Justia Civil Rights Opinion Summaries

The Second Court clarified that, to establish a prima facie pay discrimination claim under Title VII, a plaintiff need not first establish an Equal Pay Act violation—that is, that she performed equal work but received unequal pay. Rather, all Title VII requires a plaintiff to prove is that her employer discriminated against her with respect to her compensation because of her sex. The court adopted the framework applicable to Sarbanes‐Oxley Act of 2002 whistleblower retaliation claims to Consumer Product Safety Improvement Act whistleblower retaliation claims.In this case, plaintiff filed suit alleging that defendants paid her less than they would have if she were a man, retaliated against her when she raised concerns about her disparate pay and possible Consumer Product Safety Act violations, and fired her because she was pregnant. The district court held that plaintiff failed to establish a prima facie case for each of her claims.The court held that there was sufficient evidence to support a prima facie case for plaintiff's Pregnancy Discrimination Act and Title VII claims, but insufficient evidence to support her Consumer Product Safety Improvement Act whistleblower retaliation claim. Accordingly, the court vacated in part and remanded for further proceedings. View "Lenzi v. Systemax, Inc." on Justia Law

The Second Circuit held that a landlord may be liable under the Fair Housing Act (FHA) for intentionally discriminating against a tenant who complains about a racially hostile housing environment that is created by and leads to the arrest and conviction of another tenant. In this case, the landlord allegedly refused to take any action to address what it knew to be a racially hostile housing environment created by one tenant targeting another, even though the landlord had acted against other tenants to redress prior, non‐race related issues. In holding that a landlord may be liable in those limited circumstances, the court adhered to the FHA's broad language and remedial scope. The court also held that post-acquisition claims that arise from intentional discrimination are cognizable under section 3604 of the FHA. Accordingly, the court vacated the district court's dismissal of plaintiff's claims under the FHA and analogous New York State law, as well as his claims under 42 U.S.C. 1981 and 82. The court remanded for further proceedings. View "Francis v. Kings Park Manor, Inc." on Justia Law

Plaintiff appealed the district court's denial of his Federal Rule Civil of Procedure 60(b) motion to reconsider termination of the Milburn consent decree, which provided injunctive relief to inmates at Green Haven Correctional Facility seeking access to adequate medical care.The Second Circuit reversed and held that plaintiff had standing to invoke Rule 60(b) to challenge the termination because he was sufficiently connected with the underlying litigation and his interests were strongly affected by the termination. The court also held that the termination of the consent decree violated Federal Rule of Civil Procedure 23(a)(4) and the Due Process Clause because the class was inadequately represented at the times relevant to the termination proceedings. Accordingly, the court remanded for further proceedings. View "Irvin v. Harris" on Justia Law

After the Authority implemented a reduction in force (RIF), plaintiffs filed suit against the Authority and others under 42 U.S.C. 1983 and New York law, alleging that the termination of union-represented employees violated the employees' First Amendment right to associate. At issue was whether State Employees Bargaining Agent Coalition v. Rowland, 718 F.3d 126, 134 (2d Cir. 2013), which held that union activity is protected by the First Amendment right to freedom of association and that heightened scrutiny applies to employment decisions that target an employee "based on union membership," extends to agency fee payors (AFPs), who are not union members, based solely on the fact that AFPs are represented by a union during collective bargaining.The Second Circuit held that the First Amendment protections apply to union members but do not extend to AFPs based on union representation alone. The court held that AFPs did not have a First Amendment right to freedom of association merely because they were represented by a union during collective bargaining. Accordingly, the court affirmed in part, vacated in part, and remanded for the district court to determine whether the layoffs of the thirteen AFPs were justified under rational basis review. View "Donohue v. Milan" on Justia Law

Plaintiffs, a group of current and former retail sales employees of Sterling Jewelers, filed suit alleging that they were paid less than their male counterparts, on account of their gender, in violation of Title VII of the Civil Rights Act of 1964 and the Equal Pay Act. After an arbitrator certified a class of Sterling Jewelers employees that included employees who did not affirmatively opt in to the arbitration proceeding, the district court held that the arbitrator exceeded her authority in purporting to bind those absent class members to class arbitration.The Second Circuit reversed, holding that the arbitrator was within her authority in purporting to bind the absent class members to class proceedings because, by signing the operative arbitration agreement, the absent class members, no less than the parties, bargained for the arbitrator's construction of their agreement with respect to class arbitrability. The court remanded to the district court to consider, in the first instance, the issue of whether the arbitrator exceeded her authority in certifying an opt-out class. View "Jock v. Sterling Jewelers Inc." on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against four state defendants, alleging that they violated his Eighth and Fourteenth Amendment rights by holding him in state custody for four months after the expiration of his federal sentence, where the state sentencing court had originally directed that plaintiff's state and federal sentences should run concurrently. The district court denied the state defendants' motion for summary judgment.The Second Circuit held that, under Mathews v. Eldridge, 424 U.S. 319 (1976), the state defendants violated the Due Process Clause by implementing plaintiff's sentence in the manner they did without providing adequate notice to the state sentencing court and the attorneys present at plaintiff's state sentencing. The court held, nonetheless, that the state defendants were entitled to qualified immunity from all of plaintiff's constitutional claims. In regard to the Fourteenth Amendment claim, the court held that there was no clearly established law considering whether prison officials implementing a state sentence violate the Constitution by failing to provide notice to the sentencing court and attorneys. Likewise, in regard to the Eighth Amendment claim, there was not clearly established right the state defendants violated in this case. Accordingly, the court reversed and remanded with instructions to grant the motion for summary judgment. View "Francis v. Fiacco" on Justia Law

Presidential immunity does not bar the enforcement of a state grand jury subpoena directing a third party to produce non‐privileged material, even when the subject matter under investigation pertains to the President.President Trump filed suit seeking declaratory and injunctive relief to prevent the District Attorney of New York County from enforcing a grand jury subpoena served on a third-party custodian of the President's financial records. The district court dismissed the complaint under Younger v. Harris, 401 U.S. 37 (1971), abstaining from exercising jurisdiction. In the alternative, the district court held that the President was not entitled to injunctive relief.The Second Circuit held that Younger abstention did not apply to the circumstances here, because the President raised novel and serious claims that were more appropriately adjudicated in federal court. The court held, however, that any presidential immunity from state criminal process did not extend to investigative steps like the grand jury subpoena in this case. Accordingly, the court affirmed as to the immunity question, vacated as to the Younger abstention issue, and remanded for further proceedings. View "Trump v. Vance" on Justia Law

The Second Circuit affirmed the district court's sua sponte dismissal of plaintiff's complaint, claiming that various individuals involved in his pending divorce and child custody proceedings, including his wife, their marriage counselor, and a family court judge, violated his constitutional rights and New York state law.The court held that the district court correctly determined that, at all relevant times, the family court judge was entitled to judicial immunity. Furthermore, even if the judge erred in extending the temporary protection order against plaintiff shortly after recusing herself, any such error fell far short of an act taken in the complete absence of all jurisdiction. The court also held that the domestic relations abstention doctrine articulated in American Airlines, Inc. v. Block, 905 F.2d 12 (2d Cir. 1990), applies in federal‐question cases. The court clarified that, although the domestic relations "exception" to subject matter jurisdiction recognized by the Supreme Court in Ankenbrandt v. Richards, 504 U.S. 689 (1992), did not apply in federal‐question cases, the domestic relations abstention doctrine articulated in American Airlines did. Therefore, the court affirmed the district court's dismissal of plaintiff's federal claims on abstention grounds. View "Deem v. DiMella-Deem" on Justia Law

Plaintiffs Atterbury and Hauschild filed suit alleging that they were improperly discharged as Court Security Officers (CSOs). The district court granted summary judgment in favor of the USMC.The Second Circuit held that a discharged public employee, like plaintiffs here, working for a federal government contractor has a property interest in continued employment. The court also held that plaintiffs' discharges did not comply with the requirements of procedural due process. In this case, although plaintiffs were informed of the initial misconduct allegations that gave rise to the relevant investigations, USMS provided no explanation of the reasons for its decisions that they be removed from the CSO program. Accordingly, the court reversed and remanded in Atterbury's case, and affirmed and remanded in Hauschild's case. View "Atterbury v. United States Marshals Service" on Justia Law

Plaintiff filed suit against the City and an officer in his individual capacity, alleging claims of excessive force against the officer and state law claims against the City for assault and battery and negligence. Plaintiff's claim stemmed from a handcuffing incident during her voluntary surrender to police custody in connection with a misdemeanor complaint of domestic stalking and harassment filed by her estranged sister.The Second Circuit held that plaintiff sufficiently established her constitutional claim for excessive force for purposes of surviving a motion for summary judgment. In this case, a reasonable jury could find that the officer's actions in handcuffing plaintiff were objectively unreasonable in light of, inter alia, the minor nature of plaintiff's crime, the circumstances of her arrest, and the fact that she posed no apparent risk of flight or physical threat to the officers or others. However, the court held that, at the time of plaintiff's arrest, the officer's actions did not violate clearly established constitutional law. Therefore, the district court correctly concluded that his actions were protected by qualified immunity and summary judgment was proper on that basis. Accordingly, the court affirmed the district court's judgment. View "Cugini v. City of New York" on Justia Law