2nd Cir.

United States Court of Appeals for the Second Circuit

Every decision we've summarized from United States Court of Appeals for the Second Circuit.

Jan 23 2025
22-1854 Panel Decision

UNITED STATES OF AMERICA EX REL. RALPH BILLINGTON, MICHAEL ACEVES, AND SHARON DORMAN v. HCL TECHNOLOGIES LTD. AND HCL AMERICA, INC

The Second Circuit affirmed the dismissal of a qui tam action alleging that HCL Technologies violated the False Claims Act by using cheaper visas and underpaying foreign workers. The court held that the relators failed to plausibly allege a reverse FCA violation because no established legal obligation existed to pay higher taxes or visa fees that the defendant never actually incurred.

Civil Labor
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Jan 13 2025
21-2949 Panel Decision

Capitol Records, LLC v. Vimeo, Inc.

The Second Circuit affirmed summary judgment for Vimeo, holding that the platform retained DMCA safe harbor protection because plaintiffs failed to prove Vimeo had specific knowledge of infringement or exercised substantial control over user content. The court clarified that general monitoring duties and financial benefits from user subscriptions do not constitute the right and ability to control infringing activity.

Civil Intellectual Property Summary Judgment
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Jan 13 2025
22-2884 Panel Decision

Mallet v. New York State Department of Corrections and Community Supervision

The Second Circuit reversed the dismissal of an inmate's Eighth Amendment claim, holding that the statute of limitations did not begin to run until he reasonably suspected he had prostate cancer, not when he was released from prison. The court remanded the case for further proceedings on the claims against two prison doctors while dismissing the claims against a third provider and state officials.

Civil Rights - Section 1983 Criminal Qualified Immunity Statute of Limitations
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Jan 13 2025
21-2974 Panel Decision

Capitol Records, LLC v. Vimeo, Inc.

The Second Circuit affirmed summary judgment for Vimeo, holding that the video platform retained DMCA safe harbor protection despite employee interactions with infringing user content. The court ruled that Vimeo lacked the specific knowledge required to lose immunity and did not exercise the substantial control necessary to forfeit its statutory defenses.

Civil Intellectual Property Summary Judgment
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Jan 13 2025
22-1227 Panel Decision

Pearson v. Gesner

The Second Circuit affirmed the dismissal of a prisoner's medical neglect claims but vacated the dismissal of his excessive force allegations. The court held that the district court erred by relying on a defendant's self-serving report and a video to evaluate the sufficiency of the complaint under Rule 12(b)(6).

Civil Civil Rights - Section 1983
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Jan 7 2025
23-394 Panel Decision

Moreira et al. v. Société Générale et al.

The Second Circuit affirmed the dismissal of Helms-Burton Act claims, holding that the statute's two-year time bar is a statute of repose that runs from the defendant's last culpable act. Because the plaintiffs' allegations of trafficking predated their complaints by more than two years and the presidential suspensions of the right to sue did not toll the repose period, the claims were time-barred.

Civil Securities Standing
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Jan 7 2025
23-670 Panel Decision

Moreira v. Société Générale, S.A.

The Second Circuit affirmed the dismissal of Helms-Burton Act claims, holding that the statute's two-year time bar is a statute of repose that cannot be tolled by presidential suspensions. Consequently, claims based on conduct occurring more than two years before filing are permanently barred, and remaining timely allegations failed to plausibly allege trafficking.

Civil Securities Standing
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Jan 7 2025
23-568 Panel Decision

Moreira v. Société Générale, S.A.

The Second Circuit affirmed the dismissal of Helms-Burton Act claims, holding that the statute's two-year time bar is a statute of repose that cannot be tolled by presidential suspensions. Consequently, claims based on conduct occurring more than two years before filing were barred, and remaining allegations failed to plausibly allege trafficking.

Civil Securities Standing
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Jan 3 2025
22-1799 Panel Decision

United States v. Cuomo

The Second Circuit affirmed Guy Cuomo's convictions for computer fraud and identity theft, ruling that impersonating debtors to access state unemployment databases constituted unauthorized access under the Computer Fraud and Abuse Act. The court also upheld his 45-month sentence, rejecting challenges to the evidence sufficiency and sentencing enhancements.

Criminal Sentencing Guidelines
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Dec 30 2024
23-793 Per Curiam

Carroll v. Trump

The Second Circuit affirmed the $5 million judgment against Donald Trump, ruling that the district court properly admitted evidence of prior sexual misconduct and a 2005 recording under Federal Rules of Evidence 415 and 404(b). The court held that Trump failed to demonstrate any reversible error or that such rulings affected his substantial rights, thereby denying his request for a new trial.

Constitutional Habeas Corpus - General (28 USC 2241)
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