Justia Civil Rights Opinion Summaries

Plaintiffs filed suit challenging the constitutionality of a collection of New York regulations and laws that together prevent for‐profit law firms from accepting capital investment from non‐lawyers. The district court dismissed the complaint for failure to allege the infringement of any cognizable constitutional right. On de novo review, the court concluded that neither as a for-profit partnership nor as a professional limited liability company do plaintiffs have the associational or petition rights that they claim. Even if the court were to assume, given the evolving nature of commercial speech protections, that they possess First Amendment interests, the regulations at issue here were adequately supported by state interests and have too little effect on the attorney‐client relationship to be viewed as imposing an unlawful burden on plaintiffs' constitutional interests. Accordingly, the court affirmed the judgment. View "Jacoby & Meyers v. The Presiding Justices of the First, Second, Third, and Fourth Departments" on Justia Law

Plaintiff, who suffers from a fear of needles (trypanophobia), filed suit against Rite Aid, alleging violation of his rights under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., after he was terminated from his position as a pharmacist because he could not comply with the company's policy that required pharmacists to administer immunization injections to customers. On appeal, Rite Aid challenged the district court's award of substantial damages to plaintiff after a jury trial. Both parties appealed the district court's post-trial order that dismissed plaintiff's failure-to-accommodate claim, granted a new trial unless plaintiff agreed to a remittitur (later accepted), substantially granted plaintiff's claims for interest, and denied defendant's motion for judgment as a matter of law (JMOL) on plaintiff's wrongful discharge and retaliation claims. The court explained that because performing immunization injections was an essential job requirement and plaintiff presented no evidence of a reasonable accommodation that would have allowed him to perform immunizations at the time of his dismissal, no juror could reasonably conclude that plaintiff was "qualified to perform the essential functions of his job, with or without reasonable accommodation." Therefore, the court reversed the post-trial denial of the JMOL on plaintiff's federal and state wrongful termination and retaliation claims, affirmed the dismissal of the failure-to-accommodate claim; and remanded for entry of a revised judgment in favor of Rite Aid. View "Stevens v. Rite Aid Corp." on Justia Law

Plaintiffs, 20 state pretrial detainees, filed suit under 42 U.S.C. 1983, alleging that the City and the supervisory officers of a pre-arraignment holding facility were deliberately indifferent to allegedly unconstitutional conditions of confinement at the holding facility. The district court granted summary judgment for defendants, denied plaintiffs' motion to reconsider; and denied a subsequent motion to reconsider the denial of the motion for reconsideration. The court affirmed the district court's judgment as to claims plaintiffs concede were properly dismissed. However, the court concluded that the district court misapplied this court's precedents in assessing whether plaintiffs had established an objectively serious deprivation. In Willey v. Kirkpatrick, the court recently reiterated that the proper lens through which to analyze allegedly unconstitutional unsanitary conditions of confinement is with reference to their severity and duration, not the detainee's resulting injury. Furthermore, the Supreme Court's decision in Kingsley v. Hendrickson dictates that deliberate indifference be measured objectively in due process cases. In this case, the district court did not analyze the implications of Kingsley in its opinion. Therefore, the court vacated in part and remanded for further proceedings. View "Darnell v. City of New York" on Justia Law

After the district court granted habeas relief to petitioner based on his Batson v. Kentucky challenge, respondent appealed. The district court held that the New York State Appellate Division, First Department, had unreasonably applied Batson and its progeny when it affirmed the state trial court's finding that petitioner failed to make a prima facie case showing that the prosecution used its peremptory challenges in a discriminatory manner. The court held that the district court incorrectly applied the standard for evaluating a state court's rulings set forth in the Anti‐Terrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. 2254(d); the Appellate Division's order affirming the trial court's denial of petitioner's Batson challenge was not an unreasonable application of clearly established Federal law, as determined by the Supreme Court of the United States; and thus the court vacated and remanded for further proceedings. View "Carmichael v. Chappius" on Justia Law

Plaintiff filed suit against MTBank, alleging violations of various state and federal statues by not allowing her to work remotely when she became pregnant. The magistrate judge ruled as a matter of law against plaintiff on a number of claims and the jury found for MTBank on the remaining claims. The court held that the district court abused its discretion in admitting evidence of the reinstatement offer because the offer was, as a matter of law, not unconditional; the district court erred in sua sponte disqualifying the attorneys for both parties, because the disqualification depended on the erroneous admission of evidence relating to the reinstatement offer; the jury instructions were not erroneous; and the court lacked jurisdiction over plaintiff's challenge to the district court's New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq., ruling. Accordingly, the court vacated in part in regard to the jury's verdict and the disqualification order, dismissed in part in regard to claims under the NYSHRL, and remanded for further proceedings. View "Jia Sheng v. MTBank Corp." on Justia Law

Plaintiff, an inmate confined in solitary confinement for the last twenty-two years, filed suit under 42 U.S.C. 1983 against current and former prison officials, alleging that his solitary confinement under Administrative Segregation violates his Fourteenth Amendment rights to procedural and substantive due process of law. The district court granted defendants' motion for summary judgment on plaintiff's procedural due process claim, and sua sponte awarded summary judgment on the substantive due process claim. The court concluded that the record presents triable issues of fact regarding plaintiff's procedural due process claim. In this case, although there exists on the record a substantial amount of evidence for a jury to conclude that officials where methodical in their approach to conducting periodic Administrative Segregation reviews, the court concluded that plaintiff has nonetheless produced evidence to raise a fair question about the meaningfulness, and thus procedural sufficiency, of his reviews. The court also concluded that the district court violated Federal Rule of Civil Procedure 56(f) in awarding summary judgment sua sponte on plaintiff's substantive due process claim. Accordingly, the court vacated and remanded for further proceedings. View "Proctor v. LeClaire" on Justia Law

After plaintiffs' convictions for rape and murder were vacated and they had served eighteen years in prison, plaintiff filed suit alleging, inter alia, malicious prosecution and denial of fair trial claims. Defendant, as executrix of the Estate of Joseph Volpe, appealed the district court's judgment for plaintiffs. Volpe was a homicide detective that investigated the rape and murder case. The court concluded that the district court did not abuse its discretion in determining that a new trial was warranted; the court rejected defendant's evidentiary challenges; the court rejected defendant's argument that a conflict of interest deprived Volpe of a fair trial; the district court correctly denied Volpe's request for a setoff; the court denied Volpe's motion for remittitur and concluded that the district court did not abuse its discretion in holding that the jury award did not shock the conscience or materially deviate from what would be reasonable compensation; and the court affirmed the district court's award of attorney fees. Because the court found no basis for reversal, the court affirmed the judgment. View "Restivo v. Hessemann" on Justia Law

Plaintiff was arrested for speeding wildly while drunk and high, and his Ferrari was impounded. After a neutral magistrate ordered that the vehicle be retained by the County, plaintiff filed a claim under 42 U.S.C. 1983, alleging that Suffolk County, in retaining his vehicle pendente lite, deprived him of due process. The district court agreed. The court concluded that, at a post‐seizure hearing to determine whether a vehicle should be returned to a title owner pendente lite pursuant to Suffolk County’s DWI Seizure Law, the Due Process Clause permits Suffolk County, after making out a prima facia case that retention is necessary to protect the County’s interests in the financial value of the vehicle and/or in protecting the public from continued unsafe and illegal driving, to shift the burden of going forward to the title owner to identify an alternative measure that would satisfy the County’s interests. Therefore, the court reversed the district court's grant of summary judgment to plaintiff and remanded with instructions to enter judgment in favor of the County. View "Ferrari v. County of Suffolk" on Justia Law

Jarquez Dancy and Jayvon Elting, two high school students, were stopped by Police Officer Gregg McGinley while they were walking on Main Street in Poughkeepsie, New York. A confrontation ensued that left Elting bruised, scraped, and swollen, and Dancy with a broken jaw. Elting and Dancy brought a civil rights action in federal district court alleging, inter alia, false arrest and use of excessive force. The district court entered judgment as a matter of law in favor of Elting on liability as to his claims against McGinley for false arrest and use of excessive force, and thereafter the jury awarded him $215,000, which the district court remitted to $196,500. The jury found in favor of Williams on Dancy's claim for false arrest, but was unable to reach a verdict on Dancy's excessive force claim. At a second trial, the jury found in favor of Williams on Dancy's excessive force claim. The district court denied Dancy's motion for a new trial. The court affirmed the judgment in favor of Elting and the amount of damages. However, the court vacated the judgment in favor of Williams and remanded for a new trial on Dancy's excessive force claim. In this case, the court concluded that there was a lack of clarity in the district court's instructions that improperly placed the burden on Dancy to prove intent, not only as to the seizure but as to the injury as well. The error was not harmless. View "Dancy v. McGinley" on Justia Law

Plaintiff prevailed in a jury trial on her claim of pregnancy discrimination. On appeal, plaintiff challenges the district court's decision denying plaintiff's request to provide a jury instruction on punitive damages under the New York City Human Rights Law (NYCHRL), N.Y.C. Admin. Code 8‐502. The court certified the following question to the New York Court of Appeals: What is the standard for finding a defendant liable for punitive damages under the New York City Human Rights Law, N.Y.C. Admin. Code 8‐502? View "Chauca v. Abraham" on Justia Law