May 16 2025
9th Cir. 3:23-cv-00381-SK Published

ESTATE OF DECEDENT LOLOMANIA SOAKAI; LAVINIA SOAKAI, an individual and personal representative of Estate; DANIEL FIFITA, an individual; SAMIEUELA FINAU, an individual; INA LAVAL...

The Ninth Circuit affirmed the denial of qualified immunity for police officers involved in a high-speed chase where a fleeing suspect crashed into innocent bystanders. The court held that plaintiffs plausibly alleged a Fourteenth Amendment substantive due process violation by claiming the officers chased with a purpose to harm the suspect in a manner exceeding legitimate law enforcement needs, and that this right was clearly established.

Feb 26 2025
2nd Cir. 23-903 Panel Decision

Uviles v. City of New York

The Second Circuit affirmed that the City of New York lawfully detained a parolee pursuant to a warrant that remained facially valid despite the expiration of the statutory deadline for a preliminary hearing. The court held that New York law requires municipal authorities to honor outstanding parole warrants until the state board of parole lifts them, regardless of procedural delays in the state's internal hearing process.

Feb 13 2025
2nd Cir. 22-1377 Panel Decision

Hoffer v. Tellone

The Second Circuit clarified that sanctions for lost electronic evidence under Federal Rule of Civil Procedure 37(e)(2) require a specific finding of intent to deprive the opponent of that information. The court rejected the application of a lesser negligence standard, affirming the district court's denial of an adverse inference instruction in a civil rights excessive force case.

Feb 11 2025
9th Cir. 3:22-cv-00244- Published

K. J., a minor, by and through his guardian ad litem, Kasey L. Johnson v. Doctor LAMONT A. JACKSON

The Ninth Circuit reversed summary judgment, holding that school officials violated a high school student's due process rights by extending his suspension based on new charges without providing notice or a hearing. The court further ruled that the officials are not entitled to qualified immunity and that the student has standing to seek expungement of the disciplinary records.

Jan 13 2025
2nd Cir. 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.

Jan 13 2025
2nd Cir. 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).

Dec 30 2024
2nd Cir. 22-585 Panel Decision

Edwards v. Arocho

The Second Circuit vacated the dismissal of a pretrial detainee's Fourteenth Amendment claims regarding unsanitary conditions and segregation without a hearing. The court also reversed summary judgment on a failure-to-protect claim, finding a factual dispute over whether the plaintiff exhausted administrative remedies under the PLRA.

Dec 9 2024
2nd Cir. 22-3106 Panel Decision

Cerame v. Slack

The Second Circuit vacated a dismissal, holding that Connecticut lawyers have Article III standing to challenge a new bar rule restricting speech. The court found the plaintiffs plausibly alleged a credible threat of enforcement that chills their First Amendment rights.

Nov 25 2024
2nd Cir. 22-978 Panel Decision

Thompson v. Booth

The Second Circuit vacated a default judgment against a corrections officer, ruling that the district court abused its discretion by awarding damages while dismissing identical claims against co-defendants for failure to exhaust administrative remedies. Applying the prohibition on inconsistent judgments, the court held that a plaintiff cannot prevail against a defaulting defendant when the same legal bar precludes the claims against litigating co-defendants.

Oct 24 2024
2nd Cir. 22-1362 Panel Decision

State Farm Mutual Automobile Insurance Co. v. Tri-Borough NY Medical Practice P.C.

The Second Circuit reversed the district court's denial of a preliminary injunction against pending state-court proceedings, holding that an exception to the Anti-Injunction Act applies where federal arbitration claims are at stake and state litigation threatens irreparable harm. Applying the standard for enjoining state court actions under 28 U.S.C. § 2283, the court found State Farm likely to succeed on its claim that the Federal Arbitration Act preempts the state proceedings.