U.S. Court of Appeals for the Second Circuit - Justia Case Law Summaries

Jimenez v. City of New York

2026-09-04T07:00:17-08:00

In 1989, Sean Worrell was murdered in a Bronx movie theater. The police investigation initially focused on Ricardo Jimenez after he was identified by teenager Esco Blaylock, allegedly through a suggestive photo procedure. The official reports linked Jimenez to the nickname “Leon,” though evidence later suggested this identification process was flawed and possibly fabricated. The case remained dormant for a decade. Around 1999, Detective Wendell Stradford reopened the investigation, securing incriminating testimony from witnesses, including Andrew O’Brien, a federal inmate, and Blaylock, who had ceased cooperating years earlier. O’Brien’s cooperation was allegedly induced by the promise of a sentence reduction, and additional testimony came from a jailhouse informant with a history of unreliability. In 2007, Jimenez was convicted of murder based solely on these witnesses’ testimony and was sentenced to 22 years to life. Jimenez appealed his conviction through the New York State courts without success. He then sought federal habeas relief. In 2022, the U.S. District Court for the Southern District of New York vacated his conviction, finding that the prosecutor had committed Brady violations by suppressing exculpatory and impeachment evidence regarding the key witnesses. The charges were dismissed in 2023. Jimenez then sued for damages under 42 U.S.C. § 1983 and state law, alleging malicious prosecution, denial of fair trial rights, failure to intervene by the officers, and Monell liability against the City and the District Attorney’s Office. The U.S. District Court for the Southern District of New York dismissed all claims, finding, among other reasons, that Jimenez failed to overcome the presumption of probable cause from the grand jury indictment and that the pleadings were insufficient. The United States Court of Appeals for the Second Circuit affirmed the dismissal of the malicious prosecution claims, the fair trial claims against the original investigating officers, the failure to intervene claims, and the Monell claim against the District Attorney’s Office. However, it vacated the dismissal of the fair trial claim against Detective Stradford, the Monell claim against the City of New York, and the negligence claim against the City, remanding those issues for further proceedings. The court held that Jimenez plausibly alleged fabrication and forwarding of false evidence by Detective Stradford and that the Monell and negligence claims warranted further consideration. View "Jimenez v. City of New York" on Justia Law

Rapaport v. Nivoda

2026-09-04T07:00:12-08:00

A company that provides information to the diamond industry publishes a weekly price list for diamonds, categorizing them by attributes such as size, color, and clarity. This list, which the company claims is based on its expert opinion and proprietary methods, is distributed to paid subscribers. The company alleged that another business operating an online diamond marketplace copied prices from this list and displayed them on its website, showing the difference between its own prices and those in the list. The United States District Court for the Southern District of New York granted the defendant's motion to dismiss the complaint. The district court found that the “merger doctrine” applied, reasoning that the idea of the market price for diamonds based on their characteristics could only be expressed in one way—by the specific numbers listed—and that protecting these numbers would impermissibly grant copyright protection to an idea rather than its expression. The district court did not reach other arguments, such as whether the plaintiff had proper copyright registration or whether fair use applied. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision de novo. The appellate court held that the district court erred in applying the merger doctrine at the motion to dismiss stage, as there were unresolved factual questions about how the price list was created and whether the prices could only be expressed in one way. The appellate court concluded that, based on the complaint’s allegations, the list may reflect the plaintiff’s opinion and expert judgment, not just objective market facts. The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings, including consideration of alternative grounds for dismissal. View "Rapaport v. Nivoda" on Justia Law

Moore v. Rubin

2026-09-04T07:00:03-08:00

Six women filed suit against a wealthy bond trader, alleging that he recruited them to travel to New York for sadomasochistic sexual encounters in exchange for money, with the understanding that their participation would be consensual and within agreed boundaries. The plaintiffs claimed that, contrary to their understanding, the defendant engaged in conduct that was coercive, abusive, and far exceeded what they had consented to, including physical violence and other degrading acts. They brought claims under the Trafficking Victims Protection Act (TVPA) and state law torts such as assault, battery, false imprisonment, and intentional infliction of emotional distress. The case was heard in the United States District Court for the Eastern District of New York. After extensive discovery, motion practice, and delays, the case proceeded to a jury trial. The jury unanimously found the defendant liable under the TVPA for all six plaintiffs and for battery as to one plaintiff, awarding $3.85 million in compensatory and punitive damages. The defendant’s post-trial motions for judgment as a matter of law or for a new trial were denied. On a prior appeal, the United States Court of Appeals for the Second Circuit affirmed the liability findings and damages award. The plaintiffs then moved for attorneys’ fees and costs, which the District Court granted in part, awarding over $4.8 million in attorneys’ fees. On appeal, the United States Court of Appeals for the Second Circuit reviewed whether the District Court abused its discretion in awarding attorneys’ fees at rates above the prevailing forum rates and compensating multiple legal professionals. The Second Circuit held that the District Court correctly applied the relevant legal standards, properly considered the complexity, intensity, and duration of the litigation, and reasonably deviated from ordinary rates given the unique circumstances. The Court affirmed the attorneys’ fee award. View "Moore v. Rubin" on Justia Law

United States of America v. Rivera

2026-09-03T06:30:09-08:00

Miguel Rivera, a convicted felon, was apprehended by police following a report of gunshots in Waterbury, Connecticut. Upon his arrest, officers found a semiautomatic rifle, thirty rounds of ammunition for the rifle, and a single bullet of a different caliber in Rivera’s possession. The rifle was located nearby and appeared recently discarded. Rivera confessed to dropping the firearm while fleeing from police. He was charged under 18 U.S.C. § 922(g)(1) for unlawful possession of a firearm and ammunition. The United States District Court for the District of Connecticut denied Rivera’s motion to dismiss the indictment, which he argued was duplicitous for combining possession of different items in a single count. The District Court also instructed the jury that unanimity was required only as to whether Rivera possessed a firearm or ammunition, not which specific item. Rivera was convicted by a jury and sentenced to sixty months in prison and three years of supervised release. On appeal to the United States Court of Appeals for the Second Circuit, Rivera challenged his conviction on two grounds: the alleged duplicity of the indictment and the sufficiency of the evidence. The Second Circuit reviewed these claims de novo and concluded that the identity of the specific firearm or ammunition is not an element of a § 922(g)(1) offense, but rather a “brute fact.” The jury needed only to unanimously agree that Rivera possessed a firearm or ammunition, not which specific item. The court also found the evidence sufficient to support the conviction. The Second Circuit affirmed the judgment of the District Court. View "United States of America v. Rivera" on Justia Law

United States v. Stuart

2026-09-03T06:30:04-08:00

Jessica Stuart was convicted of health care fraud and using false identification after she falsely claimed to be a Board-Certified Behavioral Analyst, rendering services to children with autism and causing significant financial losses to her employer and Medicaid. Her criminal history included multiple instances of fraud and larceny, such as issuing bad checks, stealing from individuals with whom she resided, and manipulating payments for personal gain. After serving her sentence, Stuart’s supervised release was marked by additional violations, including failing to make restitution payments, moving without approval, committing new frauds involving food stamps and unemployment benefits, and failing to report police contact. The United States District Court for the District of Connecticut initially sentenced Stuart to incarceration and supervised release. When she violated conditions of her supervised release, the court, now presided over by Judge Nagala, imposed a new special condition authorizing the Probation Office to notify third parties—including employers, potential employers, and others to whom Stuart might pose a risk—of her criminal history and past conduct. Stuart objected, arguing the condition improperly delegated judicial authority to the Probation Office by granting it sole discretion to determine who qualifies as a third party at risk. The United States Court of Appeals for the Second Circuit reviewed the challenge. Applying an abuse of discretion standard and reviewing legal questions de novo, the court held that the district court had sufficiently limited the Probation Office’s discretion. The condition was found permissible because it was rooted in Stuart’s varied and opportunistic risk profile, and the court had provided enough guidance to constrain arbitrary use of delegated authority. The Probation Office’s role was determined to be execution, not imposition, of the condition. Accordingly, the Second Circuit affirmed the judgment of the district court. View "United States v. Stuart" on Justia Law

County of Westchester v. Express Scripts

2026-09-02T06:30:15-08:00

Several counties and municipalities in New York initiated lawsuits in state courts against two pharmacy benefit managers, Express Scripts, Inc. and OptumRx, Inc., alleging that these companies contributed to the opioid epidemic in their communities. The claims are based on state law and center on the defendants’ alleged practices in negotiating with opioid manufacturers and managing prescription formularies, which plaintiffs contend led to an oversupply of prescription opioids and caused substantial public harm and government expense. The defendants removed the cases to federal court—the United States District Courts for the Southern and Eastern Districts of New York—arguing removal was proper under the federal officer removal statute, 28 U.S.C. § 1442(a)(1), because some of the challenged conduct was performed under contracts with federal agencies, such as the Department of Defense (TRICARE), the Office of Personnel Management (FEHBP), and the Veterans Health Administration. After removal, the plaintiffs amended their complaints to disclaim any claims based on the defendants’ work for federal clients, seeking to have the cases remanded to state court. The district courts accepted the disclaimers and remanded the cases. The United States Court of Appeals for the Second Circuit reviewed the district courts’ decisions. It concluded that the disclaimers were ineffective because the alleged wrongful conduct and resulting harms could not be separated between federal and non-federal clients; the conduct was indivisible. Relying on the Supreme Court's decision in Chevron USA Inc. v. Plaquemines Parish, the Second Circuit held that the defendants satisfied all statutory requirements for federal officer removal: they acted under federal direction, were sued for acts relating to federal authority, and asserted colorable federal defenses. The Second Circuit therefore reversed the remand orders and returned the cases to the district courts for further proceedings. View "County of Westchester v. Express Scripts" on Justia Law

United States v. DeFelice

2026-09-02T06:30:09-08:00

Federal agents began investigating the defendant in early 2021 after receiving information that he was operating a firearms manufacturing and dealing business from his home without the required federal license. Undercover agents arranged the purchase of a semi-automatic firearm and a high-capacity magazine from him, during which he described the magazine as “highly illegal.” Following a year-long investigation, law enforcement executed a search warrant and recovered two unregistered short-barreled rifles and an unregistered suppressor from his residence. A grand jury indicted the defendant on two counts: dealing and manufacturing firearms without a license under federal law, and possession of unregistered National Firearms Act (NFA) firearms (the rifles and suppressor). He moved to dismiss both counts, alleging the NFA violated his Second Amendment rights. The United States District Court for the District of Connecticut denied his motion, holding that the Second Amendment did not cover possession of unregistered rifles and suppressors. The defendant then entered a conditional guilty plea to the NFA count, preserving his right to appeal the denial and his sentence. He was sentenced to twelve months and one day in prison. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the defendant lacked standing to challenge the NFA as amended after his offense because the amendment was not retroactive. The court applied the Bruen framework, assumed without deciding that short-barreled rifles and suppressors are “arms,” but concluded the NFA’s registration and taxation requirements did not meaningfully constrain the defendant’s Second Amendment rights. The court also found no procedural or substantive error in the district court’s sentencing determination. The Second Circuit affirmed the judgment of the district court. View "United States v. DeFelice" on Justia Law

Siren Retail Corp. v. NLRB

2026-09-02T06:30:04-08:00

A group of employees at the Starbucks Reserve Roastery in New York City wore shirts displaying the name and logo of the Starbucks Workers United union during a national campaign to negotiate a first union contract. Following this, Starbucks asked the employees to change into attire compliant with the company’s dress code, which included policies limiting union-related and other insignia on clothing. Workers United responded by filing an unfair labor practice charge, alleging that Starbucks’ dress code policies violated employees’ rights under the National Labor Relations Act by restricting union expression. The National Labor Relations Board (NLRB) initiated administrative proceedings against Starbucks, focusing on three dress code policies: the One-Pin Policy (limiting employees to one union button), the Issue-Pin Policy (prohibiting buttons or pins advocating political, religious, or personal issues), and the Logo-Shirt Policy (restricting shirts with non-approved logos or writings). An Administrative Law Judge sided with Starbucks regarding the One-Pin Policy—relying on Second Circuit precedent from NLRB v. Starbucks Corp. (“Starbucks I”)—but found Starbucks violated the NLRA with its other policies, applying the Board’s more recent Tesla, Inc. standard. The NLRB reversed the ALJ’s One-Pin Policy finding and concluded all three dress code policies violated the NLRA. The United States Court of Appeals for the Second Circuit reviewed the case, granting Starbucks’ petition for review and denying enforcement of the NLRB’s decision invalidating the dress code policies. The court held that the Board’s Tesla test failed to properly balance employer and employee interests, as required by Supreme Court precedent, and that the One-Pin Policy was not an unfair labor practice under binding circuit precedent. The case was remanded to the NLRB for further analysis of the Issue-Pin and Logo-Shirt rules under a more balanced legal standard. View "Siren Retail Corp. v. NLRB" on Justia Law

Trireme Energy Development v. RWE Renewables

2026-09-01T06:00:03-08:00

This case concerns a dispute between two sophisticated energy companies over a merger agreement. In December 2017, Trireme entered into an agreement with Innogy Renewables US, LLC, a subsidiary of a German energy company, to transfer valuable development companies related to wind and solar projects in exchange for an upfront payment and the possibility of future milestone payments. The agreement included provisions restricting Innogy from transferring these assets without Trireme’s consent. After a complex asset swap and corporate restructuring involving Innogy’s parent company and other entities, Trireme alleged that the assets were transferred within the corporate family in violation of the agreement. Previously, Trireme filed a lawsuit—referred to as Trireme I—in the United States District Court for the Southern District of New York, alleging breaches of other sections of the merger agreement but not the section concerning asset transfers. Later, Trireme sought to amend its complaint to add this new breach-of-contract claim. The district court denied the motion to amend, finding that Trireme had not acted diligently to discover the claim and was on notice of the potential breach before filing the initial action. Trireme did not pursue an appeal of this denial but instead filed a new lawsuit asserting the same claim. The district court dismissed the new case on grounds of res judicata. The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s dismissal. The court held that when a party seeks to assert a claim in a new action after unsuccessfully moving to amend its complaint in a prior action, courts should consider several factors, including whether the denial was on the merits, whether the plaintiff failed to appeal, the timing of the claim, the plaintiff’s diligence, and whether the plaintiff was represented by counsel. Applying these factors, the Second Circuit concluded that res judicata barred Trireme’s new claim and affirmed the judgment. View "Trireme Energy Development v. RWE Renewables" on Justia Law

Skatteforvaltningen v. Markowitz

2026-08-31T06:30:16-08:00

Several individuals, including Richard and Jocelyn Markowitz, John and Elizabeth van Merkensteijn, and pension funds they controlled, were found by a jury to have defrauded the Danish tax authority (Skat) by submitting false claims for tax refunds. The defendants conceded before trial that they were never entitled to the refunds under the U.S.-Denmark tax treaty, admitting that they had not owned Danish shares or received dividends subject to Danish withholding tax. However, they argued that they had been misled by a London-based trading partner into believing otherwise and were unaware that the refund claims submitted on their behalf were fraudulent. The United States District Court for the Southern District of New York presided over the case after it was consolidated as part of multidistrict litigation. The defendants unsuccessfully moved to dismiss Skat’s claims, contending that the common law revenue rule barred the suit. The district court held that because the defendants never owned the relevant Danish stocks or paid taxes, Skat’s claims were for commercial fraud rather than enforcement of Danish tax law. After trial, the jury found each defendant liable, and the district court entered judgments totaling over $476 million based on Skat’s gross payments and prejudgment interest. On appeal, the United States Court of Appeals for the Second Circuit reviewed the case. The court held that Skat’s lawsuit was not barred by the revenue rule because it did not seek to enforce foreign tax laws, but rather sought recovery for fraud. The court also found no abuse of discretion in the district court’s exclusion of certain evidence and upheld the sufficiency of evidence supporting judgments against Jocelyn Markowitz and Elizabeth van Merkensteijn under an agency theory. The Second Circuit affirmed the district court’s judgment. View "Skatteforvaltningen v. Markowitz" on Justia Law

Dziedziach v. Blanche

2026-08-31T06:30:11-08:00

A native and citizen of Poland entered the United States without inspection in 1999 and adjusted to lawful permanent resident status in 2006. Between 2006 and 2008, he participated in a conspiracy to retaliate against employees who had sued his employer for wage violations, including hiring individuals to commit violent acts and intimidation. He pleaded guilty in 2012 to conspiracy to retaliate against witnesses and parties to an official proceeding, in violation of 18 U.S.C. § 1513(b) and (f), and was sentenced to 364 days’ imprisonment. Removal proceedings were initiated by the Department of Homeland Security. Before an Immigration Judge, he argued that his conviction was not for a crime involving moral turpitude (CIMT) and that the offense was not committed within five years of his admission. The Immigration Judge denied his motion to terminate removal, finding the conviction was categorically a CIMT and met the timing requirement. He sought relief under the Convention Against Torture and a hardship waiver, but was denied by a second Immigration Judge. The Board of Immigration Appeals (BIA) dismissed his appeal. On a previous petition for review, the United States Court of Appeals for the Second Circuit remanded for the BIA to reconsider the CIMT determination. The BIA again concluded the conviction was categorically a CIMT. The United States Court of Appeals for the Second Circuit reviewed the BIA’s decision. It held that conspiracy to retaliate against witnesses in violation of 18 U.S.C. § 1513(b) is categorically a crime involving moral turpitude, and that the CIMT ground for removability is not unconstitutionally vague as applied. The court also declined to reconsider arguments already rejected in the earlier petition. The petition for review was denied. View "Dziedziach v. Blanche" on Justia Law

Dolce v. Connetquot Cent. Sch. Dist.

2026-08-31T06:30:03-08:00

Three teachers at a public high school, who openly identify as members of the LGBTQ+ community, were directed by school district officials to remove pride flags and stickers from their classrooms. The officials cited a district policy that restricted displays to only the American and New York State flags, characterizing other flags and certain stickers as “political.” While the teachers complied, they alleged that other non-sanctioned displays, such as sports flags and stickers for student organizations, were allowed to remain. The teachers also recounted differing treatment regarding permission slips for an LGBTQ+ club field trip. They filed suit, claiming violations of their First and Fourteenth Amendment rights, as well as employment discrimination under federal, state, and local law. The United States District Court for the Eastern District of New York dismissed the complaint. The court found the individual officials entitled to qualified immunity on the First Amendment claims, ruled that there was no plausible showing of discriminatory intent for the equal protection claims, determined no adverse employment actions occurred for Title VII purposes, and declined to exercise supplemental jurisdiction over the state and local law claims. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment, though it relied on different reasoning for the First Amendment claim. The Second Circuit held that classroom wall and door decorations by teachers constitute speech pursuant to their official duties under Garcetti v. Ceballos, and therefore, the school district could regulate or restrict such speech without violating the teachers’ First Amendment rights. The court further held that the teachers failed to plausibly allege selective enforcement based on impermissible motives or any adverse employment actions, and found no abuse of discretion in the district court’s decisions regarding the state claims and leave to amend. View "Dolce v. Connetquot Cent. Sch. Dist." on Justia Law

United States v. Amerisource Bergen Corp.

2026-08-28T06:30:03-08:00

The plaintiff, a former Senior Reimbursement Manager at a national pharmacy provider, alleged that her employer engaged in a scheme to overcharge government healthcare programs such as Medicare and Medicaid. She claimed the company exploited billing system discrepancies and other tactics to cause overpayments, including billing for deceased patients and miscoding pharmacy types for higher reimbursements. The company allegedly concealed these overpayments in its internal accounting and, after a period, transferred the unreturned funds into its own revenues. The plaintiff reported these practices to management and internal audit, but the issues persisted. After filing a complaint in the United States District Court for the Eastern District of New York, the plaintiff amended her allegations. The District Court dismissed all federal claims with prejudice, finding that the plaintiff did not meet the heightened pleading standards for fraud required under Federal Rule of Civil Procedure 9(b) for “direct” False Claims Act (FCA) claims (those based on submitting fraudulent invoices or statements to the government). The court also denied leave to further amend the complaint, and denied reconsideration. On appeal, the United States Court of Appeals for the Second Circuit reviewed the case de novo. The Second Circuit affirmed the District Court’s dismissal of the plaintiff’s direct FCA claims, holding that she did not identify any specific fraudulent submissions to the government, nor adequately allege that such information was solely within the defendants’ control. However, the Second Circuit vacated the dismissal of the “reverse” FCA claim, which is based on knowingly retaining government overpayments. The court found the plaintiff sufficiently alleged that the company had an obligation to return identified overpayments and knowingly concealed or improperly avoided that obligation. The case was remanded for further proceedings on the reverse FCA claim. View "United States v. Amerisource Bergen Corp." on Justia Law

Lowell v. Lyft, Inc.

2026-08-27T06:00:04-08:00

Two plaintiffs, one individual and one advocacy organization, filed suit against a ridesharing company, alleging discrimination against persons with mobility-related disabilities. They claimed the company violated the Americans with Disabilities Act (ADA) and New York State Human Rights Law (NYSHRL) by failing to make wheelchair accessible vehicles (WAVs)—that accommodate fixed-frame wheelchairs—available in all regions it operates, instead of only nine cities. The plaintiffs proposed several modifications to the company’s policies and practices to increase WAV availability in Westchester County, New York, and sought class certification for affected residents and visitors. The United States District Court for the Southern District of New York held a bench trial. After reviewing the evidence, the court found that the plaintiffs failed to demonstrate either that the rideshare platform’s limited menu constituted a barrier to WAV access or that their proposed modifications would effectively or reasonably achieve WAV transportation in the relevant regions. The court also determined that the evidence did not show the proposed modifications were likely to be effective, and that the defendant’s proof established the modifications would not be reasonable. As a result, the district court dismissed the plaintiffs’ claims. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s findings for clear error and considered plaintiffs’ arguments regarding evidentiary burdens and the effectiveness of proposed modifications. The Second Circuit concluded that plaintiffs bore the burden of persuasion as to effectiveness, and only a light burden of production as to reasonableness. The appellate court found no error in the district court’s application of these standards and affirmed the judgment, holding that the plaintiffs failed to show their proposed modifications would effectively provide WAV service in Westchester County. View "Lowell v. Lyft, Inc." on Justia Law

Waters v. Kory

2026-08-26T06:30:03-08:00

An elderly patient, after contracting COVID-19, received remote medical treatment from an out-of-state physician who prescribed multiple medications, including prednisone. Prednisone is known to carry a risk of peptic ulcer disease, especially in older individuals, and the physician did not prescribe mitigating medication to counteract these side effects. The patient subsequently developed a perforated ulcer and died from organ failure. The estate brought suit against the physician for negligence, lack of informed consent, and violation of the Connecticut Unfair Trade Practices Act (CUTPA). The estate initially filed the action in Connecticut Superior Court, and the physician removed it to the United States District Court for the District of Connecticut. The physician moved to dismiss, arguing immunity under the Public Readiness and Emergency Preparedness Act (PREP Act) and contending the CUTPA claim was not viable. The District Court dismissed the CUTPA claim but denied the motion to dismiss the negligence and informed consent claims, concluding PREP Act immunity did not apply. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the physician qualified for PREP Act immunity because he was a licensed health professional who prescribed a covered countermeasure (prednisone) for COVID-19, and the prescription had a causal relationship with the patient’s death. The court also held that the CUTPA claim was impermissible because it was based on alleged professional negligence rather than business or entrepreneurial conduct. The Second Circuit affirmed the dismissal of the CUTPA claim, reversed the District Court’s denial of PREP Act immunity, and remanded for further proceedings. View "Waters v. Kory" on Justia Law

United States v. Bagley

2026-08-24T06:30:11-08:00

The defendant pled guilty to conspiring to traffic firearms after law enforcement in Bridgeport, Connecticut, discovered evidence linking him to the illegal purchase and distribution of about twenty guns. The investigation began when he arrived at a hospital with a gunshot wound, and further inquiry revealed multiple firearm purchases, sales to prohibited persons, and the use of tools to obliterate serial numbers. Messages found on his phone confirmed his awareness that his actions were unlawful and indicated attempts to cover up his conduct. The United States District Court for the District of Connecticut adopted the Presentence Report’s Guidelines range of 51 to 63 months but sentenced the defendant to 84 months’ imprisonment, an upward variance. The court justified this by referencing the seriousness of the offense, the number of firearms involved, the obliteration of serial numbers, the defendant’s knowledge that buyers were prohibited persons, and his failure to assist law enforcement in recovering the trafficked firearms. On appeal, the United States Court of Appeals for the Second Circuit reviewed the procedural and substantive reasonableness of the sentence. The appellate court held that the district court committed procedural error by increasing the sentence based, in substantial part, on the defendant’s refusal to cooperate with law enforcement, which is impermissible. Additionally, the district court erred by imposing an upward variance based on factors already included in the Guidelines calculation, without explaining why those factors warranted greater weight in this case, as required by United States v. Sindima. The Second Circuit found these errors to be plain and determined that they affected the fairness of the proceedings. Accordingly, the Second Circuit vacated the sentence and remanded the case for resentencing before a different district judge, to ensure the appearance of justice is preserved. View "United States v. Bagley" on Justia Law

United States v. VanHoesen

2026-08-24T06:30:04-08:00

The defendant was convicted in 2009 by a jury of four drug offenses involving crack cocaine, including conspiracy and possession with intent to distribute. The offenses involved quantities that, at the time, triggered severe mandatory minimum sentences under federal law. The defendant also had two prior New York State drug convictions, which increased his sentencing exposure. He was originally sentenced to life imprisonment and life terms of supervised release. After his conviction and sentence were affirmed by the United States Court of Appeals for the Second Circuit and certiorari was denied by the Supreme Court, the defendant sought relief under the First Step Act of 2018. The district court for the Northern District of New York first denied his motion for a reduced sentence but, following the Supreme Court’s decision in Concepcion v. United States and a remand from the Second Circuit, the district court resentenced him to time served and eight years of supervised release. The district court believed it had discretion to reduce the mandatory minimum supervised release term based on nonretroactive changes to the law and the Sentencing Guidelines. On appeal, the United States Court of Appeals for the Second Circuit reviewed whether the district court could impose a supervised release term below the eight-year statutory minimum set by 21 U.S.C. § 841(b)(1)(B) when resentencing under § 404(b) of the First Step Act. The court held that Congress made clear that changes to the mandatory minimums in § 401 of the First Step Act do not apply retroactively except in narrow circumstances not present here. The Supreme Court’s decision in Concepcion does not permit district courts to disregard applicable statutory mandatory minimums. Accordingly, the Second Circuit affirmed the district court’s judgment imposing an eight-year supervised release term. View "United States v. VanHoesen" on Justia Law

United States v. Martin

2026-08-21T06:30:10-08:00

Cory Martin was charged with murder-for-hire, conspiracy to commit murder-for-hire, fraud, and identity theft after he killed Brandy Odom in April 2018. Martin’s then-girlfriend, Adelle Anderson, had taken out life insurance policies on Odom and promised Martin the proceeds upon Odom’s death. Following the murder, Anderson attempted to collect on the fraudulent policies but was unsuccessful. Law enforcement discovered Odom’s remains, secured Anderson’s cooperation, and prosecuted Martin based in large part on Anderson’s testimony. The case was heard in the United States District Court for the Eastern District of New York. At trial, Martin argued Anderson was the mastermind and that he was uninvolved, but the jury rejected this, finding Martin guilty on all counts. Anderson, having cooperated, pleaded guilty in a separate proceeding and received probation due to her history of abuse and other mitigating factors. Martin was sentenced to life imprisonment for the murder-for-hire offenses, along with additional sentences for the fraud and identity theft charges. He appealed, challenging the sufficiency of the evidence, the adequacy of the jury instructions, the inclusion of an aiding-and-abetting instruction, and alleging spillover prejudice affecting his other convictions. 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 evidence was sufficient to support the murder-for-hire convictions under 18 U.S.C. § 1958, clarifying that the statute’s “consideration” requirement does not demand a formal employment relationship but rather a reciprocal inducement—an exchange of the murder for a promise of pecuniary value. The Second Circuit also found the jury instructions were proper, the aiding-and-abetting instruction was justified, and no impermissible spillover prejudice had occurred. The district court’s judgment was affirmed in all respects. View "United States v. Martin" on Justia Law

In re Grand Jury Subpoenas to the Office of the New York State Attorney General

2026-08-21T06:30:04-08:00

The case centers on whether John A. Sarcone III lawfully served as Acting U.S. Attorney for the Northern District of New York. After the departure of the Senate-confirmed U.S. Attorney, Sarcone was appointed as Interim U.S. Attorney for 120 days under 28 U.S.C. § 546. When his term expired, the district court did not appoint a permanent replacement, leaving the office vacant. The Department of Justice then reassigned the prior First Assistant to another role and designated Sarcone as the new First Assistant (FAUSA), claiming this made him Acting U.S. Attorney under the Federal Vacancies Reform Act of 1998 (FVRA). Sarcone subsequently issued two grand jury subpoenas to the New York State Attorney General’s Office regarding investigations into the National Rifle Association and Donald J. Trump. The United States District Court for the Northern District of New York granted the New York Attorney General’s motion to quash the subpoenas, holding that Sarcone had not lawfully become Acting U.S. Attorney under the FVRA since he was not the First Assistant at the time the vacancy arose. The court also found that the Attorney General’s general delegation of all U.S. Attorney duties to Sarcone was an impermissible circumvention of the FVRA. The court disqualified Sarcone from further involvement in the investigations. The United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The court held that the FVRA only permits automatic succession by a First Assistant who is already in office when the vacancy arises. It further held that a general delegation of all duties is not a lawful means to install an acting official, as it would undermine the FVRA’s exclusivity provision. Because the government did not substantively contest Sarcone’s disqualification on appeal, the court treated that issue as forfeited and affirmed the district court’s order. View "In re Grand Jury Subpoenas to the Office of the New York State Attorney General" on Justia Law

Juca v. Banks

2026-08-20T06:30:04-08:00

A parent of a teenager with developmental and physical disabilities challenged the adequacy of the educational services provided by a public school district under the Individuals with Disabilities Education Act (IDEA). The school district prepared an individualized education plan (IEP) for the child, but the parent disagreed and placed the child in a private school specializing in services for students with special needs. The parent filed administrative complaints for three consecutive school years (2022–23, 2023–24, and 2024–25), alleging the school district failed to provide a free appropriate public education (FAPE). The administrative process involved hearings before an Impartial Hearing Officer (IHO) and appeals to a State Review Officer (SRO), resulting in varied outcomes regarding whether the district must reimburse or directly fund the private placement. The litigation moved to the United States District Court for the Southern District of New York after the parent filed an amended complaint seeking enforcement of administrative decisions and a preliminary injunction compelling the district to fund the private placement. The district court dismissed the complaint, finding the parent had failed to exhaust administrative remedies under the IDEA for the 2023–24 and 2024–25 school years and had not plausibly alleged an exception to this requirement, such as a violation of the IDEA’s stay-put provision. The court also denied the motion for a preliminary injunction as moot. On appeal, the United States Court of Appeals for the Second Circuit held it had jurisdiction because the parent disclaimed any intent to amend the complaint. The appellate court affirmed the district court’s dismissal regarding the 2023–24 school year, finding no plausible allegation that the stay-put provision was violated and agreeing that administrative remedies were not exhausted. With respect to the 2024–25 school year, the court dismissed the appeal as moot because the parent had already obtained all requested relief through subsequent administrative proceedings and because the school year had ended. View "Juca v. Banks" on Justia Law

Fonden v. FDIC

2026-08-19T06:30:10-08:00

A Swedish government agency managing a public pension fund initiated a consolidated class action for securities fraud under Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5. The claims were brought against a third-party auditor and several former executives of a New York-based, federally insured commercial bank, which collapsed in 2023 after significant losses tied to a shift into cryptocurrency banking. The plaintiff alleged that the auditor and executives made false statements regarding the bank’s liquidity and risk management, leading to artificial inflation of the bank’s stock price and subsequent investor losses when the bank failed. After the bank’s collapse, the Federal Deposit Insurance Corporation (FDIC) was appointed as receiver. The FDIC intervened in the case and moved to dismiss, arguing that, under the Succession Clause of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA), it had succeeded to all rights of the bank’s stockholders regarding the institution and its assets, thus “owning” the securities fraud claims. The United States District Court for the Eastern District of New York agreed and dismissed the complaint for lack of prudential standing, concluding that the claims had transferred to the FDIC and that the plaintiff had not exhausted required administrative remedies. On appeal, the United States Court of Appeals for the Second Circuit reviewed the statutory interpretation of the Succession Clause. The court held that the Clause does not transfer to the FDIC individual securities fraud claims brought under Section 10(b) and Rule 10b-5, as these are not rights held by stockholders in their capacity as such, but rather as purchasers of securities. Additionally, the court found that administrative exhaustion was not required, as the claims were not against the failed bank or the FDIC as receiver. The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings. View "Fonden v. FDIC" on Justia Law

Wong v. Blanche

2026-08-19T06:30:03-08:00

A native of Hong Kong and citizen of China, the petitioner was admitted to the United States as a lawful permanent resident in 1979. He was later convicted in federal court of conspiracy to import heroin, but received a waiver of deportation. Subsequently, he pleaded guilty in New Jersey Superior Court to theft by deception, a disorderly persons offense, and was fined $200. He also pleaded guilty in New York Supreme Court to forgery in the second degree, receiving probation and a fine. The Department of Homeland Security initiated removal proceedings, asserting that he was removable for having been convicted of two crimes involving moral turpitude not arising from a single scheme. An Immigration Judge denied his motion to terminate proceedings, finding both state offenses constituted crimes involving moral turpitude and that the New Jersey theft by deception offense qualified as a “conviction” under the Immigration and Nationality Act. The Board of Immigration Appeals (“BIA”) affirmed, and after various remands to address specific issues—including whether the New York offense categorically qualified as a crime involving moral turpitude—the BIA again dismissed his appeal. The petitioner sought review in the United States Court of Appeals for the Second Circuit, which initially denied relief by deferring to the BIA’s interpretation under Chevron U.S.A. Inc. v. Natural Resources Defense Council. The Supreme Court then vacated that judgment and remanded for reconsideration in light of Loper Bright Enterprises v. Raimondo, which held courts must independently interpret statutes without deferring to agency interpretations. On remand, the United States Court of Appeals for the Second Circuit held that a “conviction” under 8 U.S.C. § 1101(a)(48)(A) requires a formal judgment of guilt resulting from a criminal proceeding with minimum constitutional protections and culminating in a criminal sentence. Applying this standard, the court found the petitioner’s New Jersey offense met these criteria and denied his petition for review. View "Wong v. Blanche" on Justia Law

United States v. Valder

2026-08-18T06:00:13-08:00

A defendant, while on federal supervised release for a prior child pornography conviction, was found in possession of an unauthorized smartphone, which led authorities to discover significant amounts of child pornography, including images and videos depicting two minor brothers whom he had sexually abused over several months. The ensuing investigation and trial revealed repeated sexual exploitation of both boys. The defendant was indicted on four federal charges: two counts of sexual exploitation of a child, one count of receipt of child pornography, and one count of committing a felony while a registered sex offender. The indictment also cited a prior 2010 New York state conviction for first-degree criminal sexual act by forcible compulsion involving a 14-year-old boy. The United States District Court for the Northern District of New York conducted a jury trial, which resulted in guilty verdicts on all counts. The jury specifically found, with respect to the sexual exploitation charges, that the defendant had a prior sex conviction involving a minor. At sentencing, the district court imposed mandatory life sentences on the two exploitation counts under 18 U.S.C. § 3559(e)(1), a 40-year sentence for receipt of child pornography, and a consecutive 10-year sentence for committing a felony while a registered sex offender. The district court stated that, even absent the statutory life mandate, it would have imposed a sentence of 150 years. On appeal to the United States Court of Appeals for the Second Circuit, the defendant challenged only the imposition of the mandatory life sentences, arguing that his New York conviction did not categorically qualify as a “prior sex conviction in which a minor was the victim” under § 3559(e)(1). The Second Circuit held that the minor-victim requirement is circumstance-specific and was satisfied here. It further held that the New York statute was a categorical match to a “Federal sex offense” under the federal statute. The court affirmed the challenged judgment. View "United States v. Valder" on Justia Law

Belya v. Kapral

2026-08-18T06:00:04-08:00

A priest formerly affiliated with the Russian Orthodox Church Outside of Russia (ROCOR) brought suit against various church leaders and entities, alleging defamation. He claimed that leaders within ROCOR falsely accused him of forging letters from church officials that purportedly announced his election as a bishop. The priest maintained that he had been chosen for elevation, and that the accusations of forgery, which circulated within the church and were subsequently posted online, damaged his reputation and led to his suspension and eventual removal from clerical office. The United States District Court for the Southern District of New York, upon reassignment to a new judge, granted summary judgment to the defendants. The court found that the plaintiff failed to present sufficient evidence under New York defamation law linking the defendants to the public dissemination of the allegedly defamatory statements. Additionally, the court held in the alternative that the lawsuit was barred by the First Amendment’s church autonomy doctrine, as adjudicating the claims would require the court to intrude upon religious questions regarding ROCOR’s selection, supervision, and discipline of clergy, as well as its internal governance protocols. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision, focusing on the constitutional ground. The Second Circuit held that the First Amendment’s church autonomy doctrine prevents civil courts from adjudicating claims that would interfere with a religious organization’s management of its ministers or require secular courts to resolve disputes over church protocols and internal governance. The court concluded that the plaintiff’s claims, whether based on internal or public statements, were barred because their resolution would necessitate unconstitutional entanglement in matters of church governance and doctrine. View "Belya v. Kapral" on Justia Law

Stinn v. United States of America

2026-08-17T06:30:22-08:00

Bradley Stinn, a former chief executive officer of a large jewelry retailer, was convicted in 2009 of securities fraud, mail fraud, and conspiracy. The charges stemmed from a scheme in which Stinn and others allegedly concealed the substantial risk of customer defaults in the company’s credit-extension program, thereby fraudulently inflating the company’s financial reports. As a result, Stinn received a significant bonus and salary increase that were tied to the company’s reported earnings. The company ultimately went bankrupt, and Stinn served a sentence of imprisonment and supervised release. The United States District Court for the Eastern District of New York presided over Stinn’s trial, where the jury was instructed it could convict under either a traditional fraud theory or the now-invalidated right-to-control theory. The jury returned a general verdict of guilty, and Stinn unsuccessfully challenged his conviction on direct appeal and in a habeas petition. After the Supreme Court in Ciminelli v. United States rejected the right-to-control theory, Stinn filed a petition for a writ of error coram nobis, seeking to vacate his conviction on the grounds that the jury may have relied on an invalid theory. The district court denied the petition, holding that any error was harmless because sufficient evidence supported the conviction under the traditional fraud theory. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the standard for harmless error in coram nobis proceedings is that articulated in Kotteakos v. United States, which requires a petitioner to show that the error had a substantial and injurious effect on the verdict. The court found that Stinn failed to meet this burden, as the evidence overwhelmingly supported conviction under the traditional fraud theory. Thus, the denial of coram nobis relief was affirmed. View "Stinn v. United States of America" on Justia Law

Massimino v. Benoit

2026-08-17T06:30:10-08:00

The case concerns a man who recorded video of the exterior of a police station from a public sidewalk in Waterbury, Connecticut. After several minutes of filming publicly visible parts of the station—including police vehicles and the entrance to a division—he was approached by two police officers. When questioned, he stated that he was a journalist but declined to answer follow-up questions or provide identification, even after being told it was a lawful order. He was arrested for interfering with police under Connecticut law and detained for several hours. The criminal charge was eventually dismissed more than two years later. He then brought suit in the United States District Court for the District of Connecticut, alleging violations of his First and Fourth Amendment rights and claiming malicious prosecution under 42 U.S.C. § 1983. The officers argued that they were entitled to qualified immunity. The District Court granted summary judgment for the officers on all claims, holding that the right to record a police station was not clearly established at the time, that the officers had reasonable suspicion for the initial detention, and probable cause for the arrest and subsequent prosecution. On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court’s judgment. The Court of Appeals recognized a First Amendment right to record law enforcement activity in public, including the right to record the exterior of a police building from a sidewalk. However, it held that this right was not clearly established at the time of the incident, so the officers were entitled to qualified immunity on the First Amendment claim. The court also found the officers had reasonable suspicion for the initial detention and probable cause for the arrest based on the plaintiff’s refusal to provide identification, defeating the Fourth Amendment and malicious prosecution claims. The judgment for the officers was affirmed. View "Massimino v. Benoit" on Justia Law

Batista-Reyes v. Paul

2026-08-17T06:30:03-08:00

In December 1993, a man was assaulted and robbed in a Troy, New York motel. The police investigation led by Sergeant Robert Paul focused on Luis Batista-Reyes as the main suspect, relying on written statements from two women, Laura Ashley Pullen and Shannon Houser, who identified Batista-Reyes as the perpetrator. Pullen became the key witness, testifying against Batista-Reyes before the grand jury and at trial. Batista-Reyes was convicted by a jury on all counts and sentenced to 25 years to life in prison. Years later, in 2002, Pullen recanted her testimony in several letters, claiming Batista-Reyes was innocent and that she had been coerced by the prosecutor and possibly others into giving false statements. Based on these recantations, a special prosecutor re-investigated the case in 2016, concluding Pullen’s original testimony was untruthful and that the remaining evidence was weak. The state court subsequently vacated Batista-Reyes’s conviction and dismissed the indictment, resulting in his release after more than 24 years in prison. Batista-Reyes then filed a civil rights lawsuit against Paul in the U.S. District Court for the Northern District of New York, alleging malicious prosecution and fabrication of evidence under 42 U.S.C. § 1983. The district court granted summary judgment for Paul, finding no genuine disputes of material fact regarding the alleged constitutional violations. Batista-Reyes appealed. The United States Court of Appeals for the Second Circuit held that Batista-Reyes had presented sufficient evidence to create genuine disputes of material fact on both claims, particularly regarding whether Paul coerced or fabricated evidence and whether probable cause existed. The court concluded the district court erred in granting summary judgment and reversed and remanded the case for further proceedings. View "Batista-Reyes v. Paul" on Justia Law

United States v. Matos

2026-08-13T06:30:15-08:00

The case concerns a defendant who was involved in a drug trafficking organization in Syracuse, New York. The defendant played a central role by identifying suppliers, coordinating purchases, managing operations, and arranging for shipments of drugs. After law enforcement intercepted a cocaine shipment and found heroin at his residence, the defendant was indicted on federal drug conspiracy and possession charges. He entered a plea agreement, in which he agreed to waive his right to appeal any sentence of 135 months or less. After the indictment in the United States District Court for the Northern District of New York, the defendant pled guilty. During the plea process, both the government and the defendant estimated a lower criminal history category. However, the Presentence Investigation Report assigned a higher criminal history category based on the defendant’s prior convictions and parole history. The district court adopted this calculation and sentenced the defendant to 100 months in prison, with a five-year supervised release. The sentence included standard and special conditions, some of which were referenced by standing order but not specifically read at sentencing. On appeal to the United States Court of Appeals for the Second Circuit, the defendant argued that the district court erred in calculating his criminal history and imposed a substantively unreasonable sentence, and further challenged two supervised release conditions not specifically pronounced at sentencing. The Second Circuit held that the appeal waiver in the plea agreement was enforceable and barred challenges to the sentence calculation or length, as such claims did not meet the “miscarriage of justice” exception set forth in United States v. Hunter. The court also held that referencing the standing order sufficed for oral pronouncement of the conditions, and while the district court erred by not conducting an individualized assessment for the two challenged conditions, the error was harmless because the reasons were clear from the record. The appeal was dismissed in part and the district court's judgment was affirmed. View "United States v. Matos" on Justia Law

United States v. Leeper

2026-08-13T06:30:07-08:00

The case concerns a defendant who was involved in the distribution and sale of methamphetamine across Indiana, California, and New York. During a drug transaction in California, the defendant, believing he had been shortchanged, abducted two individuals. He ultimately bound and murdered one of them, then traveled to New York with his accomplices. Later, while driving in New York, the defendant was stopped by police, who detained him after finding the vehicle was unregistered and neither occupant had a valid license. An inventory search of the vehicle uncovered a firearm, ammunition, and methamphetamine. Following his arrest, further investigation linked him to the California homicide. Police obtained a warrant for a buccal swab to collect his DNA, which was supported by a probable cause affidavit referencing evidence from the crime scene. The United States District Court for the Northern District of New York, after an evidentiary hearing, denied the defendant’s motions to suppress the evidence obtained from his vehicle and the DNA sample. The court found the impoundment and search of the vehicle reasonable under the circumstances, and ruled that the warrant for the DNA sample was supported by probable cause. It also concluded that the ex parte issuance of the DNA warrant did not violate due process. The defendant subsequently pleaded guilty to three charges but reserved the right to appeal these suppression rulings. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The appellate court held that the warrant application established probable cause for the DNA search, that the defendant was not entitled to pre-issuance notice or a hearing before the DNA warrant was issued, and that the officers’ decision to hold and search the vehicle was reasonable under the Fourth Amendment. Thus, the convictions and evidence obtained were upheld. View "United States v. Leeper" on Justia Law

UMB Bank v. Bristol-Myers

2026-08-13T06:30:04-08:00

Bristol-Myers acquired Celgene in 2019 and, as part of the transaction, issued contingent value rights (CVRs) to Celgene shareholders. These CVRs entitled holders to a one-time payment if certain FDA approvals were obtained by specified deadlines. The CVR Agreement established a trust to benefit CVR holders, with Equiniti Trust Company as the original trustee. After concerns that Equiniti was affiliated with Bristol-Myers, a majority of CVR beneficial owners sought to appoint UMB Bank as successor trustee. UMB, acting as trustee, later sued Bristol-Myers alleging breach of its diligent efforts obligations under the Agreement. The United States District Court for the Southern District of New York dismissed UMB’s claims for lack of subject matter jurisdiction, holding that UMB lacked Article III standing because it was not properly appointed as trustee under the strict terms of the CVR Agreement. The district court found UMB’s appointment invalid, and concluded this defect implicated standing and thus could not be cured. Bristol-Myers conditionally cross-appealed the district court’s denial of a prior motion to dismiss on alternative grounds. The United States Court of Appeals for the Second Circuit reversed, holding that any defects in UMB’s appointment implicated its capacity to sue, not Article III standing. The court determined that injuries to the trust and its beneficiaries provided standing, and that UMB’s claims as trustee did not require UMB to have suffered personal injury. The Second Circuit further concluded that, even if UMB’s appointment did not strictly comply with the Agreement, the conduct of both Bristol-Myers and Equiniti, along with the approval of a majority of beneficial owners, constituted waiver or ratification, precluding Bristol-Myers from challenging UMB’s capacity to act. The appellate court vacated the district court’s judgment, dismissed the cross-appeal, and remanded the case for further proceedings. View "UMB Bank v. Bristol-Myers" on Justia Law

Mehrotra v. U.S. Dep't of Lab.

2026-08-11T07:00:03-08:00

The petitioner, a former project manager at a large corporation, raised internal compliance concerns in 2018. In April 2019, he was notified that he would be subject to a reduction in force and laid off, effective June 21, 2019. He subsequently filed several internal complaints alleging that his layoff and the company’s refusal to rehire him for numerous positions were retaliatory acts in response to his whistleblowing. After his layoff, he was placed on short-term disability and given a period during which he could apply for other positions within the company, but his applications were unsuccessful. Following these events, the petitioner filed a whistleblower-retaliation complaint under the Sarbanes–Oxley Act (SOX) with the Occupational Safety and Health Administration in December 2020. OSHA dismissed the complaint as untimely. The petitioner then sought review before an administrative law judge (ALJ), who held a hearing and dismissed the claims as untimely, also finding that equitable tolling was not warranted. The petitioner appealed, and the Administrative Review Board (ARB) affirmed the ALJ’s dismissal. On review, the United States Court of Appeals for the Second Circuit determined that the ARB did not err in finding the claims untimely. The court held that the SOX 180-day filing window begins when the employee is notified of the adverse action or when the refusal to rehire becomes apparent, not the last date of employment or the date of final application rejection. The court also found no basis for equitable tolling, as the petitioner knew or should have known of the alleged retaliation well before the statutory deadline. Accordingly, the Second Circuit denied the petition for review. View "Mehrotra v. U.S. Dep't of Lab." on Justia Law

Becerra-Paez v. Syracuse University

2026-08-11T06:30:07-08:00

In this case, the plaintiff, a student at Syracuse University, alleged that the university breached an implied-in-fact contract or was unjustly enriched by refusing to provide a partial refund of tuition and fees after transitioning to online-only education due to the COVID-19 pandemic. The student’s claims centered on the argument that he and other students paid for an in-person educational experience and associated campus services, which were not provided during the remote learning period. The university maintained that it was not obligated to provide refunds under the circumstances. The United States District Court for the Northern District of New York dismissed the complaint. The district court applied the law of the case from a previous, similar lawsuit (Poston v. Syracuse University) and, alternatively, held that the complaint failed to state a claim under Federal Rule of Civil Procedure 12(b)(6). The district court reasoned that the plaintiff had not alleged a sufficiently specific promise by the university to provide exclusively in-person instruction or services in exchange for the tuition and fees at issue. On appeal, the United States Court of Appeals for the Second Circuit noted a split between federal and New York state courts regarding what must be pleaded to state a claim for breach of contract in the context of COVID-19-related transitions to remote learning. Given this unresolved issue of New York law, the Second Circuit certified the following question to the New York Court of Appeals: whether a student seeking a tuition refund must allege a specific promise of exclusively in-person learning, or whether alleging a generally implied promise of in-person education and access to campus facilities is sufficient. The Second Circuit reserved decision on all claims pending the New York Court of Appeals’ response. View "Becerra-Paez v. Syracuse University" on Justia Law

Glover v. Connecticut General Life Insurance Company

2026-08-11T06:30:03-08:00

A group of life insurance policyholders sued Connecticut General Life Insurance Company and The Lincoln National Life Insurance Company, claiming that the companies wrongfully deducted inflated “cost of insurance” charges from the value of their life insurance policies. The lead plaintiff purchased her policy from Connecticut General, which was later administered by Lincoln following a business acquisition. The litigation in Connecticut overlapped with three similar class actions brought in Pennsylvania and New York against Lincoln and related companies, all alleging similar overcharging schemes. After years of litigation, the plaintiffs in the Connecticut case reached a settlement agreement with the defendants. This settlement aimed to resolve not only the Connecticut action but also the related actions in Pennsylvania and New York. Some class members from the related actions objected, arguing that the proposed settlement class failed to meet the requirements of Federal Rule of Civil Procedure 23, specifically the requirement that the claims of the class representatives be “typical” of those of the class. They pointed out that the named plaintiffs had policies directly issued by Connecticut General or Lincoln and could easily establish privity of contract, while many class members had policies issued by other Lincoln affiliates and would struggle to prove such privity. The United States District Court for the District of Connecticut rejected these objections, certified the settlement class, approved the settlement, and entered judgment for the plaintiffs. The objectors appealed. The United States Court of Appeals for the Second Circuit held that the typicality requirement of Rule 23(a)(3) was not met, relying on its prior decision in Mazzei v. Money Store, 829 F.3d 260 (2d Cir. 2016). The court found that the named plaintiffs’ claims were not typical because their ability to prove privity of contract was not shared by a substantial portion of the class. The Second Circuit reversed the class certification, vacated the judgment, and remanded for further proceedings. View "Glover v. Connecticut General Life Insurance Company" on Justia Law

Rosenthal v. Roosevelt Island Operating Corporation

2026-08-10T06:30:03-08:00

A former President and CEO of the Roosevelt Island Operating Corporation (RIOC), a public benefit corporation in New York, was terminated in June 2020 after an internal investigation into complaints of offensive remarks. On the same day as her termination, a senior adviser to the New York Governor’s Office provided statements to the press alleging that she was dismissed for making racially and sexually offensive comments. The former executive denied these allegations and asserted that her firing was actually retaliation for her complaints about public safety risks on Roosevelt Island and that state officials deliberately spread false allegations about her. After her termination, the former executive initiated two separate proceedings in New York State courts. First, she brought a CPLR Article 78 proceeding in New York Supreme Court, challenging her dismissal as arbitrary and capricious and seeking reinstatement and back pay. The court dismissed her petition, finding a rational basis for her termination and noting that more extensive factual disputes belonged in a plenary action, not an expedited Article 78 proceeding. The Appellate Division, First Department, affirmed. While the Article 78 proceeding was pending, she also commenced a plenary action in New York Supreme Court, raising discrimination, defamation, whistleblower, and federal civil rights claims under 42 U.S.C. § 1983. The court dismissed her discrimination claims with prejudice as precluded by the Article 78 judgment, but dismissed her § 1983 and other non-discrimination claims without prejudice, inviting her to refile them in an appropriate forum. The United States Court of Appeals for the Second Circuit reviewed whether the doctrine of res judicata barred her federal § 1983 claim. The court held that under New York law, res judicata does not preclude a claim dismissed without prejudice and with express leave to refile, even if other claims from the same transaction were dismissed on the merits. Therefore, the district court’s dismissal on res judicata grounds was vacated and the case was remanded for further proceedings. View "Rosenthal v. Roosevelt Island Operating Corporation" on Justia Law

Salters v. N.Y.C. Transit Auth.

2026-08-07T07:00:03-08:00

The case involves a car accident in which the plaintiff was seriously injured after colliding with a municipal bus operated by an employee of the New York City Transit Authority. The plaintiff filed a state law tort action in the United States District Court for the Eastern District of New York, alleging negligence by both the Transit Authority and the bus driver. Both parties requested a jury trial, and a Magistrate Judge was assigned to preside over jury selection. During jury selection, defense counsel used all peremptory strikes on three Black prospective jurors. The plaintiff’s counsel raised a Batson v. Kentucky challenge, arguing that the strikes were racially motivated. The Magistrate Judge requested race-neutral explanations from defense counsel, who provided reasons related to the jurors’ perceived education, employment, and demeanor. The plaintiff contended these explanations were pretextual. The Magistrate Judge overruled the Batson objection, finding the explanations race-neutral without explicitly assessing their credibility as required by Batson's third step. The trial then proceeded before a District Judge, who, after an eight-day trial, received a jury verdict in favor of the defendants, resulting in dismissal of the plaintiff’s claims with prejudice. On appeal, the United States Court of Appeals for the Second Circuit reviewed the plaintiff’s claims that he was denied a fair trial and that his Batson rights were violated during jury selection. The court rejected the fair-trial claim, finding no prejudicial conduct by the trial judge. However, the Second Circuit held that the Magistrate Judge erred by not making an explicit credibility determination regarding the race-neutral reasons for the peremptory strikes. The court remanded the case to the District Court to conduct a Batson reconstruction hearing or, if such a hearing is no longer feasible, to order a new trial. View "Salters v. N.Y.C. Transit Auth." on Justia Law

Farrington v. Poole

2026-08-06T07:00:08-08:00

The plaintiff, formerly incarcerated at Albany County Correctional Facility, brought claims against several corrections officers alleging excessive force during an altercation that occurred after his parole had been revoked. He was initially arrested and detained for an alleged parole violation, participated in a parole violation hearing, and stayed at the facility until his transfer to state custody. The incident in question involved the officers either using or observing the use of force to subdue him during a physical confrontation. The United States District Court for the Northern District of New York reviewed the plaintiff’s complaint, which asserted violations of both the Eighth and Fourteenth Amendments. The defendants moved for summary judgment. The district court granted the motion in part and denied it in part. It determined that the Fourteenth Amendment provided the governing standard for the plaintiff’s excessive force claims because the court found the record unclear as to whether the plaintiff had received a final adjudication on his parole violation prior to the incident. Therefore, the Eighth Amendment claims were dismissed, and the court held that factual disputes precluded summary judgment on the Fourteenth Amendment claims, also denying qualified immunity to the defendants. On appeal, the United States Court of Appeals for the Second Circuit concluded that the district court erred in applying the Fourteenth Amendment standard. The appellate court took judicial notice of the transcript from the plaintiff’s parole revocation hearing, which clearly demonstrated that the plaintiff pled guilty and had his parole formally revoked before the incident. The court held that the Eighth Amendment, not the Fourteenth Amendment, governs excessive force claims for individuals who have received a final adjudication and had parole revoked. The order of the district court was vacated and the case remanded for further proceedings under the Eighth Amendment standard. View "Farrington v. Poole" on Justia Law

The Retail Property Trust v. Nassau Cnty. Dep't of Assessment

2026-08-06T06:30:13-08:00

A commercial property owner that operates a large shopping mall in Nassau County, New York, was fined approximately $4.8 million by county officials for failing to provide financial information as required under the county’s Annual Statement of Income and Expenses (ASIE) Law. This law mandates commercial property owners to report financial data to county assessors or face a fine calculated as a percentage of the property’s market value. The property owner did not submit the required statements for two consecutive years and was subsequently notified of the fine. After receiving notice of the penalty, the property owner filed suit in the United States District Court for the Eastern District of New York, rather than pursuing remedies under state law or contesting the fine through state administrative proceedings. The owner argued that the ASIE Law and the resulting penalty violated the Eighth Amendment’s Excessive Fines Clause, the Fourteenth Amendment’s Due Process Clause, and several state laws. The district court granted summary judgment in favor of Nassau County and its officials, finding that the fine was not excessive, that adequate procedural due process was available through an Article 78 state court proceeding, and that the ASIE Law did not violate substantive due process. The district court also denied the owner’s motion for sanctions against the county, finding no evidence of bad faith or egregious conduct. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the Excessive Fines Clause applies to business entities, including trusts, and that the fine imposed was not grossly disproportional to the offense. The court further found that the available procedures satisfied due process requirements and that the ASIE Law was rationally related to a legitimate government interest. The denial of sanctions was also upheld. View "The Retail Property Trust v. Nassau Cnty. Dep't of Assessment" on Justia Law

United States v. Browning

2026-08-06T06:30:10-08:00

The defendant was convicted of Hobbs Act robbery after pleading guilty to robbing a Brooklyn smoke shop with three co-conspirators, during which he and another individual brandished firearms and physically restrained the clerk. The incident occurred while the defendant was already under supervision for prior criminal conduct, and he had a substantial criminal history including multiple violent offenses. During the robbery, the clerk managed to alert an associate using an Apple Watch, leading to police intervention and the defendant’s arrest. In a subsequent search, firearms were recovered from the scene. The case was reviewed by the United States District Court for the Eastern District of New York, which sentenced the defendant to 72 months’ imprisonment and three years of supervised release. The court adopted recommendations from the Presentence Investigation Report, including a special condition of supervised release authorizing searches of his person, property, residence, vehicle, and electronic communications if there was reasonable suspicion of a violation. The defendant objected specifically to the electronic communications portion of the search condition during sentencing, arguing it was not justified given the facts of the case. The United States Court of Appeals for the Second Circuit considered the appeal. The defendant argued that the district court failed to make an individualized assessment or adequately explain its reasons for imposing the electronic search condition, and that the condition was substantively unreasonable. The Second Circuit rejected these arguments, holding that the district court’s adoption of the PSR and its stated reasons met procedural requirements, that the condition was substantively reasonable given the defendant’s history and need for supervision, and that the inclusion of electronic searches was permissible even absent direct evidence of their use in the offense. The judgment of the district court was affirmed. View "United States v. Browning" on Justia Law

SEC v. Rogas

2026-08-06T06:30:03-08:00

The case involves civil actions brought by the Securities and Exchange Commission (SEC) against Adam P. Rogas, arising from his fraudulent conduct between January 2018 and June 2020 while serving as CEO of NS8, Inc., a technology company. Rogas falsified NS8’s bank statements to inflate revenue and customer numbers, which were then used in financial statements provided to investors. This deception enabled NS8 to raise approximately $149 million in securities offerings, with Rogas personally profiting over $17.5 million. Despite internal whistleblower reports and federal subpoenas, Rogas continued his fraudulent activities until his resignation in September 2020. After the fraud was uncovered, the SEC initiated a civil action in the United States District Court for the Southern District of New York, obtaining a temporary restraining order and subsequent asset freeze covering Rogas’s assets, including funds held for his benefit. Rogas was also criminally prosecuted and convicted of securities fraud. In the civil proceeding, an interim consent judgment was entered, holding Rogas liable for disgorgement and permanently enjoining him from violating securities laws. Rogas and his attorneys at Pillsbury Winthrop Shaw Pittman LLP (Pillsbury) disputed the application of the asset freeze to a $4 million retainer Pillsbury received from Rogas. The United States Court of Appeals for the Second Circuit reviewed two appeals: Rogas’s challenge to a lifetime bar from serving as an officer or director of a public company, and Rogas and Pillsbury’s challenge to the asset freeze covering the retainer. The Court affirmed both district court orders, holding that the lifetime bar was warranted given Rogas’s egregious, systematic fraud and likelihood of recidivism, and that Pillsbury was required to turn over the retainer funds, as they were held for Rogas’s benefit and covered by the asset freeze. View "SEC v. Rogas" on Justia Law

DoorDash, Inc. v. City of New York

2026-08-05T07:00:13-08:00

In this case, several major third-party food delivery platforms operating in New York City challenged a city ordinance enacted in 2021. The law required these platforms to share specific customer information—including full name, phone number, email address, delivery address, and order contents—with restaurants upon request. Typically, platforms retain this data and provide only limited details to restaurants. The platforms argued that the law forced them to disclose information about their customers, implicating First Amendment protections against compelled speech. Prior to this appeal, the United States District Court for the Southern District of New York reviewed cross-motions for summary judgment. The district court determined that the law compelled speech by requiring platforms to share customer data, and concluded that the deferential standard from Zauderer v. Office of Disciplinary Counsel of the Supreme Court of Ohio did not apply. Instead, the court applied the intermediate scrutiny standard from Central Hudson Gas & Electric Corp. v. Public Service Commission of New York and found the law could not survive that review. The district court granted summary judgment to the platforms and permanently enjoined enforcement of the law against their Marketplace products. The United States Court of Appeals for the Second Circuit reviewed the case on appeal. The City argued that Zauderer’s deferential standard should apply and, alternatively, that the law was valid under intermediate scrutiny. The Second Circuit disagreed, holding that Zauderer did not apply because the law compelled disclosure about third parties, not about the platforms’ own services. Applying Central Hudson’s intermediate scrutiny, the court found the law failed because the City had not shown a reasonable fit between its interests and the law’s means, especially given less burdensome alternatives. The Second Circuit affirmed the district court’s judgment, holding the law unconstitutional as applied to the platforms’ Marketplace products. View "DoorDash, Inc. v. City of New York" on Justia Law

United States ex rel. Chiles v. Cooke Inc.

2026-08-05T07:00:03-08:00

Two individuals, acting as relators on behalf of the United States, brought a qui tam action against several corporate and individual defendants. They alleged that the defendants engaged in a fraudulent scheme to secure fishing endorsements by misrepresenting the citizenship status of the entity applying for those endorsements. This misrepresentation allowed an ineligible non-U.S. entity to obtain endorsements and harvest menhaden, a commercially valuable fish, from U.S. waters. The relators claimed that these actions violated the False Claims Act by inducing federal authorities to issue fishing endorsements based on false information and by enabling the defendants to illegally profit from harvesting fish to which they were not entitled. The United States District Court for the Southern District of New York reviewed the amended complaint and granted the defendants’ motion to dismiss. The court found that the relators could not demonstrate that defendants made a claim for property as required under several subsections of the False Claims Act. It also concluded that the relators failed to show the defendants avoided or decreased any established obligation to pay money to the United States, as necessary for a reverse false claim. The district court further denied the relators’ request for leave to file an additional amended complaint. The United States Court of Appeals for the Second Circuit considered the relators’ appeal. The court held that wild fish in public waters are not “property” under the False Claims Act, foreclosing the first three causes of action. It also determined that unassessed civil penalties for alleged violations of the American Fisheries Act do not constitute an “obligation to pay” under the Act, defeating the reverse false claim. Finally, the Second Circuit concluded the district court did not abuse its discretion in denying leave to amend, and affirmed the district court’s judgment. View "United States ex rel. Chiles v. Cooke Inc." on Justia Law

Al Saidi v. Blanche

2026-08-03T06:30:09-08:00

The petitioner, a Yemeni national, sought deferral of removal under the Convention Against Torture, arguing he would likely be tortured if returned to Yemen due to an ongoing feud with the Balwi family, who allegedly aligned with the Houthis. He claimed past persecution and continuing threats, including incidents both in Yemen and after arriving in the United States. However, he failed to provide testimony or affidavits from close family members—his wife, sister, and adoptive father—who were knowledgeable about the feud and available to testify. After being convicted of first-degree assault in New York, the petitioner was placed in removal proceedings. The Immigration Judge (IJ) denied his application for relief under CAT on two independent grounds: first, the lack of reasonably available corroborating evidence from key relatives, and second, the failure to establish, on the merits, that it was more likely than not he would be tortured if returned to Yemen. The IJ noted inconsistencies and vagueness in testimony but did not make an explicit adverse credibility finding. The Board of Immigration Appeals (BIA) affirmed, adopting the IJ's reasoning and determining that the petitioner forfeited any challenge to the corroboration requirement by failing to raise it in his administrative appeal. The United States Court of Appeals for the Second Circuit reviewed the case. It held that the BIA did not abuse its discretion in finding the corroboration challenge forfeited and clarified that an IJ may require corroboration whenever it would be reasonably expected and helpful, regardless of an adverse credibility finding. The court further held that lack of corroboration was an independent and valid basis for denying CAT relief, and the agency’s decision was supported by substantial evidence. The petition for review was denied. View "Al Saidi v. Blanche" on Justia Law

Mueller v. Deutsche Bank AG

2026-08-03T06:30:03-08:00

Several family members and estates of three Americans who were kidnapped, enslaved, and ultimately murdered by ISIS brought a civil suit against a major bank, alleging that the bank violated the Trafficking Victims Protection Reauthorization Act (TVPRA). The plaintiffs claimed the bank facilitated a global fundraising operation that supported ISIS and its affiliates. Specifically, they alleged the bank provided financial services to two European, al-Qaeda-affiliated customers who conducted VAT fraud schemes, and also provided banking services to banks in Iraq after those institutions came under ISIS control. The plaintiffs argued that these actions allowed ISIS and its affiliates to raise and move funds, thereby enabling their human trafficking and related crimes. The United States District Court for the Southern District of New York ruled on the bank’s motion to dismiss. The district court declined to dismiss for lack of personal jurisdiction but dismissed the plaintiffs’ TVPRA claims for failure to state a claim. It determined that the complaint did not plausibly allege that the bank’s routine business transactions amounted to “participation in a venture” with ISIS or its affiliates, as required by the statute. The United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal de novo. The Second Circuit affirmed the dismissal, holding that the plaintiffs did not plausibly allege the bank’s conduct rose to the level of participation in a venture under the TVPRA. The court clarified that arm’s-length financial services, even if they carry financial benefit or involve risk, do not constitute “participation” in a venture without more specific involvement, such as shared purpose or operational control. The Second Circuit did not address other elements of the TVPRA claim, deciding the case solely on the participation element. View "Mueller v. Deutsche Bank AG" on Justia Law

Yousefzadeh v. Johnson & Johnson Consumer Inc.

2026-07-30T06:30:03-08:00

Buyers of over-the-counter nasal decongestants containing oral phenylephrine brought numerous class actions against drug manufacturers and retailers, alleging that for years these companies sold and advertised decongestant products they knew to be ineffective. The plaintiffs claimed that scientific studies, particularly since 2016, had shown oral phenylephrine to be no better than a placebo at relieving congestion, yet the companies continued to market their products as effective decongestants and complied with Food and Drug Administration (FDA) labeling requirements. The FDA, despite mounting evidence, did not remove oral phenylephrine’s designation as an effective decongestant under its regulations. The Judicial Panel on Multidistrict Litigation consolidated nearly one hundred class actions and transferred them to the United States District Court for the Eastern District of New York. Plaintiffs filed a complaint asserting New York statutory and common-law claims as well as a federal RICO claim. The district court granted the defendants’ motion to dismiss, holding that the Federal Food, Drug, and Cosmetic Act (FDCA) expressly preempted the state law claims because the drugs’ labels complied with FDA requirements, and that the plaintiffs lacked standing to bring the RICO claim. The court also dismissed a Lanham Act claim brought by one pharmacy plaintiff. On appeal, the United States Court of Appeals for the Second Circuit held that the FDCA expressly preempts most of the state law claims because the federal regime requires manufacturers to follow the FDA-approved labeling, but it vacated the dismissal for claims regarding “Maximum Strength” labeling and brand-name drugs approved via the New Drug Application process, remanding those for further proceedings. The court affirmed dismissal of the RICO claim, adopting the indirect purchaser rule, and upheld denial of the pharmacy’s motion for reconsideration regarding its Lanham Act claim. View "Yousefzadeh v. Johnson & Johnson Consumer Inc." on Justia Law

United States v. Greebel

2026-07-29T07:00:13-08:00

The defendant, convicted by a jury of conspiracies to commit wire and securities fraud in connection with a scheme to defraud investors, was ordered to pay over $10 million in restitution to the victim company. To enforce this restitution order, the government sought to garnish the defendant’s 401(k) retirement accounts. The defendant objected, arguing that various legal provisions, including plan terms and federal statutes, either prohibited or limited garnishment of his accounts. The victim, the financial institutions holding the accounts, and the government ultimately reached a settlement on how the garnishment and tax consequences would be handled. After the conviction and sentence were affirmed by the United States Court of Appeals for the Second Circuit, the United States District Court for the Eastern District of New York considered the government’s application for writs of garnishment. The district court rejected the parties’ proposed stipulated orders of garnishment, reasoning that the proposal exceeded the scope of the Second Circuit’s prior mandate by not resolving specific tax issues, and ordered its own procedure for liquidation and distribution of the funds. The district court also denied a stay of distribution, holding that the defendant lacked standing because the funds had been liquidated. On appeal, the United States Court of Appeals for the Second Circuit held that the controversy remained live despite the liquidation of the accounts, and that its previous mandate did not bar the district court from approving the parties’ stipulated orders of garnishment. The court found that the district court erred in its application of the mandate rule and in concluding that the defendant lacked standing. Accordingly, the Second Circuit reversed the district court’s order and remanded the case with instructions to approve the parties’ proposed stipulated orders of garnishment. View "United States v. Greebel" on Justia Law

Onosamba-Ohindo v. Ball

2026-07-29T07:00:09-08:00

A noncitizen from the Democratic Republic of the Congo was detained in New York pending removal proceedings and was ordered released on bond, which he could not pay. He then brought a class action and habeas petition on behalf of similarly situated noncitizens, challenging government bond-hearing procedures as violating due process. Specifically, he argued that the procedures wrongly placed the burden of proof on detainees, failed to consider ability to pay, and did not require consideration of alternatives to detention. The United States District Court for the Western District of New York initially certified the class and issued a preliminary injunction requiring changes to bond-hearing procedures, with the government complying for nearly two years. After the Supreme Court decided Garland v. Aleman Gonzalez, which held that lower courts lack jurisdiction to issue class-wide injunctive relief under certain immigration statutes, the district court vacated the injunction. It then decertified the class entirely, concluding that neither class-wide injunctive nor declaratory relief was appropriate, and dismissed the case. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not abuse its discretion in decertifying the class for injunctive relief, as lower courts lack authority for such relief post-Aleman Gonzalez. However, it found that the district court erred by decertifying the class for declaratory relief based on factors irrelevant to the Rule 23(b)(2) class-certification analysis. The Second Circuit clarified that while injunctive relief is unavailable, district courts retain authority to grant class-wide declaratory relief in these cases. Accordingly, the Second Circuit vacated the district court’s judgment and remanded for further proceedings. View "Onosamba-Ohindo v. Ball" on Justia Law

Civil Rights Corps v. LaSalle

2026-07-29T07:00:03-08:00

A group of plaintiffs, including Civil Rights Corps and several law professors, filed twenty-one grievance complaints against New York state prosecutors with the Attorney Grievance Committee of the Second Judicial Department. The complaints alleged unethical conduct based on public information and judicial findings. After the Committee informed the plaintiffs that any resulting proceedings against the prosecutors would remain confidential under Section 90(10) of the New York Judiciary Law, the plaintiffs brought suit under 42 U.S.C. § 1983, contending that the statute violated their First Amendment right of access as applied to their complaints. The United States District Court for the Southern District of New York reviewed the case at summary judgment. It held that a First Amendment presumption of access attaches to formal disciplinary hearings in the Second Department, to records necessary to understand those hearings, and to final dispositions by the Grievance Committee. The court found Section 90(10) unconstitutional as applied to the plaintiffs’ complaints, concluding it impermissibly interfered with their right of access. On appeal, the United States Court of Appeals for the Second Circuit considered whether the plaintiffs’ claims were ripe and whether abstention was warranted under O’Shea v. Littleton. Applying de novo review, the Second Circuit found the claims ripe and abstention unnecessary. The court applied the experience-and-logic test and determined that a qualified, presumptive First Amendment right of access exists for formal disciplinary hearings in the Second Department, pertinent records, and select Committee dispositions. The State may restrict access only if it makes specific, on-the-record findings justifying confidentiality. The Second Circuit affirmed the district court’s judgment. View "Civil Rights Corps v. LaSalle" on Justia Law

In Re: Goebel

2026-07-28T06:30:03-08:00

A debtor filed for Chapter 7 bankruptcy in the United States Bankruptcy Court for the Eastern District of New York and subsequently brought an adversary complaint against the Internal Revenue Service (IRS). The debtor sought a determination that her federal income tax debts for certain years were dischargeable under 11 U.S.C. § 523(a)(1), meaning they would be eliminated through bankruptcy. She received a general discharge, but her complaint remained pending due to delays in serving the IRS. Before service was completed, the IRS filed its own complaint in the United States District Court for the Eastern District of New York, seeking to reduce the tax debts to judgment and contending they were excepted from discharge on the grounds of fraud or willful evasion. The IRS moved to dismiss the debtor’s complaint in the bankruptcy court, arguing there was no justiciable dispute because the debtor had not plausibly alleged a concrete injury, and also argued that the Declaratory Judgment Act barred the requested relief. The bankruptcy court denied the motion, allowing the debtor to file a supplemental complaint to address any jurisdictional deficiencies, reasoning that the IRS’s later assertion of nondischargeability in district court created a live controversy. The IRS appealed. The United States District Court for the Eastern District of New York certified the appeal directly to the United States Court of Appeals for the Second Circuit, noting the absence of controlling precedent. The United States Court of Appeals for the Second Circuit held that the debtor’s initial complaint failed to allege an injury in fact, as it was based only on hypothetical future harm and not on any concrete action by the IRS. The court further held that, even if a supplemental complaint could cure a jurisdictional defect, the bankruptcy court should have dismissed the case in deference to the district court, which was the first to have jurisdiction over a justiciable dispute. The Second Circuit vacated the bankruptcy court’s order and remanded with instructions to dismiss both the original and supplemental complaints. View "In Re: Goebel" on Justia Law

United States v. Gendron

2026-07-27T07:00:03-08:00

In May 2022, Payton Gendron carried out a mass shooting at a supermarket in Buffalo, New York, killing ten Black individuals and injuring three others. He meticulously planned the attack to target Black victims, documenting his intentions and motives in a manifesto and online journal. Following the attack, a grand jury indicted Gendron on multiple federal charges, including hate crimes resulting in death and firearm offenses. The government sought the death penalty on certain counts and provided notice of both statutory and non-statutory aggravating factors, including the impact on surviving victims, Gendron’s racist motive, and his intent to incite further violence. The United States District Court for the Western District of New York struck the three contested non-statutory aggravating factors from the government’s notice. The court reasoned that the surviving victims’ injuries were irrelevant to the capital charges, that federal law precluded the government from presenting Gendron’s racist motive as an aggravator, and that citing his intent to incite further violence would violate his First Amendment rights by punishing protected speech. The United States Court of Appeals for the Second Circuit reviewed these rulings de novo. The Second Circuit held that all three non-statutory aggravating factors were permissible. It concluded that evidence of injury to surviving victims is relevant to the circumstances of the crime in a capital sentencing proceeding. The court determined that presenting Gendron’s racist motive does not violate statutory restrictions, as the motive itself, not the race of the victims, is at issue. Finally, the court held that referencing Gendron’s intent to incite further violence does not infringe upon his First Amendment rights when used to establish motive for the crime. The Second Circuit reversed the district court’s order and remanded for further proceedings. View "United States v. Gendron" on Justia Law

Cangro v. NYC Dep't of Finance

2026-07-24T06:00:04-08:00

A longtime employee of the New York City Department of Finance, who suffered from chronic respiratory conditions, was permitted to work remotely during the COVID-19 pandemic. In March 2022, the City required him to work in the Manhattan office for part of the week, while allowing remote work for the other days. He requested to perform his in-office days at the Staten Island office, citing medical difficulties related to commuting and the poor ventilation at the Manhattan location. This request was denied, as were later requests to work fully remotely or to split time between home and Staten Island. Ultimately, his appeals were only partially successful, and he was required to work some days in Manhattan. He alleged these denials constituted discrimination, failure to accommodate, and retaliation under the Americans with Disabilities Act (ADA) and New York City Human Rights Law (NYCHRL). The United States District Court for the Southern District of New York dismissed all claims, finding the employee failed to plausibly allege any adverse employment action or that he could perform his essential job functions with his requested accommodations. The court also denied his request to amend his complaint, ruling that the proposed amendments did not cure these pleading deficiencies nor state a plausible claim for retaliation. On appeal, the United States Court of Appeals for the Second Circuit held that the district court was correct to dismiss the claims of discrimination and retaliation, as the employee’s allegations did not adequately show an adverse employment action tied to his disability or protected activity, nor did they plausibly suggest retaliatory intent. However, the appellate court found that the complaints included sufficient factual allegations to support a claim that the employee could perform his job with reasonable accommodation, thus plausibly pleading claims for failure to accommodate under both the ADA and NYCHRL. The court affirmed the dismissal of the discrimination and retaliation claims but vacated the dismissal of the failure-to-accommodate claims and remanded those for further proceedings. View "Cangro v. NYC Dep't of Finance" on Justia Law

Raymond v. 1199SEIU National Benefit Fund

2026-07-23T06:30:04-08:00

The plaintiff worked for nearly thirty years for the defendant, a union benefit fund, and served most recently as an outreach coordinator required to drive to various healthcare facilities to give presentations. After developing a vein condition that limited his ability to sit or drive for more than thirty minutes at a time, the plaintiff informed the defendant of his restrictions. The defendant responded by removing the four facilities farthest from his home from his route, but left him with assignments requiring drives longer than thirty minutes. The plaintiff requested reassignment to a different area, which the defendant refused. Unable to return to work under these conditions, the plaintiff was terminated. In the United States District Court for the Southern District of New York, the defendant was granted summary judgment on the plaintiff’s claim that the defendant failed to provide reasonable accommodations, with the court finding the defendant had sufficiently accommodated him. The plaintiff’s disability discrimination claim proceeded to trial, where a jury found for the defendant. The plaintiff then moved for a new trial under Rule 59(a), arguing the verdict was against the weight of evidence, but the district court denied the motion, concluding a reasonable jury could find the plaintiff was not terminated because of his disability. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court erred in granting summary judgment on the failure-to-accommodate claim because factual questions remained about whether the accommodation provided was reasonable and whether other plausible accommodations existed. The court vacated the summary judgment, dismissed the appeal regarding the Rule 59(a) motion as not reviewable, and remanded the case for further proceedings. View "Raymond v. 1199SEIU National Benefit Fund" on Justia Law

United States v. McCrone

2026-07-21T07:00:11-08:00

Two individuals were apprehended in connection with a narcotics trafficking operation, in which they served as dealers. Their arrests followed an FBI investigation involving physical surveillance, phone records, intercepted communications, and controlled purchases. Both were charged with conspiracy to distribute and possess narcotics, and each pled guilty to a lesser included offense. At sentencing, their backgrounds—including histories of addiction, difficult childhoods, and substance abuse—were considered, and each received a below-Guidelines prison term followed by supervised release with special conditions. The United States District Court for the Southern District of New York imposed special conditions of supervised release, including requirements for outpatient substance abuse and mental health treatment, anger management, access to financial information, and submission to electronic searches. For one defendant, the mental health condition included a requirement to continue taking prescribed medications unless otherwise instructed by a health care provider. Neither defendant objected to these conditions at sentencing. The United States Court of Appeals for the Second Circuit reviewed the case under plain error, given the lack of objections at sentencing. The court found that although the district court failed to conduct an individualized assessment for the electronic search condition, the record provided sufficient justification for imposing it on both defendants, as electronic devices were instrumental to their offenses and they committed the crimes while under supervision for prior offenses. However, the court held that the medication requirement within the mental health treatment condition lacked support in the record and was not justified without findings specific to the defendant’s medical needs or a demonstration that it was necessary. The Second Circuit affirmed the electronic search condition, reversed the medication requirement, and remanded with instructions to strike the unsupported medication provision. View "United States v. McCrone" on Justia Law

Hayden v. Koons

2026-07-21T07:00:08-08:00

An American artist created a Styrofoam sculpture in Italy in the late 1980s and sold it to a production company owned by a well-known Italian adult film star and politician. About a year later, another artist, internationally recognized for his “appropriation” style, used the sculpture as a set for a series of photographs with the film star, which were subsequently incorporated into several pieces of art. These works were widely exhibited and publicized in Italy and internationally beginning around 1989. The sculptor claims he did not become aware of the alleged infringement until he saw a news article about the works in 2019. He obtained a U.S. copyright registration for the sculpture in 2020 and filed suit against the appropriation artist and his company in December 2021, later adding the artist’s LLC as a defendant. The United States District Court for the Southern District of New York considered cross-motions for summary judgment. It granted the defendants’ motion, holding that the copyright infringement claim was time-barred because the plaintiff, given his immersion in Italian culture and proximity to the events, should have discovered the alleged infringement well before 2019. The court further ruled that, because the copyright claim was untimely, the related Digital Millennium Copyright Act (DMCA) claim and a request for reconsideration of the damages period were moot. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision de novo. The Second Circuit affirmed the lower court’s judgment, holding that the copyright infringement claim was time-barred under the discovery rule, as a reasonably diligent copyright holder in the plaintiff’s position would have discovered the alleged infringement more than three years before filing suit. The appellate court also declined to consider the plaintiff’s argument regarding the independent accrual of the DMCA claim, as it was neither properly preserved nor adequately presented on appeal. View "Hayden v. Koons" on Justia Law

Mahdawi v. Trump

2026-07-21T07:00:03-08:00

The petitioner, a lawful permanent resident originally from the West Bank, lived in Vermont and was pursuing graduate studies at Columbia University. Following his vocal participation in student demonstrations protesting military actions in Gaza, he was arrested at a USCIS facility in April 2025 by Homeland Security agents, who commenced removal proceedings against him. The Notice to Appear cited a determination by the Secretary of State that his presence or activities posed potentially serious adverse foreign policy consequences, referencing his alleged rhetoric and conduct at protests. The government also presented prior allegations related to firearm purchases and drug possession, which the petitioner denied or had resolved. After his arrest, the petitioner’s attorney filed a habeas corpus petition in the United States District Court for the District of Vermont, alleging that the government targeted him for removal based on constitutionally protected speech. The petition sought to invalidate the Secretary of State’s determination, bar removal based on advocacy for Palestinian rights, and obtain his release. The district court granted his release pending review of the petition, finding a likelihood of success on the First Amendment claim and determining it had jurisdiction despite statutory provisions that restrict judicial review in immigration matters. The United States Court of Appeals for the Second Circuit reviewed the appeal. Applying a de novo standard for subject matter jurisdiction, the court concluded that 8 U.S.C. § 1252(b)(9) channels judicial review of questions arising from removal actions to the administrative process and ultimately to a petition for review of a final order of removal in the circuit courts. The court held that the district court lacked jurisdiction to entertain the habeas petition because the petitioner’s claims were intertwined with the removal proceedings. The court vacated the district court’s release order and remanded with instructions to dismiss the habeas petition for lack of jurisdiction. View "Mahdawi v. Trump" on Justia Law

Tennenbaum Living Tr. v. GCDI S.A.

2026-07-20T06:00:03-08:00

In this dispute, an Argentine construction company issued dollar-denominated convertible debt notes to two trusts as part of a capital-raising effort. The parties entered into an indenture agreement, later amended in December 2019, which authorized the company’s Board of Directors to convert the notes into equity if certain financial thresholds were met. Section 1301 of the indenture vested the Board with authority to determine if these conditions were satisfied, provided their determination was free from “manifest error.” In 2020, the Board concluded that the threshold for conversion had been reached, relying on the company’s increased net equity following the issuance of new preferred shares. The trusts disagreed, contending the Board’s calculation was manifestly erroneous and that the actual value of equity sold did not meet the $100 million threshold required by the indenture. The United States District Court for the Southern District of New York presided over a bench trial. The court dismissed the trusts’ claims regarding improper amendment and bad faith, focusing solely on the manifest error claim. After reviewing the evidence, the District Court concluded that the Board had manifestly erred by using metrics not contemplated by the indenture—specifically, shareholder equity changes and liquidation preferences—rather than the actual value of shares sold. The court found that the threshold for mandatory conversion had not been met, and GCDI breached the agreement by ceasing interest payments on the notes. The United States Court of Appeals for the Second Circuit reviewed the District Court’s factual findings for clear error and its legal conclusions de novo. The Second Circuit affirmed the District Court’s judgment, holding that the Board’s determination constituted a manifest error under New York law because it failed to value the equity sold as required by the indenture’s plain terms. The judgment awarding damages to the trusts was affirmed. View "Tennenbaum Living Tr. v. GCDI S.A." on Justia Law

United States v. DeJesus

2026-07-17T06:30:11-08:00

After pleading guilty to two drug offenses involving the sale and possession of significant quantities of heroin and fentanyl, the defendant was arrested and later attempted to flee the country while on pretrial release. Law enforcement found several kilograms of fentanyl and cash in his possession. Following his recapture, he engaged in a proffer session with the government, during which he was found to have lied about his conduct. He ultimately withdrew his objections to the facts outlined in the presentence report after waiving an evidentiary hearing. The United States District Court for the Southern District of New York sentenced the defendant to 144 months in prison and four years of supervised release, adopting the presentence report’s calculation of the sentencing range and its recommended conditions of supervised release. The district court denied the defendant a downward adjustment for acceptance of responsibility due to his obstruction of justice and dishonesty, imposed a below-Guidelines sentence, and referenced the conditions of supervised release by incorporating the relevant pages of the presentence report rather than reading them aloud. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not err in denying the acceptance of responsibility adjustment, finding that the defendant’s obstruction and dishonesty precluded such a reduction. The appellate court also ruled that the 144-month sentence was substantively reasonable, that orally referencing the presentence report to impose conditions of supervised release was permissible, and that imposing a mental health treatment condition was not plain error, given the defendant’s own statements about his need for counseling. The judgment of the district court was affirmed. View "United States v. DeJesus" on Justia Law

Asinga v. Gatorade Co.

2026-07-17T06:30:07-08:00

A professional track and field athlete received a bottle of Gatorade Recovery Gummies at an award ceremony hosted by Gatorade, which were labeled as “NSF Certified for Sport,” indicating independent testing for banned substances. After consuming the gummies, the athlete submitted a routine drug test that later returned positive for cardarine, a banned performance-enhancing drug, resulting in immediate suspension from elite competition. Subsequent investigation revealed that the gummies lot the athlete received had never been NSF certified, and Gatorade was aware of the mislabeling before distributing the product. The athlete suffered significant consequences, including loss of eligibility to compete, loss of a scholarship, and forfeiture of endorsement opportunities. The athlete initiated legal action in the United States District Court for the Southern District of New York, alleging strict products liability, negligence, negligent misrepresentation, violation of Texas’s Deceptive and Unfair Trade Practices Act, tortious interference with contract, and intentional infliction of emotional distress. The district court dismissed all claims. It found no “cognizable injury outside of purely economic damages” for the strict liability, negligence, and misrepresentation claims, applying New York’s economic loss doctrine. Additional claims were dismissed based on statutory definitions and insufficient allegations of extreme conduct or distress. On appeal, the United States Court of Appeals for the Second Circuit reviewed the dismissal de novo. It affirmed the district court’s dismissal of the tortious interference, consumer protection, and emotional distress claims. However, the court recognized uncertainty in New York law regarding tort recovery for nonconsensual bodily changes detectable only by laboratory testing and the boundaries of the economic loss doctrine. Accordingly, the Second Circuit deferred decision and certified two questions to the New York Court of Appeals concerning the scope of the economic loss doctrine and whether the athlete’s injury is cognizable in tort under New York law. View "Asinga v. Gatorade Co." on Justia Law

Rutledge v. Walgreen Co.

2026-07-17T06:30:03-08:00

Parents, guardians, and children brought state law claims against manufacturers, pharmacies, and retailers of acetaminophen products, alleging that prenatal exposure to acetaminophen caused ADHD and/or autism spectrum disorder (ASD). The plaintiffs contended that the defendants failed to warn about these risks. Acetaminophen is commonly used during pregnancy, but the FDA only requires a general warning for pregnant women and does not mandate warnings about ADHD or ASD. Scientific debate exists regarding any causal relationship between prenatal acetaminophen exposure and neurodevelopmental disorders, with studies and expert opinions both supporting and questioning such links. After these cases were consolidated in the U.S. District Court for the Southern District of New York, the court excluded all general causation expert testimony offered by plaintiffs in Rutledge (Drs. Baccarelli, Hollander, Pearson, Cabrera, Louie) and Phippen (Dr. Ness), determining their opinions were unreliable and not based on sufficient scientific methodology under Rule 702 and Daubert v. Merrell Dow Pharms., Inc. The district court then granted summary judgment for the defendants. It also rejected defendants’ arguments that federal law preempted the plaintiffs’ failure-to-warn claims, holding that federal drug labeling regulations did not prohibit supplemental warnings. The United States Court of Appeals for the Second Circuit reviewed the district court’s decisions. It held that the district court erred in excluding the testimony of Drs. Baccarelli, Hollander, and Pearson, as their methodologies and interpretations were consistent with accepted scientific practices and the ongoing debate in the field. The district court did not abuse its discretion in excluding the testimony of Drs. Cabrera and Louie. The Second Circuit also held that reconsideration of Dr. Ness’s testimony in Phippen was warranted. The court affirmed the district court’s rejection of the federal preemption defense. The judgments in both cases were vacated and remanded for further proceedings. View "Rutledge v. Walgreen Co." on Justia Law

Creditincome Limited v. The Swiss Confederation

2026-07-16T06:30:03-08:00

In late 2022 and early 2023, Swiss authorities intervened in the affairs of Credit Suisse, a major Swiss bank facing severe financial distress and significant capital outflows. Rather than pursuing receivership or nationalization, Switzerland opted to orchestrate a takeover of Credit Suisse by UBS, another large Swiss bank. As part of this process, Switzerland unilaterally negotiated merger terms, exerted coercive control over Credit Suisse, enacted emergency ordinances to facilitate the transaction, and extended substantial loans and guarantees. A key step was Switzerland’s directive that Credit Suisse write down $17.3 billion in bond liabilities, which directly affected bondholders whose securities were held and cleared in New York. Bondholders, who lost their investments due to the write-down, brought suit in the United States District Court for the Southern District of New York. They alleged that Switzerland’s actions fell within the commercial activity exception to the Foreign Sovereign Immunities Act (FSIA), claiming that Switzerland’s “brokering” of the merger was commercial in nature. The district court disagreed, finding that Switzerland’s conduct, viewed as a whole, was not commercial because it involved the exercise of sovereign authority, including coercive directives and the unilateral enactment of ordinances. The district court therefore dismissed the case for lack of subject matter jurisdiction. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal. The Second Circuit held that, while certain actions by Switzerland (such as providing loans and guarantees) might arguably be commercial if viewed in isolation, the overall course of conduct—particularly the coercive control over Credit Suisse and the use of sovereign powers to enact emergency ordinances—was not the type of activity undertaken by private parties in commerce. Accordingly, the commercial activity exception under the FSIA did not apply, and Switzerland retained sovereign immunity. View "Creditincome Limited v. The Swiss Confederation" on Justia Law

Northwell Health, Inc. v. Group Hospitalization and Medical Services, Inc.

2026-07-15T07:00:09-08:00

A large New York healthcare provider participated for decades in the Blue Cross Blue Shield insurance network through contracts with the New York Blue Cross licensee, Empire. Under this arrangement, the provider offered negotiated pricing and direct billing for Blue Cross patients. The Blue Cross network comprises thirty-four independent companies, each licensed to operate in a specific region. The provider’s current dispute concerns claims for care provided to patients insured by Blue Cross entities based in Washington, D.C., Maryland, and Virginia. These out-of-state insurers, although not directly contracted with the provider and not operating in New York, used the BlueCard Program to facilitate claims processing in New York and relied on Empire’s network to obtain discounted rates. The provider alleged that these insurers underpaid over $5.5 million in claims. After unsuccessful resolution attempts under the Provider Agreement, the provider brought suit in New York state court. The defendants removed the case to the United States District Court for the Eastern District of New York, which dismissed the case for lack of personal jurisdiction and failure to state a claim. The district court also denied leave to amend the complaint. The United States Court of Appeals for the Second Circuit reviewed the case. It found diversity jurisdiction proper, holding that the D.C.-based insurer’s federal charter made it a D.C. citizen for jurisdictional purposes. The court held that the out-of-state insurers’ purposeful business dealings with Empire and exploitation of New York’s healthcare market established personal jurisdiction under both New York’s long-arm statute and the Due Process Clause. On the merits, the Second Circuit held that the provider adequately stated claims for contract liability based on ratification and for quasi-contract, but affirmed dismissal of the provider’s third-party beneficiary claims. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Northwell Health, Inc. v. Group Hospitalization and Medical Services, Inc." on Justia Law

Bergin v. N.Y. State Unified Court System

2026-07-15T07:00:05-08:00

An employee was terminated from her position as a court officer after failing to comply with her employer’s COVID-19 vaccination mandate. She had requested a religious exemption, submitting several documents in support, but her application was denied by the employer’s review committee. After resubmitting forms and additional statements, the employer maintained its denial and ultimately terminated her for noncompliance. Several months later, the vaccination requirement was rescinded, and terminated employees, including the plaintiff, were allowed to seek reinstatement. Following her termination, the plaintiff brought suit in the United States District Court for the Eastern District of New York, alleging a violation of Title VII due to the employer’s failure to accommodate her religious beliefs. The district court granted partial summary judgment in her favor, finding that she had established a prima facie case of religious discrimination based on the employer’s statements during discovery. The court also concluded that the employer had not shown that granting the accommodation would have been an undue hardship. The district court’s decisions rested in part on treating certain statements by the employer as judicial admissions regarding the adequacy of her exemption request. The United States Court of Appeals for the Second Circuit reviewed the district court’s judgment. The Second Circuit held that the standard for a prima facie case for failure to accommodate religion under Title VII was changed by EEOC v. Abercrombie & Fitch Stores, Inc., requiring proof that the employee actually needed an accommodation and that the employer’s motive to avoid that accommodation was a factor in an adverse employment decision. The court found that the district court did not apply the correct standard and improperly treated discovery statements as judicial admissions. The Second Circuit vacated the judgment and remanded the case for further proceedings. View "Bergin v. N.Y. State Unified Court System" on Justia Law

Cumulus Media New Holdings Inc. v. The Nielsen Co. (US), LLC

2026-07-13T07:30:20-08:00

A major radio broadcasting company sought to purchase national radio audience data from a market research firm, which is the sole supplier of such data in the United States. The broadcaster also desired to buy the firm’s local radio audience data in select markets, while sourcing local data from a competitor in other markets. In 2024, the research firm instituted a policy requiring national broadcasters to purchase its local data in every market where they operate in order to access the full national report. This policy forced the broadcaster to choose between buying all local data from the firm or losing access to the essential national data product. The broadcaster sued in the United States District Court for the Southern District of New York, alleging that the firm’s policy constituted an unlawful tying arrangement under the Sherman Act. After discovery and a hearing, the district court found that the firm used its monopoly power in the national data market to coerce customers into buying local data products, resulting in anticompetitive effects in local markets by excluding competitors. The district court granted a preliminary injunction prohibiting the firm from enforcing its tying policy and from charging commercially unreasonable rates for the national report as a standalone product. The firm’s subsequent counterclaims and the broadcaster’s bankruptcy petition led the district court to stay litigation of the counterclaims, but not the broadcaster’s claims. The United States Court of Appeals for the Second Circuit reviewed the district court’s order for abuse of discretion. The appellate court held that constructive tying—where pricing effectively conditions the purchase of one product on another—can violate the Sherman Act. It affirmed the district court’s findings regarding coercion, anticompetitive effects, irreparable harm, and the tailored injunction, and held that the bankruptcy did not require a stay of the appeal. The preliminary injunction was affirmed. View "Cumulus Media New Holdings Inc. v. The Nielsen Co. (US), LLC" on Justia Law

McClarin v. City of New York

2026-07-13T07:30:17-08:00

The case centers on events that took place in December 2015 involving a man who was arrested by New York City police officers after allegations surfaced that he was holding a woman, Miranda, against her will and abusing her. The police received a report from Miranda’s aunt, Marisol Lopez, who claimed that Miranda was being beaten and forced to take drugs. Officers went to Lopez’s apartment, gathered information about Miranda and McClarin, then proceeded to 393 Warwick Street where Miranda was allegedly held. There, conflicting accounts emerged: McClarin and Miranda testified that police forcibly entered without a warrant and ransacked the apartment, while the officers claimed Miranda opened the door voluntarily and that exigent circumstances justified the entry. Miranda later provided a sworn statement accusing McClarin, but at trial testified the statement was coerced and false. The United States District Court for the Eastern District of New York presided over the jury trial. The jury found for the plaintiff on claims of unlawful search and malicious prosecution, awarding significant compensatory and punitive damages against several officers. The officers moved post-trial for judgment as a matter of law or a new trial, primarily arguing the exclusion of recorded conversations between McClarin and Miranda prejudiced their defense. The district court denied all post-trial motions, finding sufficient evidence for the jury’s verdict and ruling the exclusion appropriate because the recordings had not been disclosed before trial. On appeal, the United States Court of Appeals for the Second Circuit rejected the officers’ arguments for judgment as a matter of law, upholding the jury’s findings on the absence of exigent circumstances and qualified immunity. However, it found the district court erred in excluding the recordings, which were relevant to witness credibility and impeachment. The appellate court vacated the judgment against the officers and remanded for a new trial on the unlawful search and malicious prosecution claims. View "McClarin v. City of New York" on Justia Law

Real Estate Board of New York, Inc. v. The City of New York

2026-07-13T07:30:13-08:00

A coalition of trade associations, real estate brokerage firms, landlords, and related entities challenged New York City’s Fairness in Apartment Rental Expenses Act (FARE Act), passed in November 2024. The Act prohibits brokers from charging tenants fees for apartments where they have published listings with a landlord’s permission or agreed to work for the landlord, and prevents landlords from making rental conditional on prospective tenants hiring agents. The plaintiffs argued that the Act infringed their federal and state free speech rights, particularly by burdening their ability to publish listings and receive compensation, and violated the Contracts Clause of the U.S. Constitution by rendering certain existing agreements unenforceable. The United States District Court for the Southern District of New York heard the case, with the City opposing injunctive relief and moving to dismiss the claims. The district court dismissed the plaintiffs’ First Amendment claims, finding the FARE Act to be content-neutral regulation of commercial speech that survived intermediate scrutiny under the Central Hudson test. The court denied the plaintiffs’ motion for a preliminary injunction on those claims. As for the Contracts Clause argument, the district court denied the City’s motion to dismiss, reasoning that factual issues remained, but denied a preliminary injunction after finding plaintiffs unlikely to succeed on the merits. The district court also rejected a state preemption claim. The United States Court of Appeals for the Second Circuit reviewed the appeal, affirming the district court’s judgment. The Second Circuit held that the FARE Act regulates commercial speech in a content-neutral manner and is valid under the Central Hudson test. It also concluded that the Act does not violate the Contracts Clause, as plaintiffs failed to establish a substantial likelihood of success on that claim. The court thus affirmed denial of injunctive relief and dismissal of the constitutional claims. View "Real Estate Board of New York, Inc. v. The City of New York" on Justia Law

Rutledge v. Walgreen Co.

2026-07-13T07:30:08-08:00

A group of parents, guardians, and children alleged that prenatal exposure to acetaminophen, the active ingredient in Tylenol and similar over-the-counter drugs, caused attention-deficit/hyperactivity disorder (ADHD) and/or autism spectrum disorder (ASD) in children. The defendants were manufacturers, pharmacies, and retailers of acetaminophen products. The plaintiffs’ claims centered on the companies’ alleged failure to warn about the risk of these neurodevelopmental disorders associated with prenatal acetaminophen use. These cases were consolidated and transferred to the United States District Court for the Southern District of New York. In the Rutledge action, the district court excluded all five of plaintiffs’ expert witnesses on general causation, concluding their methodologies were unreliable, and granted summary judgment to defendants. In the Phippen action, which involved only ADHD claims, the district court excluded another expert, Dr. Ness, and again granted summary judgment to defendants. The district court also rejected defendants’ arguments that federal drug labeling law preempted the plaintiffs’ claims, holding that federal law did not bar additional, specific pregnancy-related warnings. On appeal, the United States Court of Appeals for the Second Circuit reviewed whether the district court properly exercised its gatekeeping role under Federal Rule of Evidence 702 in excluding the plaintiffs’ expert testimony. The Second Circuit held that the district court exceeded its discretion in excluding the testimony of Drs. Baccarelli, Hollander, and Pearson, because their methodologies were consistent with those generally accepted in their fields and their reasoning was within the range of scientific debate. The appellate court affirmed the exclusion of testimony from Drs. Cabrera and Louie. In light of its rulings, the Second Circuit vacated the summary judgments, remanded both cases for further proceedings, and directed reconsideration of Dr. Ness’s exclusion in Phippen. The court also affirmed that federal law did not preempt the plaintiffs’ state-law failure-to-warn claims. View "Rutledge v. Walgreen Co." on Justia Law

County of Rockland v. Triborough Bridge & Tunnel Auth.

2026-07-13T07:30:04-08:00

New York State created a congestion-pricing program in 2019, requiring vehicles entering the Central Business District (CBD) in Manhattan to pay a daily toll. The stated purposes of the program include reducing traffic congestion and raising funds to support mass transit projects. Rockland and Orange Counties, neighboring municipalities with limited mass-transit access to Manhattan, argued that this program disproportionately burdens their residents, who often rely on driving rather than transit. Before the program began, Rockland and Orange Counties sued the Triborough Bridge and Tunnel Authority and the Metropolitan Transportation Authority, alleging that the toll was an unauthorized tax, violated the right to travel, and infringed upon the Due Process, Equal Protection, and Excessive Fines Clauses of both the New York and U.S. Constitutions. The United States District Court for the Southern District of New York consolidated the cases and granted the defendants’ motion to dismiss for failure to state a claim, also denying leave to amend. The court found that the plaintiffs failed to plausibly allege constitutional violations and determined that any challenge to the toll as a tax should be brought in state court. The United States Court of Appeals for the Second Circuit reviewed the appeal, assuming without deciding that the toll was not a tax. The Second Circuit affirmed the district court’s dismissal, holding that the congestion-pricing program does not create invidious distinctions or more than a minor restriction on the right to travel and thus is reviewed for reasonableness. The court found the toll to be a reasonable user fee, rationally related to legitimate state interests in funding transit and reducing congestion. It also determined there was no due process, equal protection, or excessive fines violation. The Second Circuit further ruled that the district court did not abuse its discretion in denying leave to amend the complaints. View "County of Rockland v. Triborough Bridge & Tunnel Auth." on Justia Law

1199 SEIU UNITED HEALTHCARE WORKERS EAST v. CHINESE-AMERICAN PLANNING COUNCIL HOME ATTENDANT PROGRAM

2026-07-10T06:30:06-08:00

A union representing over 100,000 current and former home healthcare workers in New York City entered into collective bargaining agreements (CBAs) with more than 40 employers. In 2015, the union and employers amended their CBAs with a Memorandum of Agreement (2015 MOA), mandating arbitration of statutory wage-and-hour claims, including those under the Fair Labor Standards Act and New York Labor Law. The union subsequently initiated a class arbitration in 2019 for wage claims dating back to 2008. The arbitrator found for the union, ordering employers to create a $30 million fund for affected workers and established a rapid payout process. The union sought, and the United States District Court for the Southern District of New York confirmed, the arbitration awards, making them binding on virtually all covered workers, except for nine individuals named in ongoing state litigation. Prior to the arbitration, several former employees who had left their jobs before the 2015 MOA was executed sued their employers in New York State courts, asserting similar wage claims. State courts uniformly held that these individuals, no longer union members or bargaining unit employees at the time of the 2015 MOA, could not be retroactively bound to arbitrate their claims. Despite this, the district court denied intervention by these former employees in the confirmation proceedings, concluding they lacked standing and were adequately represented by the union. The United States Court of Appeals for the Second Circuit reviewed the case. It held that the district court, not the arbitrator, must decide whether the union and employers clearly agreed to arbitrate these statutory claims. The Circuit Court found that the union and employers did not agree to mandatory arbitration for former employees’ accrued statutory claims until the 2015 MOA, and the union could not lawfully waive the rights of individuals who had already left employment. The Court vacated the district court’s orders as to the appellants and remanded for further proceedings, ruling these individuals are not bound by the arbitration awards and may pursue their claims in state court. View "1199 SEIU UNITED HEALTHCARE WORKERS EAST v. CHINESE-AMERICAN PLANNING COUNCIL HOME ATTENDANT PROGRAM" on Justia Law

Mutual Fund Opt-Out Plaintiffs v. Calamari

2026-07-09T07:00:03-08:00

Investors, referred to as the Opt-Out Plaintiffs, brought state court actions against Quasar Distributors, LLC, the underwriter of a collapsed mutual fund, after choosing not to participate in a class action settlement following the fund’s collapse. The collapse was caused by fraudulent inflation of asset values by the fund’s adviser, resulting in substantial losses. The Securities and Exchange Commission initiated a federal action in the United States District Court for the Southern District of New York, which oversaw the distribution of the remaining assets of the fund, known as the Special Reserve, through a court-appointed Special Master. While the class action settlement in New York state court resolved claims against several parties without drawing from the Special Reserve, the Opt-Out Plaintiffs pursued separate state law claims against Quasar and others. The District Court entered an order staying litigation, later amended to permit certain claims, but ultimately issued a permanent injunction against the Opt-Out Plaintiffs' state court actions against Quasar. The court reasoned that permitting these actions would create indemnification obligations for the fund, potentially depleting the Special Reserve and undermining its equitable distribution. On appeal, the United States Court of Appeals for the Second Circuit reviewed whether the injunction was permissible under the Anti-Injunction Act, 28 U.S.C. § 2283. The court held that the “in aid of jurisdiction” exception to the Act—which generally applies only to actions involving control over a specific property or res—did not justify enjoining the Opt-Out Plaintiffs’ state court in personam actions against Quasar. The court found that the Opt-Out Plaintiffs’ claims did not threaten federal jurisdiction over the Special Reserve, and the narrow exception recognized in In re Baldwin-United Corp. did not apply. Accordingly, the Second Circuit vacated the injunction and remanded the case for further proceedings. View "Mutual Fund Opt-Out Plaintiffs v. Calamari" on Justia Law

20230930-DK-BUTTERFLY-1,INC. v. HBC Invs. LLC

2026-07-07T07:00:11-08:00

A company that had succeeded Bed Bath & Beyond after bankruptcy sued two investment entities, asserting that they owed the company profits made from short-term trading of its stock. Before the bankruptcy, Bed Bath & Beyond had sold derivative securities to the investment entities, giving them the right to acquire large amounts of its stock at a discount. However, the contracts for these derivatives included “blocker” provisions, which stated that the investment entities could not acquire more than 9.99% of the company’s stock at any time. The investment entities repeatedly exercised their rights under these contracts, buying and selling shares while maintaining their holdings below the 10% threshold. The United States District Court for the Southern District of New York reviewed the case after the successor company filed suit, arguing that the contractual blockers were illusory and that, in substance, the investment entities effectively had the right to acquire more than 10% of the stock, triggering liability under section 16(b) of the Securities Exchange Act of 1934. The district court dismissed the complaint, finding that the blockers were valid and shielded the defendants from section 16(b) liability. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal de novo. The court held that effective and enforceable contractual blockers, which cap an investor's beneficial ownership below 10% and are not sham provisions, prevent section 16(b) liability for short-swing profits. The court found no plausible allegations that the blockers were illusory or that the investment entities ever exceeded the 10% threshold. The Court of Appeals also rejected arguments that the parties’ contractual arrangements were part of a scheme to evade regulatory obligations. The judgment of the district court was affirmed in full. View "20230930-DK-BUTTERFLY-1,INC. v. HBC Invs. LLC" on Justia Law

The New York and Presbyterian Hospital v. New York State Nurses Association

2026-07-07T07:00:08-08:00

A hospital and a union representing registered nurses entered into a collective bargaining agreement, which required the hospital to staff its Cardio-Thoracic Intensive Care Unit according to a specific grid. When the hospital failed to maintain the agreed-upon staffing levels, the union filed a grievance on behalf of the affected nurses. The dispute proceeded to arbitration, where the arbitrator found that the hospital had breached the agreement and issued a monetary award to compensate nurses who worked on significantly understaffed shifts. The United States District Court for the Southern District of New York reviewed cross-motions from both parties—one to vacate and one to confirm the arbitral award. The district court denied the hospital’s motion to vacate and granted the union’s motion to confirm the award, concluding that the arbitrator had acted within her authority under the agreement. The hospital appealed this decision, contending that the monetary relief was not authorized by the contract and that it constituted a punitive award in violation of public policy. The United States Court of Appeals for the Second Circuit affirmed the district court’s confirmation of the arbitral award. The court held that the arbitrator did not exceed her authority under the agreement, as the agreement’s remedial authority clause permitted the issuance of monetary relief and did not expressly prohibit such remedies. The court further found that the award was compensatory, not punitive, as it was intended to make the nurses whole for extra work performed, and was not designed to punish the hospital. The court concluded that the award did not violate any explicit public policy and that the arbitrator’s remedy was properly derived from the terms of the agreement. View "The New York and Presbyterian Hospital v. New York State Nurses Association" on Justia Law

United States v. Salvador

2026-07-07T07:00:03-08:00

A noncitizen defendant, a member of the MS-13 gang, pleaded guilty to assault in aid of racketeering after providing advice and supplies to junior gang members involved in a shooting. He was charged as part of a multi-defendant racketeering indictment covering violent crimes from 2016 to 2018. The defendant was sentenced to 210 months of imprisonment and three years of supervised release. One special condition of his supervised release required him to “cooperate with and abide by all instructions of immigration authorities.” The defendant did not object to this special condition during sentencing. The United States District Court for the Eastern District of New York imposed the sentence and adopted the presentence report’s recommendations, including the special conditions of supervised release. The defendant filed an appeal challenging only the “Immigration Authorities Condition,” arguing that it was procedurally unreasonable, unconstitutionally vague, and impermissibly delegated judicial authority to non-judicial officers. The government argued the appeal was barred by a waiver in the plea agreement, but the United States Court of Appeals for the Second Circuit determined that the waiver did not cover conditions of supervised release and denied the motion to dismiss. The United States Court of Appeals for the Second Circuit reviewed the case for plain error. The court held that the challenge was ripe, was not waived but forfeited, and that the district court’s reasons for imposing the condition were self-evident in the record. The court further held that the condition was not unconstitutionally vague and did not unlawfully delegate sentencing authority. The judgment of the district court, including the challenged special condition, was affirmed. View "United States v. Salvador" on Justia Law

Chapdelaine v. Desjardin

2026-07-02T06:30:03-08:00

The case involves a dispute arising from a 2018 arrest of the plaintiff, Darlene Chapdelaine, by Connecticut State Troopers Robert L. Desjardin and Jason N. Deojay. The arrest followed a 911 call alleging that Chapdelaine, intoxicated, physically assaulted an elderly housemate. The troopers responded, and after a confrontation, arrested Chapdelaine for assault, disorderly conduct, and interfering with/resisting arrest. Subsequent criminal charges against Chapdelaine were dismissed after she completed a one-day diversionary program, following nearly five years of pending proceedings. The United States District Court for the District of Connecticut initially granted summary judgment in favor of Desjardin and Deojay on Chapdelaine’s false arrest and false imprisonment claims, finding that the officers had at least arguable probable cause. The malicious prosecution claims were dismissed without prejudice pending resolution of criminal charges, and later dismissed with prejudice after the charges were dismissed via a diversionary program, which the court held was not a favorable termination. The district court also excluded evidence of Desjardin’s disciplinary record under Rule 403, finding its probative value outweighed by potential confusion and prejudice. At trial, the jury found for Desjardin and Deojay on all claims, including excessive force, and the court denied Chapdelaine’s post-verdict motions. On appeal, the United States Court of Appeals for the Second Circuit affirmed all district court rulings. The Second Circuit held that dismissal of criminal charges contingent upon completion of a diversionary program did not constitute a favorable termination for purposes of a malicious prosecution claim. The court also found no abuse of discretion in the exclusion of disciplinary evidence and concluded the jury’s verdict was supported by sufficient evidence. The judgment was affirmed in its entirety. View "Chapdelaine v. Desjardin" on Justia Law

Association of Contracting Plumbers v. City of New York

2026-06-30T07:00:04-08:00

New York City and New York State passed laws that effectively prohibit the use of fossil-fuel-powered appliances in new buildings as part of broader efforts to address pollution and greenhouse gas emissions. These measures ban, for example, installing gas stoves or other fossil-fuel-based heating or cooking appliances in new construction. Trade associations, contractor and builder groups, and unions whose members would be affected by these prohibitions sued, arguing that the Energy Policy and Conservation Act (EPCA), a federal law that sets efficiency standards for certain appliances, expressly preempts these state and local laws. In the United States District Court for the Southern District of New York, the plaintiffs challenging the New York City law lost when the court granted the City’s motion to dismiss, finding that EPCA did not preempt the local law. In a separate case in the United States District Court for the Northern District of New York, plaintiffs challenging the State law were denied relief at the summary judgment stage against the remaining state defendant, with the court again holding that EPCA’s preemption provision did not apply. In both cases, the plaintiffs appealed. The United States Court of Appeals for the Second Circuit reviewed both appeals together. The court held that EPCA’s express preemption provision only preempts state and local “energy conservation standards” for covered appliances and a limited class of related regulations. The challenged New York laws, which prohibit the use of certain types of appliances but do not set standards for the amount of energy those appliances use, do not fall within the scope of EPCA’s preemption. Accordingly, the Second Circuit affirmed the judgments of the district courts, allowing the state and city laws to stand. View "Association of Contracting Plumbers v. City of New York" on Justia Law

Miller v. McDonald

2026-06-30T06:30:03-08:00

In this case, several Amish parents, Amish community schools, and a representative of Amish schools in New York challenged New York's school immunization law, which, since 2019, no longer provides a religious exemption to the vaccination requirement for students attending public, private, or parochial schools. The plaintiffs allege that their faith prohibits vaccination, and their schools were fined for failing to comply with the immunization law. The plaintiffs asserted that the law violated their rights under the Free Exercise Clause of the First Amendment and their parental free-exercise rights recognized in Wisconsin v. Yoder. The United States District Court for the Western District of New York dismissed the plaintiffs’ complaint, finding they failed to plausibly allege a constitutional violation. The court relied on Second Circuit precedent holding that the repeal of religious exemptions for school vaccination laws, while maintaining medical exemptions, does not violate the Free Exercise Clause. The district court also denied the request for a preliminary injunction as moot. The plaintiffs appealed, and the United States Court of Appeals for the Second Circuit initially affirmed the dismissal. After the Supreme Court vacated the Second Circuit’s judgment and remanded for reconsideration in light of Mahmoud v. Taylor, the Second Circuit reviewed supplemental briefing and recent authorities. The Second Circuit again affirmed the district court’s judgment, holding that New York's immunization law is neutral and generally applicable, and thus constitutional under rational basis review. The court also held that the law does not impose a burden “of the same character” as the parental free-exercise burdens addressed in Yoder and Mahmoud, so strict scrutiny does not apply. The Second Circuit concluded that plaintiffs failed to state a viable Free Exercise or Yoder-type claim, and affirmed the dismissal of their suit. View "Miller v. McDonald" on Justia Law

Besicorp v. Commissioner of Internal Revenue

2026-06-29T07:00:03-08:00

Several related corporate taxpayers engaged in transactions that the Internal Revenue Service determined were tax shelter schemes intended to avoid federal taxes. After audits, the IRS found that each taxpayer owed substantial deficiencies, penalties, and interest. The United States Tax Court previously adjudicated the liabilities for all six taxpayers, either through contested proceedings or stipulated decisions, and those determinations are now final and not at issue in this appeal. When the IRS sought to collect the assessed amounts by filing tax liens and issuing notices of intent to levy, each taxpayer requested a collection due process (CDP) hearing with the IRS Appeals Office, as provided by statute. At each CDP hearing, the Appeals Officer sustained the IRS’s liens and proposed levies, indicating that all necessary legal and procedural requirements had been met. The taxpayers challenged these determinations in the Tax Court, arguing that the Appeals Officer failed to verify that the penalties had received written supervisory approval as required by 26 U.S.C. § 6751(b)(1). The Tax Court, following its decision in Warner Enterprises, Inc. v. Commissioner, held that when penalties had already been conclusively determined in prior proceedings, the Appeals Officer was not required to verify compliance with the supervisory approval requirement during the CDP process, and granted summary judgment for the Commissioner. On appeal, the United States Court of Appeals for the Second Circuit held that the verification obligation imposed by 26 U.S.C. § 6330(c)(1) on Appeals Officers in CDP hearings includes the requirement to verify written supervisory approval for penalties under § 6751(b)(1), regardless of whether the penalties were previously adjudicated. The court concluded that failure to perform this verification invalidates the Appeals Officer’s determination that the liens and proposed levies were proper, although it does not affect the underlying tax liabilities or penalties themselves. The Second Circuit reversed the Tax Court’s orders on this issue and remanded for further proceedings. View "Besicorp v. Commissioner of Internal Revenue" on Justia Law

Huey v. Anavex Life Sciences Corporation

2026-06-26T06:30:03-08:00

An investor in a publicly traded biopharmaceutical company filed a proposed class action against the company and its CEO, alleging securities fraud. The plaintiff claimed that the company misled investors by suggesting that the FDA had approved their methodology for measuring a drug’s efficacy in clinical trials. The alleged misrepresentation was made in a press release that communicated the FDA’s input on the study’s endpoints, but, according to the plaintiff, failed to disclose that the FDA found the methodology unacceptable. When the company later announced it would not use the disputed methodology, the share price initially increased. A decline in the share price occurred over the next two days, during which the stock moved in line with the general market. The United States District Court for the Southern District of New York dismissed the complaint with prejudice, holding that the plaintiff failed to sufficiently plead loss causation, an essential element of a securities fraud claim. The court noted that the share price rose on the day of the corrective disclosure and only declined later, in tandem with the broader market. The district court also denied the plaintiff’s request to amend the complaint, reasoning that amendment would be futile. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court's dismissal de novo. The appellate court agreed that the plaintiff did not plausibly allege loss causation. It explained that when a stock price does not fall immediately after a corrective disclosure, and a later decline coincides with general market losses, a plaintiff must provide a plausible explanation linking the loss to the alleged fraud. Because the plaintiff failed to do so, the Second Circuit affirmed the district court’s judgment and denial of leave to amend. View "Huey v. Anavex Life Sciences Corporation" on Justia Law

United States v. Parks

2026-06-24T06:00:03-08:00

In this case, the defendant was convicted after a jury trial of two counts of kidnapping resulting in death and one count of witness tampering by killing, all related to violent events in 2015. The evidence showed that the defendant, a gang member involved in illegal gun trafficking, kidnapped two individuals as collateral when a third party failed to pay for firearms. He threatened their lives if payment was not made, and when the deadline passed, the defendant fatally shot both victims. Later that same day, the defendant also killed a witness, allegedly to prevent him from reporting the kidnappings and murders to law enforcement. The United States District Court for the District of Connecticut presided over the trial. The jury was instructed that to convict on the kidnapping resulting in death charges, it needed to find only that the defendant’s conduct was the “but-for” cause of the deaths, not that the deaths were a reasonably foreseeable (proximate) result of the kidnapping. The defendant moved for acquittal or a new trial, arguing insufficient evidence and challenging the jury instructions, particularly the omission of a proximate cause requirement. The district court denied the motions, prompting this appeal. The United States Court of Appeals for the Second Circuit reviewed the case. The main issue was whether the “death results” enhancement for kidnapping requires proof of proximate cause or only but-for cause. The Second Circuit held that the statutory language does not require proximate cause; but-for causation is sufficient. The court also found the evidence sufficient for all counts and determined that any error in the instructions would be harmless given the overwhelming evidence. The defendant’s convictions and sentences were affirmed. View "United States v. Parks" on Justia Law

United States v. Parks

2026-06-22T07:00:03-08:00

In this case, the defendant was convicted on two counts of kidnapping resulting in death and one count of witness tampering by killing, based on events in which he held two victims as collateral at gunpoint after a third party left his home with guns without paying. When the guns or payment were not returned by a deadline, the defendant forced the victims to accompany him and, according to eyewitness and forensic evidence, shot and killed both. Later, he killed a third individual, an eyewitness, to prevent him from cooperating with federal law enforcement. The evidence included testimony from multiple witnesses present at the scene, forensic corroboration, and statements made by the defendant implicating himself in the crimes. The United States District Court for the District of Connecticut presided over the trial. The jury convicted the defendant on all counts, and the court imposed three consecutive life sentences. The defendant moved for acquittal or a new trial, arguing errors in the sufficiency of the evidence and the jury instructions, particularly challenging the instruction that the kidnapping needed to be only a “but-for” cause of death rather than a proximate cause. The district court denied these motions. Upon appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s instructions and the sufficiency of the evidence. The appellate court held that, under the relevant federal kidnapping statute, the government need only prove that the kidnapping was a but-for cause of death rather than requiring proximate causation. The court found that the trial evidence overwhelmingly supported the convictions and that any alleged instructional error would have been harmless. The court also upheld the sufficiency of evidence for the witness tampering count. The convictions and sentences were affirmed in full. View "United States v. Parks" on Justia Law

Levin v. City of Buffalo

2026-06-18T06:30:03-08:00

The case involves Maxim Levin and Vodka Properties LLC, who owned a residential building in Buffalo, New York, that was demolished by the City of Buffalo in 2019 under emergency procedures. The City justified the emergency demolition by citing illegal drug activity on the property, including a recent overdose death, and the building’s vacant and allegedly structurally compromised condition. Plaintiffs contested whether these circumstances actually warranted an immediate demolition without a pre-deprivation hearing and argued that their constitutional rights were violated. A magistrate judge in the United States District Court for the Western District of New York recommended denying summary judgment on some constitutional claims, finding disputed facts about the condition of the property and notice provided. The district court, however, dismissed certain claims, including procedural due process, based on its finding that adequate notice was given and that the individual City employees (except the City itself) were entitled to qualified immunity. The court also dismissed claims against the demolition company for lack of state action and dismissed claims against the City, concluding there was no municipal liability under Monell v. Department of Social Services. The United States Court of Appeals for the Second Circuit held that summary judgment was improper on the procedural due process, unlawful taking, and unreasonable seizure claims, because there were unresolved factual questions about whether the property’s condition justified emergency demolition. The appellate court further determined that Commissioner James Comerford, Jr. was the City’s final policymaker regarding demolition decisions, so Monell liability was improperly dismissed. The court reversed the grant of qualified immunity for the Commissioner due to factual disputes but affirmed summary judgment for the other individual employees and the demolition company. The court affirmed dismissal of the substantive due process and state law claims. The judgment was affirmed in part, vacated in part, and the case remanded for further proceedings. View "Levin v. City of Buffalo" on Justia Law

United States v. Liounis

2026-06-16T09:00:10-08:00

The defendant was convicted in 2014 of multiple counts of fraud and sentenced to nearly 24 years in prison and ordered to pay approximately $3.8 million in restitution. Years later, the government sought to enforce the restitution order by pursuing a writ of garnishment against funds expected from a September 11th Victims Compensation Fund award, which were to be received by a law firm on the defendant’s behalf. After being notified of the garnishment, the defendant, acting pro se, objected and requested, among other things, that proceedings be transferred to the federal district where he resided, as provided for under the Federal Debt Collection Procedures Act. The United States District Court for the Eastern District of New York denied his objections, including the transfer request. The court held that the September 11th funds were not exempt from garnishment, that the defendant was not entitled to a hearing since his objections were meritless, and that transfer of venue was not mandatory but discretionary. The district court relied on its interpretation of the statute and on prior case law, concluding it retained authority to deny transfer requests for good cause. The United States Court of Appeals for the Second Circuit reviewed the case. It held that the statutory language of the Federal Debt Collection Procedures Act makes transfer of a garnishment proceeding mandatory when timely requested by the debtor. The court found that the district court erred by treating transfer as discretionary, and further held that failure to transfer is not subject to harmless error review. Accordingly, the Second Circuit vacated the district court’s judgment and remanded the case for the district court to consider a renewed motion to transfer the proceedings to the district in which the defendant currently resides. View "United States v. Liounis" on Justia Law

United States v. Robinson

2026-06-16T09:00:05-08:00

After returning to the United States from international travel in 2022, the defendant was subjected to a customs inspection at JFK Airport. During this inspection, authorities searched his cellphone and discovered evidence of child sexual abuse material. Based on these initial findings, the government obtained a warrant to conduct a more thorough forensic search, which uncovered additional images and videos of child pornography. The defendant was subsequently charged with related offenses. The United States District Court for the Eastern District of New York granted the defendant’s motion to suppress the cellphone evidence, ruling that the initial search lacked probable cause or a warrant and that the government could not rely on the good faith exception to the exclusionary rule. The government filed an interlocutory appeal and timely submitted a notice of appeal. However, the defendant moved to dismiss the appeal, arguing that the statutory certification required by 18 U.S.C. § 3731 was invalid because it was signed by an interim United States Attorney who, at the time, was allegedly not lawfully appointed. The defendant claimed this defect deprived the appellate court of jurisdiction. The United States Court of Appeals for the Second Circuit reviewed the case and assumed, for argument’s sake, that the original certification was invalid. The court determined that subsequent certifications—one by the same United States Attorney after proper appointment by the district court and another by the Attorney General—were sufficient, even though they were filed after the appeal period expired. The court held that late certification does not eliminate jurisdiction, but permits discretionary dismissal under Federal Rule of Appellate Procedure 3(a). Exercising its discretion, the Second Circuit denied the defendant’s motion to dismiss and concluded that it had appellate jurisdiction under § 3731, confining its decision to this jurisdictional issue. View "United States v. Robinson" on Justia Law

U.S. v. Bankman-Fried

2026-06-12T14:00:07-08:00

The case concerns actions taken by the former CEO of a prominent cryptocurrency exchange and a related trading firm. The defendant, who exercised substantial control over both entities, was accused of misappropriating billions of dollars of customer funds. These funds, which customers believed would be safely held and used only for authorized transactions, were instead funneled to the trading firm and used for various unauthorized purposes, including investments, political contributions, and purchases of real estate. The collapse of cryptocurrency markets in 2022, followed by a rapid loss of customer confidence and mass withdrawals, ultimately led to the bankruptcy of both the exchange and the trading firm. After the bankruptcy, the defendant was indicted in the United States District Court for the Southern District of New York on several counts of fraud and conspiracy. The government’s case was supported by testimony from the defendant’s close associates, who described how the defendant orchestrated the transfer and misuse of customer funds, and by business records and communications. The defendant argued that he believed all customers would ultimately be repaid and that he acted in good faith. The jury found the defendant guilty on all counts, and the district court sentenced him to 25 years in prison, imposed a three-year term of supervised release, and ordered a forfeiture of approximately $11 billion. On appeal to the United States Court of Appeals for the Second Circuit, the defendant challenged the district court’s evidentiary rulings, jury instructions, discovery-related decisions, and the forfeiture order. The Second Circuit held that the district court did not err in its evidentiary rulings, instructions, or discovery decisions, and that the forfeiture was authorized and not constitutionally excessive. The judgment of the district court was affirmed. View "U.S. v. Bankman-Fried" on Justia Law

United States v. Simmons

2026-06-01T08:00:13-08:00

While under supervised release for a prior fraud conviction, the defendant was charged in the United States District Court for the Eastern District of New York with multiple violations of the terms of his release, including fraudulently obtaining a loan, unauthorized travel, and prohibited communication with felons. On the scheduled date for his violation of supervised release (VOSR) hearing, the defendant failed to appear, despite having been informed of the time and place and contacted by his counsel. The district court delayed the proceedings to allow for his arrival, then, after continued absence, issued a warrant for his arrest and proceeded with the hearing in his absence. The court found overwhelming evidence of violations, based on records and counsel’s concessions, but did not immediately impose a sentence. Over a year later, the defendant was arrested in Florida and returned to New York, where he pleaded guilty to failing to appear for the VOSR hearing. The district court then held a combined sentencing, imposing concurrent sentences for the supervised release violations and a separate, consecutive sentence for the failure to appear, citing 18 U.S.C. § 3146(b)(2) as requiring the sentences to be consecutive. The defendant appealed, arguing that the court erred by conducting the VOSR hearing in absentia, by imposing consecutive sentences based on a mistaken interpretation of the statute, and by upholding the constitutionality of supervised release revocation proceedings. The United States Court of Appeals for the Second Circuit held that the defendant knowingly and voluntarily waived his right to be present at the VOSR hearing, and any error in proceeding without him was harmless. The court concluded that it was not plain error for the district court to impose consecutive sentences under 18 U.S.C. § 3146(b)(2), given the unsettled nature of the law. The court also reaffirmed the constitutionality of supervised release revocation proceedings. The judgment of the district court was affirmed. View "United States v. Simmons" on Justia Law

United States v. The M/Y Amadea

2026-06-01T08:00:08-08:00

The United States government brought a civil forfeiture action against a luxury superyacht, alleging that it was beneficially owned by a Russian national subject to U.S. sanctions. Two claimants, an individual and his company, asserted that they—not the sanctioned individual—owned the yacht, both legally and beneficially. The government, however, argued that these claimants were mere straw owners holding title on behalf of the sanctioned individual and therefore lacked constitutional standing to contest the forfeiture. The United States District Court for the Southern District of New York held an evidentiary hearing to resolve factual disputes regarding the claimants’ standing. The court found, by a preponderance of the evidence, that the claimants had relinquished all meaningful ownership and control over the yacht through a memorandum of agreement executed in September 2021. As a result, the court concluded that the claimants were only bare title holders, acting as straw owners, and lacked Article III standing to object to the forfeiture. The court granted the government’s motion to strike the claim and entered default and final judgments of forfeiture when no other claims were filed. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Second Circuit affirmed, holding that the claimants’ legal title alone did not establish standing where the evidence showed they retained no substantive ownership interest after the September 2021 agreement. The court also upheld the district court’s exclusion of a hearsay declaration and concluded there was no procedural error in the conduct of the evidentiary hearing. The judgment of forfeiture was affirmed. View "United States v. The M/Y Amadea" on Justia Law

United States v. Ross

2026-05-29T06:00:03-08:00

In 2003, the defendant pleaded guilty in Vermont state court to a charge of domestic assault under a state statute, specifically for “willfully or recklessly causing bodily injury to a family or household member.” Many years later, police found a firearm in her car during a traffic stop. Based on her prior domestic assault conviction, she was charged in federal court under 18 U.S.C. § 922(g)(9), which prohibits firearm possession by anyone convicted of a “misdemeanor crime of domestic violence.” The defendant did not dispute her prior conviction but argued that the Vermont statute did not meet the federal definition because it did not require, as an element, “the use or attempted use of physical force.” The United States District Court for the District of Vermont denied the defendant’s motion to dismiss the indictment, finding that her prior conviction qualified as a “misdemeanor crime of domestic violence.” The defendant then entered a conditional guilty plea, reserving the right to appeal this legal issue. She was sentenced to time served and one year of supervised release, and appealed the conviction. The United States Court of Appeals for the Second Circuit reviewed the case. It held that the Vermont domestic assault statute is divisible into three separate offenses. The court found that the specific offense for which the defendant was convicted—willfully or recklessly causing bodily injury—requires proof of the use of physical force under federal law. Relying on United States Supreme Court precedent, the court concluded that such a conviction qualifies as a “misdemeanor crime of domestic violence” for purposes of 18 U.S.C. § 922(g)(9). Accordingly, the Second Circuit affirmed the judgment of conviction. View "United States v. Ross" on Justia Law

The Satanic Temple, Inc. v. Newsweek Digital LLC

2026-05-28T07:00:12-08:00

A national news organization published an article in 2021 detailing internal conflicts within a religious group, including a quote from a former member alleging that reports of sexual abuse were “being covered up in ways that were more than anecdotal.” The religious group, which has a large national membership, sued the news organization and the article’s author for defamation, contending that the article’s statements were false and published with actual malice. The author, based in Washington state, conducted all her research and reporting outside New York, though the news organization is headquartered in New York. The United States District Court for the Southern District of New York dismissed the claims against the article’s author for lack of personal jurisdiction, finding she had no relevant contacts with New York. The court also dismissed most of the claims against the news organization, allowing only the statement about covering up sexual abuse to proceed. At summary judgment, the district court applied New York’s anti-SLAPP statute, which requires a heightened showing of actual malice for defamation cases involving matters of public interest, and ruled for the news organization, holding the religious group had not shown a triable issue as to actual malice. On appeal, the United States Court of Appeals for the Second Circuit affirmed both rulings. It held that New York courts did not have personal jurisdiction over the author under the state’s long-arm statute because she did not engage in any journalistic activity in New York related to the article. The appellate court also held that New York’s anti-SLAPP law applied, requiring the religious group to prove actual malice by clear and convincing evidence, and found the group had failed to raise a genuine issue of fact on that element. The judgments for the defendants were affirmed. View "The Satanic Temple, Inc. v. Newsweek Digital LLC" on Justia Law

Smith v. The Gap, Inc.

2026-05-28T07:00:08-08:00

Gap, a major clothing retailer, launched an initiative in August 2021 to expand plus-size clothing options in its Old Navy stores. The company overestimated customer demand for these larger sizes, resulting in excess inventory that had to be sold at discounts. By early 2022, Gap reduced its in-store plus-size offerings and eventually limited extended sizing to online sales. In May 2022, Gap disclosed that these missteps negatively affected its financial results for the first quarter of the year. Investors who purchased Gap stock between November 24, 2021, and July 11, 2022, filed a putative securities class action in the United States District Court for the Eastern District of New York. They alleged that Gap and two senior executives violated the Securities Exchange Act of 1934 by failing to disclose problems with the initiative in various statements to investors. The district court dismissed the complaint under Rule 12(b)(6), concluding that the plaintiffs did not identify any false or misleading statements or adequately plead that the defendants acted with scienter (intent or recklessness). The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court held that the challenged statements—including risk disclosures, earnings call remarks, and press releases—were not false or misleading in context and did not obligate Gap to disclose the problems with the initiative. The court found that the statements at issue were either generic industry risks, unactionable opinions or puffery, or did not give rise to a duty to disclose additional information. The appellate court also concluded that the plaintiffs failed to allege facts supporting a strong inference of scienter and, accordingly, their control-person liability claims under Section 20(a) were properly dismissed. The judgment of the district court was affirmed. View "Smith v. The Gap, Inc." on Justia Law

Colwell v. Sig Sauer, Inc.

2026-05-28T07:00:03-08:00

A police sergeant suffered a gunshot injury to his leg when his department-issued Sig Sauer P320 pistol discharged while he was conducting a training exercise. He did not know what caused the trigger to move, but testified that the pistol was holstered and his hand was not on the gun at the time. Emergency responders’ documentation, however, suggested the gun discharged while he was still holstering it. The injured officer and his spouse brought strict products liability and negligence claims against the manufacturer, alleging that the P320 was defectively designed because it lacked an external safety, making it prone to accidental discharges. The United States District Court for the Northern District of New York excluded the causation opinions of the plaintiffs’ experts, finding their analysis unreliable because they did not explain how the accident happened or how an external safety would have prevented it. The district court then granted summary judgment for the manufacturer, concluding New York law required expert testimony to establish proximate causation in a case involving the operation of a complex product like a firearm, and the plaintiffs could not meet that burden without admissible expert causation opinions. The United States Court of Appeals for the Second Circuit reviewed the case and held that the district court did not abuse its discretion by excluding the experts’ causation opinions, as they were not sufficiently grounded in the facts of the accident. However, the Second Circuit ruled that the district court erred in granting summary judgment. The appellate court held that, under New York law, expert testimony on causation is not always required if a jury can determine causation based on its own judgment, the characteristics of the product, and the evidence presented. The court vacated the district court’s judgment and remanded the case for further proceedings. View "Colwell v. Sig Sauer, Inc." on Justia Law

Ryniker v. Sumec Textile Co.

2026-05-27T08:30:03-08:00

Décor Holdings, Inc. and its affiliates, sellers of decorative fabric, filed for Chapter 11 bankruptcy in February 2019. Sumec Textile Company Limited, a Chinese manufacturer, was listed as a major unsecured creditor. After filing an insurance claim with Sinosure (China Export & Credit Insurance Corporation) for Décor’s unpaid debt, Sumec authorized Sinosure to collect the full amount owed. Sinosure then hired Brown & Joseph, LLC (B&J), a U.S. collection agency, which filed Sumec’s proof of claim in the bankruptcy proceeding, listing itself as the recipient of notices to the creditor. In August 2020, Bryan Ryniker, as litigation administrator, commenced an adversary proceeding against Sumec to recover alleged preferential payments. Service of process was made on B&J as Sumec’s agent. The United States Bankruptcy Court for the Eastern District of New York entered a default judgment against Sumec, finding service on B&J sufficient. Sumec moved to vacate, claiming B&J lacked authority to accept service. The bankruptcy court denied the motion, relying on the agency relationship. On appeal, the United States District Court for the Eastern District of New York vacated the default judgment, ruling that Sumec had not expressly or impliedly authorized B&J to accept service of process. On remand, the bankruptcy court dismissed the adversary proceeding with prejudice. The United States Court of Appeals for the Second Circuit reviewed the dismissal. It held that the record established Sumec had conferred actual authority on Sinosure and B&J, both to file the proof of claim and to act to collect the full amount owed, implicitly authorizing B&J to accept service of process in the adversary proceeding. The Second Circuit vacated both the district court’s and bankruptcy court’s orders, reinstated the default judgment, and remanded for further proceedings. View "Ryniker v. Sumec Textile Co." on Justia Law

Sufiyan v. Blanche

2026-05-26T06:30:03-08:00

A native and citizen of Sri Lanka sought protection in the United States, claiming that he would face persecution and torture if returned to his home country. He described being forcibly detained by members of the Liberation Tigers of Tamil Eelam (LTTE), a designated terrorist organization, compelled to serve as a translator during their interrogation of another captive, and subsequently detained and beaten by the Sri Lankan army under suspicion of LTTE affiliation. After living in Sri Lanka without incident for several years, he traveled to and from the United States, ultimately seeking asylum, withholding of removal, and relief under the Convention Against Torture (CAT). An Immigration Judge (IJ) denied all forms of relief, ruling that the applicant was barred from asylum and withholding due to his provision of material support to the LTTE, and finding his asylum application untimely. The IJ also determined that the applicant had not demonstrated past persecution or a well-founded fear of future persecution, and that his CAT claims failed for lack of corroboration and insufficient likelihood of torture upon return. The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, relying exclusively on the material support bar for asylum and withholding claims, and upholding the denial of CAT deferral on the merits, without assessing whether the applicant would otherwise qualify for asylum or withholding but for the bar. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the BIA erred by not determining whether the applicant would be entitled to asylum or statutory withholding of removal if the material support bar did not apply, as such findings are necessary for the applicant to pursue a discretionary waiver from the Department of Homeland Security. The court granted the petition in part and remanded for this determination. The petition for review of the denial of CAT relief was denied. View "Sufiyan v. Blanche" on Justia Law

Bellin v. McDonald

2026-05-21T06:01:25-08:00

A Medicaid recipient in her late 80s, suffering from serious health conditions, applied in 2019 for 24-hour at-home personal care services through New York’s Medicaid program. The state, which provides varying levels of in-home care to eligible Medicaid recipients, partners with private managed long-term care plans (MLTCPs) to assess needs and offer care plans. The plaintiff was initially offered only eight hours of daily care by all MLTCPs she applied to, though she believed she required around-the-clock assistance. Under New York’s regulations, individuals cannot immediately appeal the initial level of care offered; they must first enroll in the plan, request an increase, and only appeal if that request is denied. The plaintiff followed this process and ultimately received 24-hour care after subsequent assessments, but with a delay and a gap in retroactive reimbursement for services. The United States District Court for the Southern District of New York granted summary judgment to the defendants—the State's Health Commissioner and the MLTCP—holding that the plaintiff did not have a cognizable property interest in a particular level of care, and therefore no due process rights were implicated. The court also denied class certification. The plaintiff appealed these decisions. The United States Court of Appeals for the Second Circuit reviewed the case de novo. The Second Circuit disagreed with the District Court’s conclusion regarding the existence of a property interest. It held that New York’s laws, regulations, and practices substantially restrict discretion in determining eligibility for 24-hour personal care services, thereby creating a property interest for qualifying Medicaid recipients and triggering due process protections. However, the court determined that New York’s current appeals procedures, though delayed, are constitutionally adequate because the delay is modest, expedited procedures exist for urgent cases, and the overall private interests at stake are sufficiently protected. On this alternative ground, the Second Circuit affirmed the District Court’s grant of summary judgment to the defendants. View "Bellin v. McDonald" on Justia Law

United States of America v. Amazon.com, Inc.

2026-05-20T06:30:22-08:00

The case involves allegations by two relators, acting on behalf of the United States, that Amazon.com, Inc. and Amazon.com Services, LLC facilitated and conspired with foreign manufacturers to submit false records to the U.S. government. The relators claimed that these manufacturers, who sold fur products via Amazon’s platform, provided false information on Customs Declarations to avoid paying mandatory tariffs and inspection fees on imported fur products. According to the complaint, Amazon was not the importer of record, but the relators alleged that Amazon either knew or should have known about the fraudulent conduct due to discrepancies in documentation and the absence of required forms, and that Amazon nonetheless continued to market, store, and deliver the products. The United States District Court for the Southern District of New York reviewed the relators’ second amended complaint under Federal Rule of Civil Procedure 12(b)(6). The court dismissed the claims, concluding that the relators failed to adequately allege that Amazon had the requisite knowledge or causation necessary for liability under 31 U.S.C. § 3729(a)(1)(G) (the “reverse false claims” provision of the False Claims Act), and failed to plead the essential elements of a conspiracy claim under § 3729(a)(1)(C), including an agreement to violate the statute and overt acts in furtherance of such a conspiracy. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal. The Second Circuit held that the relators did not plausibly allege that Amazon had actual knowledge, deliberate ignorance, or reckless disregard regarding the foreign manufacturers’ false claims, as required by the statute. The court also determined the relators had not alleged facts showing an agreement or overt act necessary to support a conspiracy claim. Thus, the district court’s judgment dismissing the complaint in its entirety was affirmed. View "United States of America v. Amazon.com, Inc." on Justia Law

United States v. Parasmo

2026-05-19T06:00:13-08:00

A licensed medical doctor in New York was charged with unlawfully distributing controlled substances, specifically opioids, to multiple patients between 2014 and 2015. Evidence at trial showed the doctor continued prescribing large quantities of oxycodone and hydrocodone even after learning that patients were addicted, diverting medications, or abusing other substances. The doctor was repeatedly warned by insurers, pharmacies, and the state medical society about overprescribing. The United States District Court for the Eastern District of New York presided over the case. After a jury trial, the doctor was convicted on thirty-two counts of unlawful distribution of controlled substances in violation of 21 U.S.C. § 841. Following the Supreme Court’s decision in Ruan v. United States, the defendant argued the jury instructions were erroneous and sought acquittal or a new trial, but the district court denied these motions. On appeal, the United States Court of Appeals for the Second Circuit addressed three main issues: whether the district court’s jury instructions improperly used an objective rather than subjective standard of intent, whether expert testimony and evidence about New York’s medical standards were improperly admitted, and whether the defendant received ineffective assistance of counsel. The Second Circuit agreed the jury instruction on intent was erroneous under the new Ruan standard but held the error was harmless given overwhelming evidence of the defendant’s subjective intent. The court also found the evidentiary rulings proper, as the expert testimony assisted the jury without usurping its function. The ineffective assistance claim was deemed more appropriate for collateral review and not addressed on direct appeal. The Second Circuit affirmed the district court’s judgment. View "United States v. Parasmo" on Justia Law

K.W. v. The City of New York

2026-05-19T06:00:04-08:00

A father, K.W., lost custody of his newborn son, K.A., when New York City’s Administration for Children’s Services removed the infant from his care without a court order, citing concerns about the mother’s history of neglect toward her other children. At the time, K.W. had not been accused of any abuse or neglect, and K.A. had been living with him since birth. The following day, the agency obtained a family court order for continued removal, but the petition did not cite any wrongdoing by K.W. and omitted key facts about his involvement as K.A.’s caretaker. As a result, K.W. was denied custody and granted only limited visitation for nearly three years, despite no allegations of unfitness. Both K.W. and K.A. suffered emotional harm from the prolonged separation. The United States District Court for the Southern District of New York granted a motion to dismiss all of the plaintiffs’ claims, ruling that they had not successfully stated a claim and that the defendant caseworker was entitled to qualified immunity. The district court also dismissed the claims against the Children’s Aid Society and its caseworker. On appeal, the United States Court of Appeals for the Second Circuit found that the plaintiffs stated viable claims on behalf of K.A. for unlawful seizure under the Fourth Amendment and for violation of procedural due process under the Fourteenth Amendment. The court concluded that qualified immunity did not protect the individual caseworker, Moody, for these claims. However, the court affirmed dismissal of K.W.’s individual procedural due process claim as time-barred, and upheld dismissal of all claims against the Children’s Aid Society and its caseworker. The Second Circuit reversed in part, affirmed in part, and remanded the surviving claims for further proceedings. View "K.W. v. The City of New York" on Justia Law

Christian v. James

2026-05-18T06:30:03-08:00

The plaintiffs challenged two provisions of New York’s Concealed Carry Improvement Act (CCIA): one that criminalizes carrying firearms on private property open to the public unless the owner has explicitly permitted it (the Private Property Provision), and another that prohibits firearm possession in “sensitive locations,” specifically public parks (the Public Parks Provision). Plaintiffs argued that these provisions violate the Second and Fourteenth Amendments. The Private Property Provision was challenged as applied to places open to the public, while the Public Parks Provision was subject to a facial challenge, with plaintiffs later attempting, unsuccessfully, to add an as-applied challenge concerning rural parks. The United States District Court for the Western District of New York permanently enjoined the State from enforcing the Private Property Provision as applied to private property open to the public, finding it unconstitutional because it was not consistent with the nation’s historical tradition of firearms regulation. The district court, however, granted summary judgment to the State on the Public Parks Provision, concluding that it was facially constitutional since historical analogues supported restrictions on firearms in public parks. The district court declined to consider plaintiffs’ as-applied challenge to the parks provision, ruling that this argument had not been properly raised. The United States Court of Appeals for the Second Circuit reviewed both appeals. It affirmed the permanent injunction against the Private Property Provision, holding that the State failed to show that the restriction is consistent with the historical tradition of regulating firearms, as required by New York State Rifle & Pistol Association, Inc. v. Bruen. The court also affirmed the judgment in favor of the State on the Public Parks Provision, finding it constitutional as applied to urban parks, and declined to consider the as-applied challenge regarding rural parks since it had not been raised below. View "Christian v. James" on Justia Law

Am. Ass'n of Univ. Professors v. Department of Justice

2026-05-14T07:30:03-08:00

Union Plaintiffs, comprised of two labor organizations, challenged the federal government's termination of approximately $400 million in funding to Columbia University and its demand for significant reforms at the institution. Columbia University was not a party in the lawsuit. The plaintiffs sought injunctive relief to restore funding, prevent enforcement of the government’s reform demands, protect future grants and contracts, and recover damages. The United States District Court for the Southern District of New York denied the plaintiffs’ motion for a preliminary injunction and dismissed the case for lack of standing. After this dismissal, the plaintiffs appealed to the United States Court of Appeals for the Second Circuit. While the appeal was pending, Columbia and the government reached an agreement whereby most of the disputed funding was restored and Columbia agreed to implement certain reforms. Following this, the plaintiffs withdrew their requests for prospective equitable relief and damages, citing changed circumstances. The United States Court of Appeals for the Second Circuit reviewed a joint motion from both parties to dismiss the appeal, vacate the district court’s order, and remand with instructions to dismiss the case as moot. The court held that the case was moot for reasons not fairly attributable to the plaintiffs and granted the joint motion in full. The court dismissed the appeal as moot, vacated the district court’s order, and remanded with instructions to dismiss the case as moot, emphasizing that vacatur was appropriate due to circumstances beyond the plaintiffs’ control and the agreement between the parties. View "Am. Ass'n of Univ. Professors v. Department of Justice" on Justia Law

Banco San Juan Internacional, Inc. v. Fed. Rsrv. Bank of N.Y., Bd. of Governors of the Fed. Rsrv.

2026-05-13T07:00:09-08:00

A Puerto Rican international banking entity, which operated under an offshore charter and was regulated by Puerto Rico’s Office of the Commissioner of Financial Institutions, maintained a master account with the Federal Reserve Bank of New York. In 2019, following a federal investigation into potential anti-money laundering violations involving a Venezuelan client, the entity’s offices were raided and its account was temporarily suspended. After the investigation concluded with a fine and compliance improvements, the account was restored under stricter risk-mitigation terms. However, in 2022 and 2023, the Federal Reserve Bank determined the entity had not met required compliance standards and ultimately terminated the master account, citing serious risk concerns related to money laundering and deficiencies in compliance programs. The entity sued in the United States District Court for the Southern District of New York, seeking to compel reinstatement of its account and damages. It claimed a statutory entitlement to a master account under the Federal Reserve Act, as amended by the Monetary Control Act, and brought claims under the Administrative Procedure Act, Mandamus Act, Declaratory Judgment Act, the Fifth Amendment, and New York contract law, among others. The district court denied preliminary relief and dismissed all claims, holding that the relevant statutes did not create a nondiscretionary entitlement to a master account and finding failures in both standing and the plausibility of the claims. The United States Court of Appeals for the Second Circuit affirmed. It held that the Federal Reserve Act does not grant depository institutions a statutory or nondiscretionary right to a master account; instead, regional Reserve Banks retain discretion over account access. The court further found that the plaintiff lacked standing to sue the Federal Reserve Board of Governors, failed to plausibly allege contract or constitutional claims, and that amendment of the complaint would be futile. The district court’s judgment was affirmed in all respects. View "Banco San Juan Internacional, Inc. v. Fed. Rsrv. Bank of N.Y., Bd. of Governors of the Fed. Rsrv." on Justia Law

Article 13 LLC v. LaSalle NationalBank Ass'n

2026-05-13T07:00:03-08:00

A junior mortgage holder sought to quiet title against a senior mortgage on a Brooklyn property, arguing that the senior mortgage had become unenforceable under New York’s six-year statute of limitations. The senior mortgage had been accelerated by the filing of a foreclosure action in 2007, which was later discontinued without prejudice. The junior mortgage was subsequently assigned to the plaintiff, who argued that the limitations period had expired, thus barring any further foreclosure by the senior lienholder. The validity of the original 2007 foreclosure action, specifically whether it properly accelerated the debt, was disputed. The United States District Court for the Eastern District of New York denied both parties’ motions for summary judgment, citing a disputed issue of material fact regarding the standing of the entity that initiated the 2007 foreclosure. Shortly after this ruling, New York enacted the Foreclosure Abuse Prevention Act (FAPA), which, among other provisions, bars the defense that a prior acceleration was invalid in quiet title actions unless a court previously expressly determined invalidity. The district court, upon reconsideration, held FAPA applied retroactively and did not violate constitutional due process protections, and granted summary judgment to the junior mortgage holder. On appeal, the United States Court of Appeals for the Second Circuit certified questions to the New York Court of Appeals, which held that FAPA applies retroactively and that such application does not violate the New York Constitution’s due process guarantees. The Second Circuit then addressed whether retroactive application of FAPA violates substantive or procedural due process, the Contracts Clause, or the Takings Clause under the U.S. Constitution. The Second Circuit held that FAPA’s retroactive application does not violate any of these federal constitutional provisions and affirmed the district court’s judgment. View "Article 13 LLC v. LaSalle NationalBank Ass'n" on Justia Law

United States v. Dralle

2026-05-12T06:30:12-08:00

Federal authorities investigated a man after discovering that his co-defendant, who had been involved in two separate shooting incidents, had purchased a firearm for him. The defendant was charged with illegal receipt of a trafficked firearm based on this transaction. He pleaded guilty to that charge and was released pending sentencing, but while on bail, he was alleged to have participated in an assault and attempted robbery at a gas station, leading to the revocation of his bail. The United States District Court for the District of Connecticut held a sentencing hearing, during which it imposed a sentence of 30 months’ imprisonment—substantially above the advisory Sentencing Guidelines range of 12 to 18 months. The district court based its decision in part on the defendant’s alleged uncharged conduct while on bail and on the violent conduct of the co-defendant, specifically the two shootings. The district court reasoned that these incidents provided relevant context for the nature and circumstances of the defendant’s offense, even though there was no evidence that the defendant participated in or was aware of the co-defendant’s shootings, and no finding was made regarding the reliability or proof of the uncharged conduct by the defendant. On appeal, the United States Court of Appeals for the Second Circuit held that the district court plainly erred by considering the co-defendant’s prior violent activities in sentencing the defendant. The Second Circuit found there was no basis to attribute the co-defendant’s shootings to the defendant under any sentencing factor, as they were not part of a joint undertaking or conspiracy and were not shown to be relevant to the defendant’s conduct. The court vacated the sentence and remanded for a full resentencing, instructing the district court not to consider the co-defendant’s unrelated violent acts and clarifying the process for addressing any alleged uncharged conduct by the defendant. View "United States v. Dralle" on Justia Law

United States v. Jimenez

2026-05-12T06:30:04-08:00

The case involves an individual who, in January 2020, sold fentanyl-laced heroin to an undercover police detective using his phone to arrange the sales. That same month, he shot someone in the knee and, after his arrest, was found with crack cocaine, heroin, and marijuana. He was indicted on five counts, including possession of ammunition after a felony conviction and drug-related offenses. He ultimately pled guilty to the ammunition charge under a plea agreement that included an express waiver of appeal for sentences within a specified range. The United States District Court for the Southern District of New York sentenced him to 105 months’ imprisonment and three years of supervised release, imposing several special conditions. Three of those conditions—electronic device searches upon reasonable suspicion, mandatory community service when unemployed, and participation in an outpatient mental health counseling program—were challenged by the defendant. In a prior appeal, the United States Court of Appeals for the Second Circuit vacated these three conditions due to insufficient explanation and remanded for further proceedings. On remand, the District Court elaborated on the reasons for imposing the conditions and reimposed them with some modifications. In the current appeal, the United States Court of Appeals for the Second Circuit reviewed the procedural and substantive reasonableness of these special conditions. The court held that the District Court did not abuse its discretion when imposing the challenged conditions, as they were sufficiently individualized and reasonably related to the relevant sentencing factors. The court also held that the defendant’s challenge to his term of imprisonment was barred by the appeal waiver in the plea agreement. Accordingly, the Second Circuit affirmed the judgment of the District Court. View "United States v. Jimenez" on Justia Law