Justia Civil Rights Opinion Summaries

Two New York residents applied for concealed carry firearm licenses under the state’s licensing laws. Their applications were reviewed by a county court judge acting as a statutory licensing officer, who denied both applications. The judge found that one applicant’s criminal arrest history and failure to disclose it demonstrated a lack of maturity and responsibility, while the other applicant’s criminal history, including a youthful-offender adjudication for robbery, similarly indicated he was not qualified for a license.After their applications were denied, the applicants filed a lawsuit in the United States District Court for the Northern District of New York. They sued the judge in both his individual and official capacities under 42 U.S.C. § 1983, alleging violations of their Second and Fourteenth Amendment rights. The district court dismissed the claims against the judge in his individual capacity, holding that absolute judicial immunity applied because the judge was acting in a judicial role. The court also dismissed the official-capacity claims for injunctive and declaratory relief, finding that Article III’s case-or-controversy requirement and § 1983’s limitations barred such claims against a judge acting in this capacity.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The Second Circuit held that judges deciding firearms license applications under New York law act in a judicial capacity and are therefore entitled to absolute immunity from individual-capacity suits for damages. The court further held that Article III’s case-or-controversy requirement bars claims for injunctive and declaratory relief against state court judges in their official capacity when they act as neutral adjudicators without a personal or institutional stake in the challenged law. The judgment of the district court was affirmed. View "Kellogg v. Nichols" on Justia Law

Brian Flores, a current NFL coach, brought a putative class action against the National Football League and several of its member clubs, including the Denver Broncos, New York Giants, and Houston Texans, alleging racial discrimination under federal, state, and local law. Flores’s claims stemmed from his interviews and employment experiences with these teams, during which he alleged discriminatory hiring practices. His employment contracts with various NFL teams incorporated the NFL Constitution, which contains a broad arbitration provision granting the NFL Commissioner authority to arbitrate disputes between coaches and member clubs.The United States District Court for the Southern District of New York reviewed the defendants’ motion to compel arbitration based on Flores’s employment agreements. The District Court granted the motion for claims against the Miami Dolphins, Arizona Cardinals, and Tennessee Titans, but denied it for Flores’s claims against the Broncos, Giants, Texans, and related claims against the NFL. The court found the NFL Constitution’s arbitration provision illusory and unenforceable under Massachusetts law, as it allowed unilateral modification by the NFL and lacked a signed agreement in one instance. The District Court also denied the defendants’ motion for reconsideration.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court’s orders. The Second Circuit held that the NFL Constitution’s arbitration provision, which vested unilateral substantive and procedural authority in the NFL Commissioner, did not qualify for protection under the Federal Arbitration Act and was unenforceable because it failed to guarantee Flores the ability to vindicate his statutory claims in an impartial arbitral forum. The court also affirmed the denial of the motion for reconsideration, concluding there was no abuse of discretion. View "Flores v. N.Y. Football Giants" on Justia Law

Several individuals with developmental disabilities, along with Disability Rights New York (DRNY), an advocacy organization, alleged that New York State agencies responsible for services to people with developmental disabilities caused them to remain in restrictive institutional settings for extended periods, despite being eligible for community-based residential placements. The individual plaintiffs claimed they waited from nine months to six years for such placements, resulting in physical and psychological harm. DRNY, as the state’s designated Protection and Advocacy System, joined the suit, asserting authority to represent the interests of individuals with disabilities under federal law.The United States District Court for the Southern District of New York first addressed the defendants’ motion to dismiss DRNY’s claims for lack of standing, agreeing that DRNY had not suffered an injury in fact and rejecting its argument that federal statutes conferred “congressionally authorized representational standing.” The district court also dismissed the individual plaintiffs’ claims as moot, based on pre-motion letters from the defendants indicating that all individual plaintiffs had since been moved out of institutional facilities. Additionally, the court denied a motion by other individuals seeking to intervene as plaintiffs, finding the motion untimely.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal of DRNY’s claims, holding that DRNY lacked standing because it had not suffered a concrete injury and that Congress could not override Article III’s standing requirements by statute. The Second Circuit also affirmed the denial of the motion to intervene, finding no abuse of discretion in the district court’s timeliness determination. However, the Second Circuit vacated the dismissal of the individual plaintiffs’ claims as moot, holding that the district court erred by dismissing those claims based solely on pre-motion letters without full briefing or a hearing. The case was remanded for further proceedings on the individual plaintiffs’ claims. View "A.H. v. N.Y. State Dep't of Health" on Justia Law

Angel Diaz, a prisoner in the custody of the New York State Department of Corrections and Community Supervision (DOCCS), filed a pro se petition for a writ of habeas corpus in the Southern District of New York. Diaz argued that due to the COVID-19 pandemic, the State could not provide him with constitutional conditions of confinement at any of its facilities, necessitating his release. He claimed that his high blood pressure and morbid obesity put him at severe risk of serious harm or death from COVID-19 and that DOCCS had no plan to protect medically vulnerable inmates like himself.The District Court referred the case to a magistrate judge, who recommended denying the petition on the grounds that Diaz's claim was not cognizable in habeas and should be brought under 42 U.S.C. § 1983 instead. The District Court adopted this recommendation, holding that Diaz's complaints about the conditions of his confinement did not challenge the validity or duration of his confinement. Diaz's request for a certificate of appealability was initially denied by the District Court but later granted by the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit reviewed the case and held that Diaz's claim was indeed cognizable under habeas corpus because he alleged violations of the Constitution that would require his release from all available facilities. However, the court found that Diaz failed to provide sufficient factual support to make his claim plausible. As a result, the Second Circuit affirmed the District Court's decision to dismiss the petition. View "Diaz v. Kopp" on Justia Law

Samantha Long, a former Clerk of the Town Justice Court for the Town of New Lebanon, filed a lawsuit against the Town of New Lebanon and Jessica Byrne, a former Town Justice. Long alleged that she was unlawfully terminated in retaliation for cooperating with an investigation by the New York State Commission on Judicial Conduct into Byrne’s suspected judicial misconduct. Long claimed that she provided specific case files to the Commission and refused to discuss the investigation with Byrne, which led to her termination. She argued that her termination violated her First Amendment rights and her rights under New York State Civil Service Law § 75-b.The United States District Court for the Northern District of New York dismissed Long’s claims. The court concluded that Long’s actions were not protected by the First Amendment because they were part of her official duties as Court Clerk and did not constitute protected citizen speech. Consequently, the court declined to exercise supplemental jurisdiction over Long’s Section 75-b claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court’s judgment and remanded the case for further proceedings. The appellate court held that Long’s complaint adequately alleged that she acted as a private citizen, not pursuant to her work responsibilities, when she cooperated with the Commission’s investigation and refused to discuss it with Byrne. The court emphasized that Long’s refusal to discuss the investigation with Byrne was not within the scope of her job duties and that her cooperation with the Commission was motivated by a sense of civic duty rather than employment-related responsibilities. The court also vacated the district court’s dismissal of Long’s state-law claim under Section 75-b, as the legal premise for the dismissal was defeated by the reinstatement of her First Amendment claim. View "Long v. Byrne" on Justia Law

In 2014, Tyrone Walker, who had been in solitary confinement for punitive reasons since 2000, was placed in solitary confinement as a preventative measure by prison officials, based on a determination that he posed a threat to prison security. The officials were constitutionally obligated to conduct regular, meaningful reviews of Walker’s solitary confinement. Walker argued that the reviews he received were not constitutionally meaningful, as they did not adequately assess his current threat level or consider his behavior over time.The United States District Court for the Northern District of New York granted summary judgment to the defendants, ruling that Walker demonstrated no genuine issues of material fact regarding the constitutional meaningfulness of his reviews. The court also decided that all defendants were entitled to qualified immunity because no clearly established right of Walker’s had been violated during the review process.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that a reasonable jury could find that the reviews Walker received during his continued solitary confinement were not constitutionally meaningful. The court noted that the reviews were repetitive and rote, failed to consider Walker’s positive behavior, and often used circular logic to justify his continued confinement. Additionally, the court found that the delays in completing and providing the reviews to Walker raised genuine issues of material fact regarding the meaningfulness of the process.The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings, emphasizing that the focus was on the procedural due process rights of Walker, not the substantive outcome of his confinement. The court also determined that it was premature to grant qualified immunity to the defendants at this stage. View "Walker v. Bellnier" on Justia Law

Plaintiffs, thirty survivors of childhood sexual abuse, sought damages for negligence from the Holy See under a vicarious liability theory. They alleged that the Holy See promulgated a mandatory policy of secrecy that governed how its dioceses and bishops handled reports of sexual abuse by clerics. Plaintiffs claimed that bishops in New York failed to warn children and parents of the dangers posed by the accused clerics and failed to report suspected abuse to law enforcement, thus emboldening abusers and exposing children to harm.The District Court granted the Holy See’s motion to dismiss for lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The court concluded that the discretionary function exclusion from the FSIA’s tortious activity exception barred Plaintiffs’ claims. The court found that the bishops’ conduct was discretionary and susceptible to policy analysis, thus falling within the discretionary function exclusion.The United States Court of Appeals for the Second Circuit reviewed the case de novo and affirmed the District Court’s judgment. The appellate court agreed that the discretionary function exclusion applied, precluding federal courts from exercising jurisdiction over the claims against the Holy See. The court held that the bishops’ challenged conduct involved discretionary acts and that Plaintiffs failed to allege that the bishops’ conduct violated a mandatory policy. Additionally, the court found that the bishops’ conduct was susceptible to policy analysis, satisfying the second prong of the Berkovitz/Gaubert test. Therefore, the discretionary function exclusion barred the exercise of jurisdiction over Plaintiffs’ claims against the Holy See. View "Blecher v. Holy See" on Justia Law

A bus driver, Wendy Alberty, was involved in an incident where she locked a passenger in the luggage compartment of a bus during a layover. The passenger called the police from inside the compartment, leading to Alberty's arrest for reckless endangerment and breach of the peace, with an additional charge of unlawful restraint added later. All charges were eventually dropped, and Alberty sued three police officers for false arrest, malicious prosecution, and retaliatory prosecution, claiming lack of probable cause.The United States District Court for the District of Connecticut granted summary judgment in favor of the defendants, holding that the officers had probable cause to arrest Alberty and arguable probable cause to prosecute her. Alberty appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that the officers had probable cause to arrest Alberty based on the evidence available at the time, including the passenger's 911 call, her identification of Alberty, and statements from another bus driver about company policy. The court also found that the officers had probable cause to prosecute Alberty for all charges, despite a video suggesting the incident might have been accidental. The court held that the video and the opinion of a trooper who viewed it did not dissipate probable cause. Consequently, the court affirmed the dismissal of Alberty's claims for false arrest, malicious prosecution, and retaliatory prosecution. View "Alberty v. Hunter" on Justia Law

The case involves the National Rifle Association of America (NRA) suing Maria T. Vullo, the former Superintendent of the New York State Department of Financial Services (DFS), alleging that Vullo violated its First Amendment rights. The NRA claimed that Vullo engaged in coercive and retaliatory actions against the NRA by pressuring financial institutions and insurers to sever ties with the NRA, thereby infringing on its free speech and equal protection rights. Vullo argued that she was entitled to qualified immunity.The United States District Court for the Northern District of New York denied Vullo's motion to dismiss the NRA's First Amendment claims, finding that the NRA had sufficiently stated a claim and that Vullo was not entitled to qualified immunity at that stage. Vullo appealed the decision.The United States Court of Appeals for the Second Circuit initially reversed the district court's decision, holding that the NRA failed to state a First Amendment claim and that Vullo was entitled to qualified immunity. The NRA then petitioned the Supreme Court, which granted certiorari to address whether the NRA had stated a plausible First Amendment claim. The Supreme Court concluded that the NRA had plausibly alleged a First Amendment violation and remanded the case to the Second Circuit to reconsider the issue of qualified immunity.Upon reconsideration, the Second Circuit concluded that Vullo was entitled to qualified immunity. The court reasoned that, although the general principle that a government official cannot coerce a private party to suppress disfavored speech was well established, it was not clearly established that Vullo's conduct—regulatory actions directed at the nonexpressive conduct of third parties—constituted coercion or retaliation in violation of the First Amendment. Therefore, the court reversed the district court's denial of qualified immunity and remanded the case for the district court to enter judgment dismissing the remaining claims against Vullo. View "Nat'l Rifle Ass'n of Am. v. Vullo" on Justia Law

Plaintiff Jere Eaton sued the City of Stamford and police officer Steven Estabrook, alleging that Estabrook used excessive force during a protest on August 8, 2020. Eaton claimed that Estabrook lifted her by her bra strap, drove her backward several feet, and dropped her on the ground without warning, violating her Fourteenth Amendment rights and committing assault and battery under Connecticut state law. Estabrook and the City of Stamford moved for summary judgment on the grounds of qualified immunity and state governmental immunity.The United States District Court for the District of Connecticut granted summary judgment in favor of the defendants. The court found that while there were genuine disputes of material fact regarding whether Estabrook used excessive force, Estabrook was entitled to qualified immunity because it was not clearly established at the time that his actions were unconstitutional. The court also granted summary judgment on Eaton’s state law claims, concluding that Estabrook was entitled to state governmental immunity.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that there were genuine disputes of material fact regarding the use of excessive force. However, the appellate court concluded that Estabrook was not entitled to qualified immunity at this stage because the same factual disputes also affected whether his actions were clearly established as unconstitutional at the time. The court affirmed the district court’s judgment in part, vacated it in part, and remanded the case for further proceedings. The appellate court upheld the district court’s decision regarding state governmental immunity for the state law claims. View "Eaton v. Estabrook" on Justia Law