Justia Civil Rights Opinion Summaries

The Second Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action alleging discrimination and retaliation against plaintiff, a former duty chaplain at New York Methodist Hospital. The court held that the district court did not err in applying the ministerial exception. In this case, the hospital, because of its history and continuing purpose, through its Department of Pastoral Care, is a "religious group," and since plaintiff's role within the Department of Pastoral Care was to provide religious care to the hospital's patients and religious care only, the ministerial exception doctrine should be applied. The court held that, once applied, the ministerial exception doctrine warranted dismissal of the suit. View "Penn v. New York Methodist Hospital" on Justia Law

Connecticut General Statute 52‐59b, which provides for long‐arm jurisdiction over certain out‐of‐state defendants except in defamation actions, does not violate plaintiff's First or Fourteenth Amendment rights. This case arose out of a news article published by Bloomberg News, reporting a lawsuit filed by plaintiff against his former employer, Palladyne International Asset Management, and others. The Second Circuit affirmed the district court's dismissal of plaintiff's defamation action as to the out-of-state defendants. In regard to allegedly defamatory statements made by the remaining defendants, the court affirmed the district court's dismissal of plaintiff's defamation claim based on the "as much as $500 million" statement, and reversed the district court's dismissal of the defamation claim based on the "repeatedly tried to extort" statement, pursuant to New York Civil Rights Law 74. View "Friedman v. Bloomberg L.P." on Justia Law

The Second Circuit reversed the district court's grant of summary judgment in favor of ACE on its claim that the decision not to renew its precious metals license violated procedural due process because it was made without adequate notice and opportunity to be heard. The court held that ACE was not entitled to summary judgment on this procedural due process challenge because Connecticut law did not afford it a constitutionally protected property interest in the renewal of its precious metals license. Therefore, the Town was entitled to summary judgment on this claim. The court remanded to the district court for it to enter judgment in favor of defendants on all claims. View "Ace Partners, LLC v. Town of East Hartford" on Justia Law

The Second Circuit reversed the district court's grant of summary judgment in favor of ACE on its claim that the decision not to renew its precious metals license violated procedural due process because it was made without adequate notice and opportunity to be heard. The court held that ACE was not entitled to summary judgment on this procedural due process challenge because Connecticut law did not afford it a constitutionally protected property interest in the renewal of its precious metals license. Therefore, the Town was entitled to summary judgment on this claim. The court remanded to the district court for it to enter judgment in favor of defendants on all claims. View "Ace Partners, LLC v. Town of East Hartford" on Justia Law

Sexual orientation discrimination constitutes a form of discrimination "because of . . . sex," in violation of Title VII of the Civil Rights Act. The en banc court held that sexual orientation discrimination was motivated, at least in part, by sex and was thus a subset of sex discrimination. The en banc court overturned Simonton v. Runyon, 232 F.3d 33, 35 (2d Cir. 2000), and Dawson v. Bumble & Bumble, 398 F.3d 211, 217–23 (2d Cir. 2005), to the extent they held otherwise. In this case, plaintiff filed suit against his former employer, Altitude Express, alleging that he was terminated from his position as a skydiving instructor based on his sexual orientation. After determining that it had jurisdiction, the en banc court vacated the district court's judgment as to the Title VII claim and held that plaintiff was entitled to bring a claim for discrimination based on sexual orientation. The court remanded for further proceedings and affirmed in all other respects. View "Zarda v. Altitude Express, Inc." on Justia Law

The provision of a New York City licensing scheme (Rule 5-23), under which an individual with a "premises license" for a handgun may remove the handgun from the designated premises only for specified purposes, did not violate the Second Amendment, the Commerce Clause, the fundamental right to travel, or the First Amendment. The Second Circuit applied intermediate scrutiny and held that the burdens imposed by the Rule did not substantially affect the exercise of core Second Amendment rights, and the Rule contributed to an important state interest in public safety substantial enough to easily justify the insignificant and indirect costs it imposed on Second Amendment interests. The court also held that the Rule did not violate the dormant Commerce Clause by hindering interstate commerce; the right to travel interstate where nothing in the Rule prevented plaintiffs from engaging in intrastate or interstate travel; or the First Amendment where plaintiffs failed to demonstrate how the ability to join a specific gun club, or the ability to transport their licensed firearms to a shooting club outside of New York City, qualified as expressive association. Therefore, the court affirmed the district court's denial of plaintiffs' motion for summary judgment and for a preliminary injunction. View "New York State Rifle & Pistol Assoc. v. City of New York" on Justia Law

Citizens United filed suit challenging the regulations promulgated by the Attorney General's office that required non-profit organizations to disclose their donors on a yearly basis. The Second Circuit affirmed the district court's dismissal of all claims, except the due process claim, for failure to state a claim. The court found that the mere requirement on a tax‐exempt organization to disclose its donor list to a state's authority charged with regulating non‐profits did not impermissibly chill speech or assembly rights. Furthermore, it did not operate as a prior restraint on non‐profits' solicitation of donations. Finally, the court reversed the dismissal of the due process claim for lack of ripeness and remanded so that the claim could be dismissed with prejudice for failure to state a valid claim. View "Citizens United v. Schneiderman" on Justia Law

The public access TV channels in Manhattan are public forums and MCAC's employees were sufficiently alleged to be state actors taking action barred by the First Amendment to prevent dismissal of the claims against MCAC and its employees, but not against the City. In this case, the Second Circuit held that public access channels, authorized by Congress to be "the video equivalent of the speaker's soapbox" and operating under the municipal authority given to MNN in this case, are public forums, and, in the circumstances of this case, MNN and its employees are subject to First Amendment restrictions. In regard to municipal liability, the court held that the complaint did not allege actions by the City that suffice to make it liable for plaintiffs' federal claims. Therefore, the court affirmed the district court's dismissal for failure to state a valid claim against the City, reversed as to MCAC and its employees, and remanded for further proceedings. View "Halleck v. Manhattan Community Access Corp." on Justia Law

The public access TV channels in Manhattan are public forums and MCAC's employees were sufficiently alleged to be state actors taking action barred by the First Amendment to prevent dismissal of the claims against MCAC and its employees, but not against the City. In this case, the Second Circuit held that public access channels, authorized by Congress to be "the video equivalent of the speaker's soapbox" and operating under the municipal authority given to MNN in this case, are public forums, and, in the circumstances of this case, MNN and its employees are subject to First Amendment restrictions. In regard to municipal liability, the court held that the complaint did not allege actions by the City that suffice to make it liable for plaintiffs' federal claims. Therefore, the court affirmed the district court's dismissal for failure to state a valid claim against the City, reversed as to MCAC and its employees, and remanded for further proceedings. View "Halleck v. Manhattan Community Access Corp." on Justia Law

Plaintiffs, employees of the Rensselaer County Jail, filed suit alleging violations of their right to privacy in health information under the Fourteenth Amendment and the Computer Fraud and Abuse Act (CFAA), 18 U.S.C. 1030. The district court dismissed all CFAA claims and granted summary judgment to defendants on the Fourteenth Amendment claims. The Second Circuit affirmed the dismissal of the CFAA claims, because plaintiffs failed to plead damages. The court vacated the district court's grant of summary judgment on the right to privacy in medical records claims, holding that even individuals with non-stigmatizing medical conditions have a right to privacy in their medical records, even if their interest in privacy might be less. The court remanded for further proceedings. View "Hancock v. County of Rensselaer" on Justia Law