Last Week in Federal Appeals (No. 76)
Last Week in Federal Appeals (No. 76)
Appellate decisions from the week of August 12, 2024
“After all, for our Constitution’s liberty-ensuring principles to have any strength, they must, like a muscle, be used correctly, consistently, and forcefully.”
Judge Restrepo, Williams v. Superintendent Greene SCI
Decision Summaries
First Circuit
Bazinet v. Beth Israel Lahey Health, Inc.
The First Circuit reversed and vacated the lower court’s dismissal and allowed the plaintiff’s religious discrimination claim to move forward based on her claim that her sincere religious belief prohibited her from receiving the COVID-19 vaccine after her employer refused to provide an accommodation.
Perez-Perez v. Hospital Episcopal San Lucas Inc.
The First Circuit held that the application of Puerto Rico’s statutory cap on medical malpractice is a question of fact best determined by the jury when it turns on the physician’s employment status.
Second Circuit
Soukaneh v. Andrzejewski
The Second Circuit held that the defendant police officer not entitled to qualified immunity after he detained the plaintiff during a traffic stop without probable cause. The panel agreed with the lower court that the officer lacked probable cause after the plaintiff informed the officer of his lawful possession of a firearm and the plaintiff showed the officer the requisite permit.
Olivieri v. Stifel, Nicolaus & Company, Inc.
The Second Circuit vacated the lower court’s decision finding the plaintiffs’ copyright infringement claim untimely. According to the panel, the lower court improperly reasoned that the plaintiffs’ “relative sophistication” weighed on the timeliness of its discovery and filing of the claim.
Jeffery v. City of New York
The Second Circuit held that New York City’s implementation and enforcement of a week-long curfew in light of violent ongoing protests was constitutional because the rule survives the strict scrutiny analysis triggered by the restriction on the right to travel.
Third Circuit
Williams v. Superintendent Greene SCI
The Third Circuit affirmed the lower court’s grant of habeas corpus relief when the plaintiff’s trial judge twice read a non-testifying codefendant’s criminal information to the jury in violation of the Sixth Amendment, and the plaintiff’s counsel failed to intervene in violation of the plaintiff’s right to effective defense counsel.
Fisher v. Hollingsworth
The Third Circuit held that there is no federal constitutional claim “against federal officials who fail to protect prisoners from the criminal acts of their fellow inmates.”
Schaffner v. Monsanto Corporation
The Third Circuit held that Pennsylvania’s state-law duty to include additional warnings on pesticide labels imposes requirements that are different from those imposed under Federal Insecticide, Fungicide, and Rodenticide Act, is preempted by that federal statute.
Seventh Circuit
United States v. Yang
In a case of first impression, the Seventh Circuit held that procedural default barred a criminal defendant’s claim of competency initially raised on a collateral challenge to his conviction.
Vanegas v. Signet Builders, Inc
The Seventh Circuit held that, in claims proceedings under the Fair Labor Standards Act, a court overseeing a collective action must secure personal jurisdiction over each plaintiff’s claim. The panel explained that neither the Act, nor Rule of Civil Procedure 4, furnish nationwide personal jurisdiction in such cases.
Ninth Circuit
Cox v. CoinMarketCap OpCo, LLC
The Ninth Circuit held that the Commodity Exchange Act authorizes nationwide service of process without the need to first show proper venue and that personal jurisdiction over potential defendants under the Act may be demonstrated by sufficient contacts with the forum to satisfy due process.
Election Integrity Project California, Inc. v. Weber
The Ninth Circuit affirmed the lower court’s dismissal of plaintiffs’ challenge to the November 2020 election results and constitutional challenge to California’s vote-by-mail system. The panel held that the plaintiffs failed to plausibly demonstrate the requisite massive disenfranchisement or complete lack of integrity necessary to state a claim under the Due Process Clause.
NetChoice, LLC v. Bonta
The Ninth Circuit held that California Age-Appropriate Design Code Act likely facially violates the First Amendment by requiring covered businesses to “mitigate” the risk that children may be exposed to harmful or potentially harmful materials online. The panel affirmed the lower court’s preliminary injunction on only certain provisions of the Act.
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