Justia Civil Rights Opinion Summaries

Plaintiff filed suit against police officers, alleging that they used excessive force in violation of the Fourth Amendment. In this interlocutory appeal, the officers challenged the district court's order of a new trial. Insofar as the officers argued that the district court erred in finding the jury's verdict to be against the weight of the evidence, the Second Circuit dismissed the appeal for lack of jurisdiction, holding that the issues before the court turned on disputed facts. The court noted that, given the district court's conclusion that the jury's verdict was against the weight of the evidence, that verdict did not resolve the factual disputes. View "Bryant v. Meriden Police Department" on Justia Law

The First Amendment protects a prisoner's right not to serve as a prison informant or provide false information to prison officials. The Second Circuit affirmed the district court's grant of summary judgment to defendants in a First Amendment retaliation claim. Plaintiff alleged that his constitutional rights were violated when he was put on a restricted status known as Involuntary Protective Custody for over six months because he refused the demands of prison guards to act as a snitch, or to falsify his account of a minor incident in the commissary. The court held that defendants were entitled to qualified immunity because the court had not previously recognized the speech and speech‐related activity as protected by the First Amendment. View "Burns v. Martuscello" on Justia Law

Plaintiffs filed suit against senior federal law enforcement officials and 25 named and unnamed federal law enforcement officers, alleging that federal officers retaliated against plaintiffs when plaintiffs refused to serve as informants and put plaintiffs on the No Fly List in violation of the First Amendment and the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb et seq. The district court held that RFRA did not permit the recovery of money damages against federal officers sued in their individual capacities. The Second Circuit held, however, that RFRA permitted a plaintiff to recover money damages against federal officers sued in their individual capacities for violations of RFRA's substantive protections. Accordingly, the court reversed and remanded. View "Tanvir v. Tanzin" on Justia Law

Various entities and individuals associated with the New York City medallion taxicab industry filed suit under 42 U.S.C. 1983, alleging that defendants' regulatory scheme applicable to the ground transportation market in New York City violated their equal protection and due process rights and that they suffered a taking. The Second Circuit affirmed the district court's grant of defendants' motion to dismiss, holding that plaintiffs failed to state an equal protection violation because medallion taxicabs and for-hire vehicles (FHVs) were not similarly situated and thus the different regulations were supported by rational bases; plaintiffs failed to state a violation of procedural due process because the only effect on plaintiffs of defendants' permitting FHVs to operate in New York City and their promulgation of the Accessible Conversion Rules was some diminution in the value of a medallion, which was not a protected property interest; even assuming plaintiffs had suffered a deprivation of a cognizable property interest, they failed to plead facts to support their claim that they were denied a meaningful opportunity to be heard prior to the promulgation of the Rules; and plaintiffs' takings claim was unripe because they failed to seek compensation through the adequate state procedures that were available. View "Progressive Credit Union v. City of New York" on Justia Law

Plaintiff challenged the district court's dismissal of claims alleging that his employer, the City, retaliated against him after he filed a discrimination complaint, in violation of 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, et seq. The Second Circuit held that 42 U.S.C. 1983 provided the sole cause of action against state actors alleged to have violated section 1981. The court construed defendant's claims as section 1983 claims and held that he failed to allege a policy or custom of misconduct, as was necessary to assert liability against a municipality. The court also held that defendant could not avoid Title VII's exhaustion requirement by asserting retaliation for filing a claim of discrimination that he failed to pursue. However, in regard to claims that plaintiff properly exhausted, he has adequately alleged retaliation following both of his EEOC complaints. Therefore, the court vacated the dismissal of those claims. The court affirmed in all other respects. View "Duplan v. City of New York" on Justia Law

Plaintiff filed a putative class action challenging the City's policy of denying tenants the opportunity to open water accounts in their own name and shutting off water service to tenants when landlords fail to pay water bills. The Second Circuit held that the City's policy of denying tenants the opportunity to open water accounts satisfied the requirements of the Equal Protection Clause of the Fourteenth Amendment. The court held, however, that the City's water shutoff policy violated the Due Process Clause and the Equal Protection Clause. While the City has offered sufficient reasons for its policy of refusing to allow tenants to open their own water accounts and thus satisfied the rational basis test, the City's practice of terminating water service to tenants when a landlord failed to pay the water bill was not rationally related to a legitimate government interest. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Winston v. City of Syracuse" on Justia Law

Plaintiff filed a putative class action challenging the City's policy of denying tenants the opportunity to open water accounts in their own name and shutting off water service to tenants when landlords fail to pay water bills. The Second Circuit held that the City's policy of denying tenants the opportunity to open water accounts satisfied the requirements of the Equal Protection Clause of the Fourteenth Amendment. The court held, however, that the City's water shutoff policy violated the Due Process Clause and the Equal Protection Clause. While the City has offered sufficient reasons for its policy of refusing to allow tenants to open their own water accounts and thus satisfied the rational basis test, the City's practice of terminating water service to tenants when a landlord failed to pay the water bill was not rationally related to a legitimate government interest. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Winston v. City of Syracuse" on Justia Law

The Second Circuit vacated the district court's denial of plaintiff's request for a jury instruction concerning punitive damages for pregnancy discrimination claims arising under the New York City Human Rights Law (NYCHRL). The court certified to the New York Court of Appeals the question of the appropriate standard for determining whether a defendant may be liable for damages under the NYCHRL. The Court of Appeals resolved the certified question by holding that the standard for determining damages under the NYCHRL was whether the wrongdoer has engaged in discrimination with willful or wanton negligence, or recklessness, or a conscious disregard of the rights of others or conduct so reckless as to amount to such disregard. In doing so, the Court of Appeals expressly rejected the application of the federal standard for punitive damages. Therefore, after hearing from the Court of Appeals, the court held that the district court erred in applying the test for whether punitive damages are available under substantive federal law. View "Chauca v. Abraham" on Justia Law

Plaintiff filed suit against defendants, alleging claims under 42 U.S.C. 1983 for deliberate indifference and seeking to hold defendant Michael Allen, a police officer, responsible for excessive use of force. The Second Circuit affirmed the district court's grant of summary judgment for the City on plaintiff's municipal liability claims where the evidence proffered by plaintiff was insufficient to permit an inference of deliberate indifference. The court held that the cross-appeal by Allen was without merit given that as to an affirmative defense of qualified immunity, the burden was on the defendant to prove the necessary factual predicates by a preponderance of the evidence; that in order to avoid having the district court instruct the jury that he had that burden, Allen chose not to have submitted to the jury the fact questions as to which he now wants favorable answers presumed; and that the pertinent factual findings made by the district court were not inconsistent with the jury's answers to the questions that were posed. View "Outlaw v. Allen" on Justia Law

Plaintiff filed suit against defendants, alleging claims under 42 U.S.C. 1983 for deliberate indifference and seeking to hold defendant Michael Allen, a police officer, responsible for excessive use of force. The Second Circuit affirmed the district court's grant of summary judgment for the City on plaintiff's municipal liability claims where the evidence proffered by plaintiff was insufficient to permit an inference of deliberate indifference. The court held that the cross-appeal by Allen was without merit given that as to an affirmative defense of qualified immunity, the burden was on the defendant to prove the necessary factual predicates by a preponderance of the evidence; that in order to avoid having the district court instruct the jury that he had that burden, Allen chose not to have submitted to the jury the fact questions as to which he now wants favorable answers presumed; and that the pertinent factual findings made by the district court were not inconsistent with the jury's answers to the questions that were posed. View "Outlaw v. Allen" on Justia Law