Justia Civil Rights Opinion Summaries

Defendants, federal prison officials, appealed a district court’s judgment awarding former prisoner $20,000 for mental and emotional injury requesting damages pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), for his imprisonment in overcrowded conditions that posed a substantial risk of serious damage to his health or safety, to which Defendants were deliberately indifferent, in violation of his rights under the Eighth Amendment to the Constitution.The Second Circuit reversed the judgment and remanded for dismissal of Plaintiff’s complaint. The court held first that the PLRA provision in 42 U.S.C. Section 1997e(e) precludes a prisoner's recovery of compensatory damages for mental or emotional injury resulting from his conditions of confinement absent a showing of physical injury. Next, Section 1997e(e) makes physical injury an element of such a claim for mental or emotional injury and is not an affirmative defense that would be subject to waiver if not presented in Defendant's answer. In light of Section 1997e(e), the jury's finding that Plaintiff failed to prove that the prison conditions of which he complained caused him physical injury precluded an award to him of compensatory damages for such mental or emotional injury as the jury found he suffered based on the conditions it found existed.Moreover, even if the jury's findings of fact warranted a conclusion that Plaintiff’s Eighth Amendment rights were violated by deliberate indifference to cruel and unusual psychological punishment caused by overcrowding, Defendants are entitled to qualified immunity from such an award. View "Walker v. Schult" on Justia Law

Plaintiff appealed from a district court’s order awarding him attorney’s fees under 42 U.S.C. Section 1988 in an amount substantially less than he sought. After Plaintiff prevailed against the City of New York on the merits of his due process claim under 42 U.S.C. Section 1983, the district court, adopting the report and recommendation of the magistrate judge, lowered the attorney’s claimed hourly rate, excluded time spent on a related concurrent administrative proceeding, struck certain billing entries and imposed a 40% across-the-board reduction to the fee request.   Plaintiff challenged primarily the across-the-board reduction and the exclusion of time-related to the administrative proceeding. The Second Circuit vacated the district court’s order, explaining that while it identified no error in the district court’s decision to exclude all hours related to that proceeding, the court found that the 40% blanket reduction was not justified on the record. The court explained that it agrees with Plaintiff that the 40% overall reduction applied by the district court was not justified: the district court was able to (and in fact did) examine the block-billed entries for reasonableness, and Plaintiff’s counsel obtained a strongly favorable result for him overall, prevailing on claims that rested on the same core set of facts as did the claims that the court dismissed. However, the court identified no error in the district court’s decision to exclude from the fee calculation the hours that Plaintiff’s counsel devoted to defending him in the OATH proceeding because Plaintiff has not shown that this work was necessary to the result achieved in the federal court. View "Raja v. Burns" on Justia Law

Defendant was indicted for knowingly producing child pornography in violation of federal law. He moved to suppress evidence gathered from his electronic devices, arguing that the government’s search warrants lacked probable cause and therefore violated his Fourth Amendment rights. The district court denied the motion. Defendant then pleaded guilty but reserved the right to appeal the district court’s decision on his motion to suppress.   The Second Circuit affirmed the district court’s judgment explained that it disagrees with the district court that Defendant’s prior guilty plea to an earlier charge in Tennessee state court precludes him from challenging the search warrants in this case. But the court agreed that even assuming arguendo that the warrants are defective, the good-faith exception to the exclusionary rule applies.   The court explained that there was at least arguable probable cause for the Tennessee Warrants, therefore, the Detective acted based on an “‘objectively reasonable good-faith belief’ that [his] conduct [was] lawful.” The court further wrote that the affidavits at issue here are not so devoid of factual support because they detail allegations from State Victim 1’s mother that support the common-sense inference that her daughter told her that Defendant took nude photographs of her. View "United States v. Jones" on Justia Law

Plaintiffs are several parents suing on behalf of themselves and their children, whose requests for medical exemptions from the school immunization requirements were largely denied. They brought this action below against Defendants, the New York State Department of Health (the "Health Department"), Health Department officials, local school districts, and local school district officials (collectively, "Defendants"), alleging that the new regulations and the enforcement thereof violated their rights under the Due Process Clause of the Fourteenth Amendment and Section 504 of the Rehabilitation Act, 29 U.S.C. Section 794 (the "Rehabilitation Act"). The district court granted Defendants' motions to dismiss for failure to state a claim.   The Second Circuit affirmed the district court’s judgment. The court first concluded, as a procedural matter, that the district court properly applied the motion to dismiss standards. The court then concluded, as a substantive matter, that neither the new regulations nor the enforcement thereof violated the Due Process Clause or the Rehabilitation Act. The court explained that the new regulations do not implicate a fundamental right and that therefore strict scrutiny does not apply. The court further found that there is a reasonable relationship between the delegation of authority to school districts to review and approve medical exemption requests and protecting communities from serious diseases. Finally, the court concluded that Plaintiffs fail to plausibly allege that they were excluded from school "solely by reason of" their disabilities. View "Goe v. Zucker" on Justia Law

After a three-and-a-half-year delay, a jury convicted Appellant of conspiring to launder the proceeds generated by a network of Brooklyn medical clinics. Appellant appealed his conviction and sentence. He argued that the district court erred when it denied his motions to dismiss based on violations of the Speedy Trial Act, 18 U.S.C. Section 3161 et seq. Specifically, Appellant claimed that the district court improperly excluded time based on the complexity of the case without determining, on the record, why the case was complex or that such exclusions outweighed the best interest of the public and the defendant in a speedy trial. He contended that the excessive pre-trial delay, to which he objected, arose not from the supposed complexity of the prosecution but rather because the Government delayed production of certain documents possessed by state and federal agencies that had participated in the joint investigation and prosecution of Appellant.   The Second Circuit reversed the district court’s judgment of conviction, vacated Appellant’s conviction and sentence, and remanded to the district court. The court held that the district court’s exclusion of time during at least two long periods of delay was insufficient under the Speedy Trial Act.   The court explained that the Speedy Trial Act was designed to enforce the Sixth Amendment’s guarantee that the accused shall enjoy the right to a speedy trial. Here, the district court failed in this responsibility. It neither held the Government accountable for its discovery obligations nor appropriately considered the causes and implications of the extraordinary delays introduced by the Government’s dilatory conduct of discovery. View "United States v. Pikus" on Justia Law

Plaintiffs are practicing Muslims who believe that they are required under the precepts of their religion to perform five daily congregational prayers with as many other Muslims as are available and wish to participate. Plaintiffs alleged that while they were incarcerated at the Federal Correctional Institution in Danbury, Connecticut ("FCI Danbury"), wardens enforced a policy that restricted prayer in groups of more than two to the prison's chapel.   Plaintiffs filed suit against defendant prison officials seeking injunctive relief and damages on the grounds that FCI Danbury's communal prayer policy violated the Religious Freedom Restoration Act ("RFRA") and the Free Exercise Clause of the First Amendment to the United States Constitution.   The district court granted Defendants' motion to dismiss Plaintiffs' Second Amended Complaint (“SAC”) in large part, but declined to dismiss Plaintiffs' RFRA claims for damages against Defendants in their individual capacities, holding that qualified immunity was not available to the wardens at the motion-to-dismiss stage.   The Second Circuit affirmed the district court’s ruling, concluding that the wardens are not entitled to qualified immunity at this stage of the proceedings because the pleadings do not establish that their enforcement of the policy against Plaintiffs was in service of a compelling interest, and it was clearly established at the time of the violation that substantially burdening an inmate's religious exercise without justification violates RFRA. The court explained that a reasonable officer should have known, based on clearly established law, that denying a Muslim inmate the ability to engage in group prayer without any justification or compelling interest, as alleged in the SAC, violates RFRA. View "Sabir v. Williams" on Justia Law

Following a disturbance at a hospital, two New York City police officers arrested Plaintiff and transported her to another hospital for a psychiatric evaluation. Plaintiff asserted false arrest claims, alleging that the police officers lacked probable cause to arrest her for a mental health examination. The district court granted Defendants’ motion for summary judgment, holding that because the police officers had probable cause to arrest Plaintiff for a misdemeanor trespass, her false arrest claim was precluded. The district court did not reach the issue of the existence of probable cause for a mental health arrest. The district court also held, in the alternative, that the officers were protected by qualified immunity because they had arguable probable cause to make a mental health arrest.   The Second Circuit affirmed, concluding that while the district court erred in its probable cause analysis, the officers were protected by qualified immunity. The court explained that even where actual probable cause does not exist, police officers may be entitled to qualified immunity from a Section 1983 false arrest claim if their actions did not violate "clearly established" rights or if "arguable probable cause" existed at the time of the arrest.   Here, the parties disagree as to whether the officers had probable cause to arrest her for an emergency mental health evaluation. The court held that the existence of probable cause to arrest an individual for a criminal violation does not preclude a false arrest claim based on a wrongful arrest for a mental health evaluation. However, nonetheless, the officers here are protected by qualified immunity. View "Guan v. City of New York" on Justia Law

Plaintiff worked as a flight attendant for Delta Air Lines. She alleged that, while working on an airplane, she heard a passenger refer to her using a racist remark and reported the passenger’s remark to the pilot. The pilot responded by demanding that Plaintiff “step out on the jet bridge with the passenger,” and when she refused the pilot had her removed from the plane. Plaintiff reported the pilot’s conduct to her supervisor, and within two months of these events Plaintiff alleged she was subjected to random drug testing, wrongfully suspended, and ultimately fired. She filed a complaint in state court, alleging retaliation and vicarious liability under the New York City Human Rights Law. (“NYCHRL”) Delta removed the case to federal district court and moved to dismiss for failure to state a claim. The district court granted the motion, holding that Leroy failed adequately to allege that Delta had discriminated against her and that she therefore failed to allege retaliation for a protected activity under the NYCHRL.   The Second Circuit affirmed the district court’s ruling dismissing Plaintiff’s claims finding that her complaint did not allege facts adequate to support a good-faith, reasonable belief that Delta engaged in discrimination against her. The court explained that the NYCHRL prohibits retaliation for “opposing [the] employer’s discrimination.” To succeed on a retaliation claim, the plaintiff must at least have a good-faith, reasonable belief that she was opposing an unlawful employment practice. On the facts as alleged, Plaintiff could not have reasonably and in good faith believed that the passenger’s comment or the pilot’s conduct was an unlawful employment practice. View "Leroy v. Delta Air Lines, Inc." on Justia Law

Plaintiff appealed from the district court’s ruling granting summary judgment on all claims to Defendants-Appellees Chautauqua County (“the County”) and Correction Officers (“the Officers”) in this civil rights suit concerning the County’s policy of handcuffing inmates in an allegedly painful manner and the Officers’ use of force in extracting Plaintiff from his cell at the Chautauqua County Jail (“the Jail”).   The Second Circuit held that the district court did not err in granting summary judgment on exhaustion grounds with regard to Plaintiff’s claims against the Officers, but that it did err in doing so with regard to his claim against the County. The court explained that that the district court was correct that Plaintiff failed to present sufficient evidence to create a genuine dispute of material fact as to whether he had submitted a timely grievance related to his claims against the Officers. The district court erred, however, in holding that the Chautauqua County Jail’s grievance policy applied to his separate claim against the County. By its plain terms, the grievance procedures did not apply to matters outside the jail captain’s control, such as the County handcuffing policy that Plaintiff challenges, and thus there were no administrative remedies for Plaintiff to exhaust with respect to that claim. View "Saeli v. Chautauqua County" on Justia Law

A former faculty member appealed the district court’s judgment dismissing (A) claims against the university principally for violation of his right to due process, and for gender and national origin discrimination in violation of, respectively, Title IX of the Education Amendments of 1972 and Title VI of the Civil Rights Act of 1964; and (B) claims that documents issued by the United States Department of Education violated the Administrative Procedure Act and the  Spending Clause of the Constitution. The district court granted the university's motion for judgment on the pleadings finding that Title IX does not authorize a private right of action for discrimination in employment and that the complaint failed to state a claim for national-origin discrimination under Title VI. The court granted the United States Defendants' motion to dismiss the claims.   The Second Circuit vacated the judgment in part finding merit only in Plaintiff’s contention that Title IX allows a private right of action for a university's intentional gender-based discrimination against a faculty member. The court found that the complaint contained sufficient factual assertions to permit a plausible inference that Plaintiff was disciplined following irregular investigative procedures in circumstances permitting a plausible inference of bias on the basis of gender in violation of Title IX. Plaintiff’s Title VI claim, viewed within the same analytical framework as that applicable to his Title IX claim, lacks sufficient factual assertions to permit a plausible inference that Plaintiff was disciplined in whole or in part on the basis of his national origin in violation of Title VI. View "Vengalattore v. Cornell University" on Justia Law