violence – specifically, the Hobbs Act robbery conspiracy – that caused the death of another person, in violation of 18 U.S.C. Section 924(c) and (j). On appeal, Petitioners contend that the district court erroneously enforced the collateral-attack waivers in their plea agreements, which they argue are unenforceable in light of Johnson v. United States, 576 U.S. 591 (2015), and United States v. Davis, 139 S. Ct. 2319 (2019).   The Second Circuit dismissed the appeal and explained that subsequent changes in the law do not allow Petitioners to back out of their valid agreements with the government; the waivers are enforceable. The court explained that a waiver of the right to bring a postconviction challenge is presumptively enforceable, even after the legal landscape shifts. A defendant who wishes to maintain his right to collaterally attack his conviction in the event of unforeseen legal developments may, of course, attempt to negotiate more favorable waiver terms with the government before pleading guilty. But where the waiver itself is clear, unambiguous, knowingly and voluntarily entered, and supported by consideration – here, the government’s agreement not to pursue charges or arguments that could have resulted in a much higher sentence – the terms of the plea agreements must be enforced. View "Cook v. United States" on Justia Law

While riding a bicycle, Plaintiff ran into an open car door being operated by a recruiter for the U.S. Marines. Plaintiff brought a claim for negligence against the United States, pursuant to the Federal Tort Claims Act. The district court found the United States liable but concluded Plaintiff was also negligent and, therefore, partially liable.On appeal, the Second Circuit found that the evidence of Plaintiff's negligence was "dubious," and, even if Plaintiff was negligent, the district court failed to make the findings necessary to any holding that the plaintiff’s negligent conduct sufficiently caused the collision so as to make Plaintiff 40% responsible for the damages. View "Dooley v. United States" on Justia Law

Defendant appealed from the district court’s judgment of conviction on charges including attempted murder in aid of racketeering and possession of a firearm in furtherance of a crime of violence. Defendant argued that his firearms conviction should be vacated because the predicate offenses on which the conviction was based are not “crimes of violence” in light of United States v. Davis, 139 S. Ct. 2319 (2019), and United States v. Taylor, 142 S. Ct. 2015 (2022).   The Second Circuit affirmed. The court concluded that Defendant’s section 924(c) conviction remains valid even after Davis and Taylor because one of the predicate offenses underlying the conviction – attempted murder in aid of racketeering – is a categorical crime of violence. The court explained that here, unlike Hobbs Act robbery, the crime of second-degree murder cannot be committed through the mere threat of force and must instead involve the actual use of force. Since attempted murder requires both an intent to use physical force and a substantial step towards the use of physical force, it satisfies the “attempted use . . . of physical force” element under section 924(c), 18 U.S.C. Section 924(c)(3)(A), and thereby qualifies as a crime of violence. View "United States v. Pastore" on Justia Law

Plaintiff was sitting on a bus when police officers boarded the bus, removed him, and arrested him on a misdemeanor bench warrant. Plaintiff, then 67 years old, was a resident of the City of Elmira (the "City"), in Chemung County (the "County"), New York. Plaintiff was taken to the County Jail, where an officer subjected him to a visual body cavity strip search. In addition, although Plaintiff’s girlfriend promptly posted his bail, his release was delayed about two hours. Plaintiff sued the County, the City, and officers in the County Sheriff's Department and City Police Department in the Western District of New York pursuant to 42 U.S.C. Section 1983. The district court dismissed the claims against the City and County at the outset of the case and eventually granted summary judgment dismissing the claims against the individual defendants as well.  Plaintiff appealed the dismissal of the claims against the individual defendants.   The Second Circuit affirmed in part, vacated in part, and remanded. The court explained that on the record, a reasonable jury could find that, instead of simply following the orders of a superior officer, the corrections officer was a party to harassment and demeaning conduct culminating in the search -- conduct that he, and other reasonable officers, should have known had no legitimate penological purpose and was therefore unconstitutional. The court explained that a jury may find otherwise, but in light of these disputed material facts, the district court erred when it granted summary judgment on Plaintiff’s strip search claim. View "Murphy v. Hughson et al." on Justia Law

Defendant pleaded guilty to unlawful possession of a firearm and ammunition after previously having been convicted of a felony. The district court determined that Defendant’s recommended range of imprisonment under the Sentencing Guidelines was 15 to 21 months. On July 7, 2021, the court nevertheless sentenced Defendant principally to an above-Guidelines sentence of 48 months of imprisonment. Defendant argued that his sentence was both procedurally and substantively unreasonable because the district court failed to adequately explain its rationale for the sentence it imposed on Defendant and because the district court’s stated justifications were insufficient to support the sentence imposed.   The Second Circuit affirmed the judgment. The court explained that to hold that Defendant’s sentence was not ultimately reasonable, the court would need to conclude that the sentence he received was “shockingly high.” Defendant argued that his sentence meets that standard because, inter alia, he had a difficult upbringing, completed many rehabilitative program hours while in prison, and does not have a lengthy history of violence. The court explained that these facts weigh in Defendant’s favor and likely were part of the district court’s reasons for not sentencing Defendant to a 70-month imprisonment term as the government requested and as Defendant received when he was convicted of the same offense in 2005. However, they are not strong enough to demonstrate that the district court abused its discretion when sentencing Defendant to a 48-month imprisonment term. Accordingly, the court concluded that the district court did not commit any plain procedural error when imposing Defendant’s sentence. View "United States v. Davis" on Justia Law

In the months following the 2020 presidential election, Defendant-Appellant threatened prominent elected officials in several posts on various social media platforms. A jury convicted Defendant of one count of threatening to assault and murder members of Congress. The district court sentenced Defendant to a prison term of nineteen months. On appeal, Defendant challenged the sufficiency of the evidence, a jury instruction, the partial closure of the courtroom due to the COVID-19 pandemic, and his sentence.The Second Circuit affirmed. The court explained that the constitutional fact doctrine’s requirement that courts “determine for themselves whether the fact-finder appropriately applied First Amendment law to the facts” is inapplicable where, as here, the First Amendment is not implicated. The court found that the evidence was sufficient to support Defendant’s conviction.   Defendant also argued that the district court violated his right to a public trial by excluding his father from the courtroom during the trial. The court explained that the Sixth Amendment guarantees defendants in a criminal prosecution the right to a public trial. However, the court reasoned as a general matter, courts may constitutionally close a courtroom under certain circumstances. Applying the relevant four-part test, the court found that the district court did not plainly err by excluding Defendant’s father from the trial courtroom.   Defendant also challenged the district court’s sentence on the ground that it improperly considered a rehabilitative purpose in sentencing him to prison. The court explained that in sentencing Defendant, the district court did not impermissibly consider rehabilitation. Rather, it considered the factors prescribed by 18 U.S.C. Section 3553(a) View "United States v. Hunt" on Justia Law

Plaintiffs-appellants, nineteen children in New York City’s foster care system, filed suit alleging “systemic deficiencies” in the administration of the City’s foster care system in violation of federal and state law. The named Plaintiffs moved to represent a class of all children who are now or will be in the foster care custody of the Commissioner of New York City’s Administration for Children’s Services and two subclasses. As remedies, they sought injunctive and declaratory relief to redress alleged class-wide injuries caused by deficiencies in the City’s administration—and the New York State Office of Children and Family Services’ oversight—of foster care. The district court denied Plaintiffs’ motion for class certification. Plaintiffs appealed, arguing that the district court erred in its analysis of the commonality and typicality requirements under Federal Rule of Civil Procedure 23(a).   The Second Circuit vacated the district court’s order denying class certification and remanded. The court held that the district court erred in its analysis of commonality and typicality under Rule 23. The court explained that the district court did not determine whether commonality and typicality exist with respect to each of Plaintiffs’ claims. Instead, it concluded that commonality was lacking as to all alleged harms because “Plaintiffs’ allegations do not flow from unitary, non-discretionary policies.” The court held that this approach was legal error requiring remand. Further, the court wrote that here, the district court largely relied upon its commonality analysis to support its finding that typicality was not satisfied. Thus, the deficiencies identified in its commonality inquiry can also be found in its handling of typicality. View "Elisa W. v. City of New York" on Justia Law