Justia Civil Rights Opinion Summaries

After plaintiff was acquitted for disorderly conduct, resisting arrest, and harassment, he filed suit under 42 U.S.C. 1983, alleging claims of excessive force, false arrest, and malicious prosecution. Two officers moved for summary judgment based on qualified immunity, but the district court denied the motion.The Second Circuit dismissed the officers' appeal based on lack of appellate jurisdiction, holding that the district court did not err as a matter of law when it concluded that there is a genuine dispute of material fact as to whether one of the officers gave verbal commands to disperse prior to his arresting plaintiff and thus had probable cause for the arrest. The court also held that it is properly up to the jury, not a court of appeals, to determine whether to believe testimony supporting plaintiff's claim that there was no such command from the officer. View "Franco v. City of Syracuse" on Justia Law

After a jury returned a verdict in favor of plaintiff on her claim of intentional discrimination on the basis of race or national origin by her former employer, Rockefeller University, both plaintiff and the University appealed the final judgment of $250,000 in back pay and $200,000 in remitted emotional distress damages.The Second Circuit affirmed and rejected both parties' claims of error. The court held that, at bottom, any evidence in the trial record that could even arguably justify punitive damages is sparse, and the failure to instruct the jury on such damages accordingly did not cut to the core of plaintiff's case; plaintiff cannot demonstrate that the failure to instruct the jury on punitive damages constituted an error so serious and flagrant that it goes to the very integrity of the trial; the requirement of intentional discrimination was clearly expressed in the jury instructions and thus the court rejected the University's contention to the contrary; there was no prejudicial error in the formulation of the verdict form necessitating a new trial; the district court had the power to rescind its discharge order and, in the circumstances of this case, its decision to do so was a proper exercise of discretion; and the court rejected the University's challenge to the second verdict form. View "Emamian v. Rockefeller University" on Justia Law

Plaintiffs filed suit challenging the quarantine decisions of certain Connecticut state officials in response to an Ebola epidemic in West Africa. On appeal, plaintiffs challenged the district court's denial of their motion for class certification and dismissing their suit for lack of standing and based on qualified immunity. Plaintiffs primarily argue that they suffered actual or imminent injuries that create standing to seek prospective relief to avert allegedly unconstitutional future quarantines; clearly established law required that any quarantine imposed be medically necessary and comport with certain procedural safeguards; and their class is sufficiently numerous to merit certification.The Second Circuit affirmed and held that the district court properly deemed plaintiffs' injuries too speculative to support standing. In this case, plaintiffs failed to plead a sufficient likelihood that, under the revised policy, any of them faces a substantial risk of suffering a future injury. The court also held that the law surrounding quarantines was not clearly established such that a state official may be held liable for the actions taken here. The court did not reach the class certification issue because it is mooted by the court's conclusion as to standing. Accordingly, the court remanded with instructions to amend the judgment to clarify that the state law claims were dismissed without prejudice. View "Liberian Community Ass'n v. Lamont" on Justia Law

Plaintiffs appealed the district court's dismissal, under Federal Rule of Civil Procedure 12(b)(1) and 12(b)(6), of plaintiffs' amended complaint brought under 42 U.S.C. 1983 against various state officials, alleging that New York State's firearm licensing laws, N.Y. Penal Law 400.00, violate plaintiffs' rights under the Second and Fourteenth Amendments to the Constitution. The district court dismissed on grounds of mootness or lack of standing the claims of all but two plaintiffs, against all but two defendants, for failure to plead injury-in-fact or traceability of injury to other defendants; dismissed claims for money damages against the two remaining defendants on grounds of judicial and Eleventh Amendment immunity; dismissed individual-capacity claims against those defendants for injunctive relief as barred by 42 U.S.C. 1983; and dismissed the surviving claims on the grounds that the section 400.00 licensing criteria of "good moral character," "good cause," and "proper cause" are not unconstitutionally vague, and that the statutory scheme, while impacting Second Amendment rights, does not burden those rights substantially, closely relates to the State's interests in public safety, and thus survives intermediate scrutiny.The Second Circuit has been informed by the parties of events that have rendered the claims of certain plaintiffs moot and the court otherwise affirmed the rulings of the district court principally for the reasons stated by the district court. The court dismissed as to the Libertarian Party, which expressly disclaimed any request for appellate relief; dismissed as moot insofar as it pursues relief on behalf of plaintiff Rober, who is deceased with no successor or representative having been substituted for her; dismissed insofar as it pursues relief on behalf of plaintiff Kuzma, whose acquisition of a firearm license has made moot any claim that was pursued for him; and dismissed insofar as it pursues injunctive relief on behalf of plaintiff Cuthbert, whose relocation to Colorado has made him ineligible to apply for a New York concealed-carry permit. The court considered all of the other arguments properly before it and found them to be without merit. View "Libertarian Party of Erie County v. Cuomo" on Justia Law

Under 28 U.S.C. 2253, in a habeas corpus proceeding or a proceeding under section 2255 before a district judge, the final order shall be subject to review, on appeal, by the court of appeals for the circuit in which the proceeding is held.The Second Circuit determined, sua sponte, that it lacks jurisdiction to hear petitioner's appeal because a district court's order denying a certificate of appealability is not an appealable final order. In this case, petitioner moves for a certificate of appealability and for leave to file an oversized motion for a certificate of appealability, challenging the district court's order denying a certificate of appealability. The court dismissed the appeal for lack of jurisdiction and denied petitioner's motion as moot. View "Lasher v. United States" on Justia Law

Plaintiffs, a group of state and local governments and a group of non-profit organizations, filed separate suits under the Administrative Procedure Act, both challenging the validity of a DHS rule interpreting 8 U.S.C. 1182(a)(4), which renders inadmissible to the United States any non-citizen deemed likely to become a public charge. The district court entered orders in both cases to enjoin implementation of the rule nationwide.After determining that the States and the Organizations have Article III standing to challenge the rule and that they fall within the zone of interests of the public charge statute, the Second Circuit affirmed the district court's grant of a preliminary injunction enjoining the implementation of the rule. The court held that plaintiffs have demonstrated a likelihood of success on the merits of their claim that the rule is contrary to the Immigration and Nationality Act (INA). The court explained that, in reenacting the public charge ground in 1996, Congress endorsed the settled administrative and judicial interpretation of that ground as requiring a holistic examination of a non-citizen's self-sufficiency focused on ability to work and eschewing any idea that simply receiving welfare benefits made one a public charge. Furthermore, the rule makes receipt of a broad range of public benefits on even a short-term basis the very definition of "public charge." Therefore, that exceedingly broad definition is not in accordance with law.The court also held that plaintiffs have demonstrated a likelihood of success on the merits of their claim that the rule is arbitrary and capricious. In this case, DHS has not provided a reasoned explanation for its changed definition of "public charge" or the rule's expanded list of relevant benefits. The court further held that plaintiffs have established irreparable harm, and that the balance of the equities and the public interest tips in favor of granting the injunction. However, the court modified the scope of the injunctions to cover only the states of New York, Connecticut, and Vermont. View "New York v. United States Department of Homeland Security" on Justia Law

Plaintiff filed suit against Officers Miller and Clarke for using excessive force and failing to intervene during her arrest. Plaintiff's claims arose from an encounter with her ex-boyfriend and a group of teenagers.The Second Circuit affirmed the district court's denial of summary judgment as to Clarke where a reasonable jury could find that plaintiff was not physically resisting arrest before she was brought to the ground, and that Clarke used unreasonable force on an individual who was not resisting arrest and who was secured in such a manner that she posed no threat to public safety. Furthermore, it was clearly established at the time that it is impermissible to use significant force against a restrained arrestee who is not actively resisting. The court reversed the district court's denial of summary judgment as to Miller and held that, even assuming that Miller observed Clarke's use of force, there is no evidence in the record that would suggest he had a realistic opportunity to intervene that he then disregarded. Nor is there any clearly established law that would require Miller to abandon his crowd control duties and intervene to stop Clarke's use of force. Accordingly, the court remanded for further proceedings. View "Lennox v. Miller" on Justia Law

After expungement of his disciplinary record of theft, plaintiff filed suit against prison officials under 42 U.S.C. 1983, claiming violations of the Eighth Amendment and the Due Process Clause of the Fourteenth Amendment. The district court dismissed the Eighth Amendment claim with prejudice at the pleading stage and then awarded summary judgment to defendants on the due process claims.The Second Circuit held that plaintiff received adequate notice in regard to the charges against him. However, the court held that plaintiff's disciplinary conviction was not sufficiently supported by the evidence and the proceedings were tainted by procedural lapses that violated plaintiff's' due process rights. In this case, the defendant prison officers failed to consult readily available prison records to identify the officers with relevant information, limiting defendant's ability to defend against the charges. The court also held that the district court exceeded the permissible bounds of its discretion in dismissing plaintiff's Eighth Amendment claim without providing him a meaningful opportunity to seek leave to amend his complaint. Accordingly, the court affirmed in part, reversed in part, and remanded in part. View "Elder v. McCarthy" on Justia Law

New Hope Family Services, a voluntary and privately funded Christian ministry devoted to providing adoption services, filed suit alleging that OCFS violated its First and Fourteenth Amendment rights by advising New Hope that it either had to change its policy of not recommending adoptions by unmarried or same-sex couples or close its operation. The district court dismissed the complaint for failure to state a claim and denied New Hope's motion for a preliminary injunction as moot.The court held that the pleadings, viewed in the light most favorable to New Hope, state plausible claims under the Free Exercise and Free Speech Clauses of the Constitution because they (a) raise a plausible suspicion that OCFS acted with hostility towards New Hope because of the latter's religious beliefs, (b) plausibly allege that New Hope would be compelled to speak or associate in violation of those beliefs if the regulation in question were enforced, and (c) do not permit a court to conclude as a matter of law that New Hope's speech equates to government speech merely because New York State has authorized New Hope to provide adoption services.The court also held that this case is not analogous to Fulton v. City of Philadelphia, 922 F.3d 140 (3d Cir. 2019), cert. granted, 140 S. Ct. 1104 (2020), now pending before the Supreme Court. Furthermore, because New Hope's Free Exercise and Free Speech claims should not have been dismissed, the court held that its motion for a preliminary injunction was not moot and should not have been denied on that ground. Therefore, the court reversed the district court's judgment insofar as it dismissed New Hope's Free Exercise and Free Speech claims, and vacated the judgment insofar as it denied New Hope's motion for a preliminary injunction. The court remanded for further proceedings. View "New Hope Family Services, Inc. v. Poole" on Justia Law

Plaintiff, a state prisoner, filed suit against various corrections officials alleging that (1) New York DOCCS Rule 105.13 banning gang insignia or materials is unconstitutionally vague as applied to his photographs depicting family and friends wearing blue and making hand signs and (2) his placement in a special housing unit for six months following a prison disciplinary hearing determination that he had violated Rule 105.13 by possessing those photographs violated his due process rights.The Second Circuit affirmed the district court's grant of summary judgment to defendants, holding that Rule 105.13 provides adequate standards for prison guards to determine whether pictures of people wearing blue and intentionally making "C" hand signs are prohibited. In this case, no reasonable prison guard could have doubted that plaintiff's possession of photographs of people wearing blue and making "C" hand signs violated Rule 105.13 and, therefore, there was no danger that the Rule's enforcement would be arbitrary with regard to plaintiff's photographs. The court also held that plaintiff received a hearing that provided the minimal requirements of procedural due process. The court considered plaintiff's remaining arguments and found them to be without merit. View "Williams v. Korines" on Justia Law