Justia Civil Rights Opinion Summaries

Plaintiff filed suit under 42 U.S.C. 1983 and state law for false arrest, excessive force, assault, failure to intervene, and unlawful entry. The district court granted summary judgment as to the claims of unlawful entry and the other claims were tried to a jury. After a verdict in favor of plaintiff on the remaining counts, the district court granted judgment for defendants under Fed. R. Civ. Pro. 50(b). The court agreed with the district court's disposition of plaintiff’s false arrest claims. Because the trial record establishes that a reasonable law enforcement officer could have concluded that there existed probable cause to arrest plaintiff, defendants can claim the protection of qualified immunity. The court concluded that the force used in effecting plaintiff’s arrest was reasonable as a matter of law, and found no error in the district court’s dismissal of unnamed defendants or discovery rulings. Therefore, the court affirmed the judgment insofar as it disposed of plaintiff’s claims for false arrest, excessive force, and assault, dismissed unnamed defendants, and refused to permit further discovery. However, the district court erred in concluding, as a matter of law, that defendants had no realistic opportunity to intervene in an alleged assault on plaintiff by an unidentified police officer and that plaintiff lacked a legitimate expectation of privacy in his mother’s apartment. Accordingly, the court vacated the judgment in regard to the failure-to-intervene and unlawful-entry claims and remanded for further proceedings. View "Figueroa v. Mazza et al." on Justia Law

Defendants appealed the district court's denial of their motion for judgment as a matter of law (JMOL) under Federal Rule of Civil Procedure 50, or alternatively for a new trial under Rule 59, or relief from the judgment under Rule 60(b)(6) on plaintiff's New York State Human Rights Law (NYSHRL) claim. Plaintiff, diagnosed with cancer, cross-appealed the dismissal of her New York City Human Rights Law (NYCHRL) claim. Plaintiff and her husband cross-appealed the dismissal of their Consolidated Omnibus Budget Reconciliation Act (COBRA), 29 U.S.C. 116(a), claims. The court held that, because plaintiff did not request a reasonable accommodation prior to her termination, the district court erred in denying defendants’ Rule 50 motion. Therefore, the court reversed that decision and vacated the jury award on the NYSHRL claim. However, the court affirmed the district court's dismissal of plaintiff's NYCHRL claim for lack of subject matter jurisdiction and denial of the COBRA claims on the merits. View "Vangas v. Montefiore Med. Ctr." on Justia Law

Defendant, the former New York State Governor, launched the Sexually Violent Predator Initiative, which provided for the involuntary civil commitment at state psychiatric facilities of some ʺsexually violent predatorsʺ (SVPs) nearing the date of their release from incarceration or supervision. Plaintiffs, six individuals who were civilly committed to a psychiatric hospital, filed suit asserting claims under the Fourth Amendment, the substantive and procedural components of the Fourteenth Amendmentʹs Due Process Clause, the Fourteenth Amendmentʹs Equal Protection Clause, and several provisions of New York state law. The district court concluded that defendants were not entitled to qualified immunity as a matter of law, which the court affirmed on interlocutory appeal. Many of the claims were thereafter dismissed by the district court on judgments as a matter of law, while the remainder were tried to a jury. The jury found one defendant liable for procedural due‐process violations, and awarded each plaintiff one dollar in nominal damages against that defendant. On appeal, plaintiffs Warren and Brooks challenged the district courtʹs (1) jury instruction on personal involvement; (2) denial of judgment as a matter of law on procedural due‐process liability; (3) denial of judgment as a matter of law on plaintiffsʹ entitlement to actual, compensatory damages; (4) entry of judgment for the defendants on the plaintiffsʹ false‐imprisonment claims on the grounds that these claims were duplicative; and (5) limitations on depositions, and several other evidentiary decisions. The court concluded that plaintiffs' arguments lack merit and affirmed the judgment of the district court. View "Warren v. Pataki" on Justia Law

Plaintiff, an inmate at the Attica Correctional Facility, filed suit under 42 U.S.C. 1983, alleging that while he was incarcerated at Attica, defendant corrections officers Dennis Fleckenstein and Chester Kosmowski subjected him to cruel and unusual punishment by depriving him of meals and defendant Fleckenstein physically assaulted him in violation of his Eighth Amendment rights. At trial, the jury found that both defendants violated plaintiff's constitutional right to nutritionally adequate food and awarded him nominal and punitive damages. On appeal, defendants challenged the district court's admission of a prison monitoring report conducted by a private, nonprofit corporation. The court concluded that the report is hearsay that does not fall within the Business Records Exception nor the Public Records Exception. Furthermore, the report was inadmissible because it further contains hearsay in the form of statements from inmates complaining about abuse at Attica. Because admission of the report was not harmless error, the district court abused its discretion in admitting it. Accordingly, the court vacated and remanded for further proceedings. View "Abascal v. Fleckenstein" on Justia Law

Plaintiff, a corrections officer at the Ulster County Jail, filed suit against the County and its officials, alleging that the denial of her request for an accommodation under the County's light duty policy amounted to pregnancy discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., as amended by the Pregnancy Discrimination Act of 1978, 42 U.S.C. 2000e(k). The district court dismissed plaintiff's claim against the County and former Sheriff VanBlarcum. The district court granted defendants’ motion for judgment as a matter of law at the close of plaintiff’s direct case, reasoning that the policy could not be discriminatory because it was facially neutral with respect to pregnancy. While this appeal was pending, the Supreme Court decided Young v. United Parcel Service, Inc., which held that an employer’s facially neutral accommodation policy gives rise to an inference of pregnancy discrimination if it imposes a significant burden on pregnant employees that is not justified by the employer’s non‐discriminatory explanation. In this case, the court concluded that plaintiff has presented sufficient evidence to support a pregnancy discrimination claim under Young and therefore vacated the judgment in part and remanded with instructions to conduct a new trial. The court also vacated the post judgment orders and remanded for further proceedings. View "Legg v. Ulster Cnty." on Justia Law

Plaintiff filed suit against her former employer, alleging that defendant unlawfully retaliated against her for opposing an employment practice proscribed by Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq. The court concluded that the conduct plaintiff opposed - the amendment of internal procedures in a manner that, she believed, would permit political considerations to influence the evaluation of discrimination claims - is not a “practice made an unlawful employment practice” by Title VII. Nor could plaintiff reasonably have believed otherwise. Accordingly, the court affirmed the district court's dismissal of her claims. View "Cooper v. N.Y. State Dep’t of Labor" on Justia Law

Plaintiff appealed the district court's grant of qualified immunity to Defendant Police Officer Patterson. The district court dismissed plaintiff's claim against Patterson by reason of his having seized her for psychiatric evaluation based on her supposed dangerousness to her son. The court found that the record of evidence of what happened consists only of the terse notes of the CPS caseworkers, and those notes lack indicia of, or specific observations substantiating, plaintiff’s “dangerousness". Nor do they show that Patterson reasonably relied on communications from CPS caseworker Jodi Weitzman or others in making the seizure. Moreover, and notably, there is no statement by Patterson in the record. Therefore, without evidence regarding the grounds of Patterson's decision, the court is unable to determine whether his actions were contrary to clearly established law. Accordingly, the court vacated and remanded for further expansion of the record as to the basis on which the arrest was made, and for reevaluation of Patterson’s entitlement to qualified immunity on the basis of an expanded record. View "Johnson v. Patterson" on Justia Law

Garden City appealed from a final judgment finding it liable for violations of the Fair Housing Act, 42 U.S.C. 3601 et seq.; 42 U.S.C. 1981; 42 U.S.C. 1983; and the Equal Protection Clause. Plaintiffs cross-appealed from the 2012 grant of summary judgment by the same district court in favor of Nassau County. The court held that plaintiffs have Article III standing and plaintiffs' claims are also not moot; the district court did not commit clear error in finding that Garden City’s decision to abandon R‐M zoning in favor of R‐T zoning was made with discriminatory intent, and that defendants failed to demonstrate they would have made the same decision absent discriminatory considerations; the court affirmed the judgment insofar as it found plaintiffs had established liability under 42 U.S.C. 3604(a) of the FHA based on a theory of disparate treatment; the court held that 24 C.F.R. 100.500(c) abrogated the court's prior precedent as to the burden‐shifting framework of proving a disparate impact claim; the court vacated the judgment insofar as it found liability under a disparate impact theory, and remanded for further proceedings; the court held that the district court properly dismissed plaintiffs’ disparate treatment claims against Nassau County at the summary judgment stage because plaintiffs have not raised a genuine issue of material fact as to whether the County had legal responsibility for Garden City’s adoption of R‐T zoning; the court affirmed the dismissal of plaintiffs' disparate treatment claims against Nassau County at the summary judgment stage; and the court remanded with respect to plaintiffs' claims under Section 804(a) and Title VI relating to Nassau County’s “steering” of affordable housing. View "MHANY Mgmt., Inc. v. City of Nassau" on Justia Law

After plaintiff was terminated for taking time off work to care for her sons, plaintiff filed suit against the CIA and two of her supervisors under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(b)(4), alleging that she had been wrongfully denied leave, retaliated against for taking leave, and discriminated against on the basis of her association with a disabled individual. The district court granted summary judgment to defendants on all claims. The court concluded that a rational jury could find that Shaynan Garrioch, CIA's Director of Human Resources, exercised sufficient control over plaintiff's employment to be subject to liability under the FMLA and the court vacated the district court's dismissal of plaintiff's FMLA claims against her; plaintiff has presented sufficient evidence to present genuine disputes of material fact in regard to her interference and retaliation claims under the FMLA; but, in regard to plaintiff's ADA claim, she failed to present evidence that she was fired because her employer suspected distraction or concern for her son would cause her to perform her work inadequately. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Graziadio v. Culinary Inst. of America" on Justia Law

After plaintiff was terminated for taking time off work to care for her sons, plaintiff filed suit against the CIA and two of her supervisors under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(b)(4), alleging that she had been wrongfully denied leave, retaliated against for taking leave, and discriminated against on the basis of her association with a disabled individual. The district court granted summary judgment to defendants on all claims. The court concluded that a rational jury could find that Shaynan Garrioch, CIA's Director of Human Resources, exercised sufficient control over plaintiff's employment to be subject to liability under the FMLA and the court vacated the district court's dismissal of plaintiff's FMLA claims against her; plaintiff has presented sufficient evidence to present genuine disputes of material fact in regard to her interference and retaliation claims under the FMLA; but, in regard to plaintiff's ADA claim, she failed to present evidence that she was fired because her employer suspected distraction or concern for her son would cause her to perform her work inadequately. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Graziadio v. Culinary Inst. of America" on Justia Law