Justia Civil Rights Opinion Summaries

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

Dr. Sari Edelman, a female rheumatologist, was employed by the New York University (NYU) hospital system. After nearly five years of employment without disciplinary issues, she had disputes with Joseph Antonik and David Kaplan regarding her office space. Edelman claimed that Antonik used a gender-based slur and behaved aggressively, and that Kaplan's subsequent handling of the issue was discriminatory. She lodged complaints with NYU human resources, alleging gender discrimination and hostile behavior. Her employment contract was not renewed the following year, leading to her termination.Edelman sued various NYU entities and individual employees, asserting claims under the federal and New York Equal Pay Acts, Title VII, the New York State Human Rights Law, and the New York City Human Rights Law. The United States District Court for the Southern District of New York granted partial judgment as a matter of law (JMOL) in favor of some defendants and dismissed certain claims. The jury found in favor of Edelman on her retaliation claims against NYU and Antonik, awarding her $700,000 in damages, but found for the defendants on all other claims. The District Court later granted judgment notwithstanding the verdict (JNOV) for the defendants, vacating the jury's verdict in favor of Edelman.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that there was sufficient evidence to support the jury's verdicts in Edelman's favor on her retaliation claims against NYU and Antonik. The court vacated the District Court's grant of JNOV for these claims and remanded with instructions to reinstate the jury's verdict. The court also vacated the District Court's decision granting JMOL in favor of Kaplan on the retaliation claim and remanded for a new trial on that claim. The judgment on the remaining claims was affirmed. View "Edelman v. NYU Langone Health System" on Justia Law

Lawrence Ray was convicted in the United States District Court for the Southern District of New York for multiple crimes, including racketeering conspiracy, extortion, sex trafficking, forced labor, money laundering, tax evasion, and committing a violent crime in aid of a racketeering enterprise. These convictions stemmed from Ray's operation of a criminal enterprise that targeted young adults, primarily his daughter's college roommates, for indoctrination and exploitation, including sex trafficking and forced labor in Pinehurst, North Carolina.The district court sentenced Ray to 720 months of imprisonment, followed by a lifetime term of supervised release. Ray appealed his conviction, arguing insufficient evidence to support his convictions, the unconstitutionality of the racketeering statutes, improper admission of expert testimony, and the substantive unreasonableness of his sentence.The United States Court of Appeals for the Second Circuit reviewed Ray's appeal. The court found sufficient evidence to support Ray's convictions, including the existence of an enterprise, the commission of violent crimes to maintain or increase his position in the enterprise, and the coercion of victims into sex trafficking and forced labor. The court also rejected Ray's constitutional challenge to the racketeering statutes, noting that such challenges have been consistently rejected in the past.Regarding the expert testimony, the court held that the district court did not abuse its discretion in admitting the testimony of Dr. Hughes, a clinical and forensic psychologist, who provided general background on coercive control tactics without directly linking her testimony to Ray or his victims. The court also found that the district court properly balanced the probative value of the testimony against its potential prejudicial effect.Finally, the court concluded that Ray's 720-month sentence was substantively reasonable, given the gravity of his crimes and the need for deterrence, incapacitation, and just punishment. The court affirmed the judgment of the district court. View "United States v. Ray" on Justia Law

In this case, the plaintiff, Josue Ortiz, claimed that Detective Mark Stambach fabricated and coerced a confession from him regarding a double homicide in 2004. Ortiz, who suffered from severe mental illness, was subsequently charged and convicted based on this false confession. In 2012, a reinvestigation revealed Ortiz's innocence, leading to the conviction of three other individuals for the murders. Ortiz's conviction was vacated, and he was released in 2014 after over a decade of wrongful imprisonment. A jury found Detective Stambach liable for malicious prosecution, fabrication of evidence, and violating Ortiz’s right against self-incrimination, awarding Ortiz $5 million in compensatory damages and $1.5 million in punitive damages.The United States District Court for the Western District of New York denied Detective Stambach’s post-trial motions for judgment as a matter of law, a new trial, and remittitur. Stambach argued that there was insufficient evidence for the jury to find in favor of Ortiz on any of the claims and that the damages awarded were excessive.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that sufficient evidence supported the jury’s findings on all three causes of action. The court noted that the jury could reasonably infer from the circumstantial evidence that Detective Stambach fabricated the confession and acted in bad faith. The court also found that the jury’s award of compensatory and punitive damages was justified based on the evidence presented at trial. Consequently, the Second Circuit affirmed the judgment of the district court, upholding the jury’s verdict and the damages awarded to Ortiz. View "Ortiz v. Wagstaff" on Justia Law

A Turkish graduate student, Rümeysa Öztürk, was lawfully residing in Massachusetts on a student visa when she was arrested by plainclothes officers without warning on March 25, 2025. She was transported across state lines and eventually detained in Louisiana. Her counsel, unaware of her location, filed a habeas petition in the District of Massachusetts, alleging her arrest was based on an op-ed she co-authored. The petition was transferred to the District of Vermont after it was revealed she had been in Vermont during transit.The District of Vermont set a schedule for a bail hearing and to resolve the constitutional claims in the habeas petition. The court ordered the government to transfer Öztürk from Louisiana to Vermont to aid in these proceedings. The government appealed this order, seeking an emergency stay of the transfer.The United States Court of Appeals for the Second Circuit reviewed the case. The court concluded that the government failed to justify a stay. It determined that the District of Vermont was the proper venue for the habeas petition since Öztürk was in Vermont when the petition was filed. The court also found that the government was unlikely to succeed on its arguments that jurisdiction-stripping provisions of the Immigration and Nationality Act deprived the district court of jurisdiction over Öztürk’s detention challenge. Additionally, the court held that the government did not demonstrate irreparable injury absent a stay and that the balance of equities favored Öztürk.The Second Circuit denied the government’s motion for a stay, denied the request for a writ of mandamus, and vacated the administrative stay. The court ordered the government to comply with the district court’s transfer order within one week. View "Öztürk v. Hyde" on Justia Law

Ms. Shela Linton participated in a sit-in protest at the Vermont statehouse on January 8, 2015, against the governor's perceived lack of support for universal healthcare. When the statehouse closed at 8 p.m., law enforcement warned the demonstrators to leave or face arrest. Linton and others remained, linking arms and singing. During her arrest, Sergeant Jacob Zorn used a "rear wristlock" pain compliance technique, causing Linton to cry out in pain and suffer permanent injuries to her left wrist and shoulder. Linton later alleged that she was diagnosed with PTSD, depression, and anxiety due to the incident.The United States District Court for the District of Vermont granted summary judgment in favor of Sergeant Zorn, concluding that he was entitled to qualified immunity. The court found that no clearly established law put Zorn on notice that his actions might violate Linton's Fourth Amendment rights. Linton appealed, arguing that the district court erred in its interpretation of relevant case law and failed to view the facts in the light most favorable to her.The United States Court of Appeals for the Second Circuit reviewed the case and disagreed with the district court's decision. The appellate court held that the case Amnesty America v. Town of West Hartford clearly established that the gratuitous use of pain compliance techniques on a passively resisting protestor constitutes excessive force. The court found that genuine issues of material fact existed regarding the degree of Linton's resistance and the appropriateness of Zorn's use of force. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings to resolve these factual disputes. View "Linton v. Zorn" on Justia Law

Neysha Cruz, on behalf of her son O.F., filed a lawsuit against the New York City Department of Education (DOE) under the Individuals with Disabilities Education Act (IDEA). Cruz rejected the DOE's education plan for O.F., who has multiple disabilities, and sought reimbursement for his private school tuition. Cruz argued that the DOE's placement of O.F. in a twelve-student classroom violated a New York regulation requiring students with highly intensive management needs to be placed in classes of six or fewer students. The DOE acknowledged the regulation but argued that another regulation allowing a maximum of twelve students for those with severe multiple disabilities also applied, giving them discretion in class size placement.An Impartial Hearing Officer (IHO) initially found that the DOE offered O.F. a Free Appropriate Public Education (FAPE) but that the recommended school could not implement the IEP due to scheduling issues. The IHO ordered partial reimbursement for private tuition. The State Review Officer (SRO) reversed the IHO's finding on the school's ability to implement the IEP and concluded that the DOE provided a FAPE, thus denying reimbursement.The United States District Court for the Southern District of New York upheld the SRO's decision, agreeing that the DOE could choose between the two class size regulations. Cruz appealed to the United States Court of Appeals for the Second Circuit.The Second Circuit found that the case hinged on interpreting New York's education regulations and certified the question to the New York Court of Appeals. The court sought clarification on whether the DOE must satisfy both class size regulations or if it can choose between them when both apply to a student. The Second Circuit retained jurisdiction pending the state court's response. View "Cruz v. Banks" on Justia Law

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

A pretrial detainee, Alexandra Grimaldi, died after attempting suicide during acute heroin withdrawal while in a County jail. Her mother, Nancy Lara-Grimaldi, filed a lawsuit seeking damages under 42 U.S.C. § 1983 and New York State law against the County of Putnam and various County employees, alleging deliberate indifference to Grimaldi's health and safety.The United States District Court for the Southern District of New York granted summary judgment in favor of the defendants, dismissing the § 1983 claims against correction employees Karen Jackson, Steven Napolitano, and Michelle Nigro, as well as a Monell claim against the County. The court concluded that no reasonable jury could find that these defendants knew or should have known that there was an excessive risk that Grimaldi would attempt suicide. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the dismissal of the § 1983 claims against Jackson and Napolitano, finding that the record did not support a finding of deliberate indifference on their part. However, the court vacated the dismissal of the § 1983 claim against Nigro, concluding that there was sufficient evidence for a reasonable jury to find that Nigro knew or should have known about Grimaldi's risk factors and failed to provide adequate supervision. The court also vacated the dismissal of the state-law claims against Nigro, Jackson, Napolitano, and the County, and remanded for further proceedings on those claims. View "Lara-Grimaldi v. County of Putnam" on Justia Law

On October 24, 2016, Syracuse Police Department officers entered Troy Alexander's home without a warrant after receiving a report of a sexual assault. They searched the home for 12.5 hours before obtaining a warrant, during which they also towed Alexander's cars. After obtaining the warrant, they found narcotics in Alexander's bedroom. Alexander was arrested and faced multiple charges, including burglary, narcotics, and sexual assault. He posted bail twice but was not immediately released. Eventually, all charges were dropped.Alexander filed a lawsuit alleging violations of his constitutional rights and state law by the City of Syracuse, County of Onondaga, and Detective Rory Gilhooley. He claimed the warrantless entry and prolonged seizure of his home violated his Fourth Amendment rights, that he was falsely arrested, maliciously prosecuted, and improperly detained after posting bail. The United States District Court for the Northern District of New York granted summary judgment to the defendants on all claims.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that Alexander's claims regarding the warrantless entry, search, and seizure of his home, as well as his false arrest and malicious prosecution claims related to the burglary charges, presented triable issues of fact. The court also found gaps in the evidentiary record regarding Alexander's state law claims of continued detention after posting bail, precluding summary judgment for the City and County on these claims. The court vacated and remanded the judgment on these claims but affirmed the judgment in all other respects. View "Alexander v. City of Syracuse" on Justia Law