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The Second Circuit held that Title VI's bar on employment-related claims does not prevent an employee from suing for retaliation when the underlying complaint concerns non-employment discrimination. The court vacated the dismissal of the plaintiff's claim and remanded the case for further proceedings on the merits.
The Second Circuit affirmed the district court's grant of summary judgment to the USPS, holding that aggregated change-of-address data qualifies as information of a commercial nature under the Postal Reorganization Act. The court ruled that FOIA Exemption 3 bars disclosure of this data because the underlying statute establishes specific criteria for withholding commercial information derived from the agency's core business operations.
The Second Circuit reversed summary judgment, holding that plaintiffs need not prove an aggregate disparate impact to establish a discriminatory effect under the Equal Protection Clause if discriminatory intent is shown. Instead, the court ruled that harm to individual Asian-American students excluded from a school admissions program is sufficient to trigger strict scrutiny review.
The Second Circuit vacated the district court's affirmation of a Social Security Administration denial, holding that the Administrative Law Judge's decision was not supported by substantial evidence. The court found the ALJ misinterpreted medical and lay evidence regarding the plaintiff's ability to adapt to environmental changes.
The Second Circuit affirmed a conviction for possessing child pornography, holding that a search warrant for a cellular phone validly authorized the examination of an SD card inserted into that device. The court ruled that the warrant's broad language covering electronic storage in any form included the removable flash memory card.
The Second Circuit affirmed Eric Tompkins's conviction, holding that a search warrant for a cellular phone validly authorized the examination of an SD card inserted into that device. The court ruled that the warrant's broad language covering 'electronic storage' encompassed the SD card as an integral component of the phone.
The Second Circuit affirmed that the 1676 Andros Order is not a valid federal treaty binding on the United States because it predates the nation and lacks federal ratification. Consequently, the order does not preempt New York's fishing regulations prohibiting the harvesting of glass eels in off-reservation waters.
The Second Circuit reversed a district court dismissal, holding that a foreign defendant transacted business in New York by accepting online orders from New York residents, even without physical shipment. The court clarified that New York's long-arm statute requires a transaction, not a completed delivery, to establish personal jurisdiction over interactive websites.
The Ninth Circuit affirmed a 46-month prison sentence for a felon in possession of a firearm, ruling that the district court did not clearly err in applying a sentencing enhancement for reckless endangerment during flight. The court further held that the district court properly relied on Sentencing Commission data to address sentencing disparities and that the defendant forfeited arguments regarding a downward departure.
The Second Circuit vacated a district court ruling that denied sovereign immunity to a foreign state's UN mission, holding that the employment of a non-diplomatic chauffeur for high-ranking officials may constitute a sovereign function rather than commercial activity. The appellate court found the lower court erred by shifting the burden of proof and failing to conduct a nuanced examination of the specific context surrounding the driver's duties.
