This case concerns a dispute over the award of attorney's fees and costs after a lengthy civil rights trial in which Orthodox and Hasidic Jewish plaintiffs sued the Village of Airmont and multiple other defendants alleging religious discrimination in zoning ordinances, village incorporation, and related actions under 42 U.S.C. §§ 1983, 1985(3), and the Fair Housing Act. The jury found violations by the Village on two claims but awarded no damages, while ruling for the defendants on twenty-three other findings, and the district court had previously denied fees; on appeal the Second Circuit reversed and remanded for a substantial fee calculation based on the plaintiffs' injunctive relief and intertwined claims. The district court declines to follow the remand instructions, reasoning that the appellate findings rest on clear errors of fact and law, that the plaintiffs achieved only minimal success against a single defendant, and that imposing nearly two million dollars in fees would risk bankrupting the small village.
In Taylor v. Sullivan, parolee Rodney Taylor sued his parole officer Karen Sullivan, alleging she intentionally harassed him by filing reports against him that she knew to be false. Following a jury verdict finding Sullivan liable, the court addressed her renewed motion for judgment as a matter of law. The court granted the motion in favor of the defendant. Its reasoning focused on the applicability of qualified immunity to the parole officer's conduct in preparing violation reports and related actions, drawing on precedents distinguishing such duties from those warranting absolute immunity.
This case concerns a §1983 claim by plaintiff Warner against the Orange County Department of Probation, alleging that his probation sentence requiring attendance at Alcoholics Anonymous meetings violated the Establishment Clause due to the program's religious elements, given his atheist beliefs. On remand from the Second Circuit, the district court addressed whether Warner had waived or forfeited his claims by failing to object to or appeal his sentence, and whether the County had raised any waiver defense at trial. The court determined that waiver is an affirmative defense under Federal Rule of Civil Procedure 8(c) that must be pled and was not, and that the County had never asserted waiver or forfeiture during the proceedings, instead maintaining that AA was not religious. Evidence from trial showed Warner had voiced objections to the religious aspects to his probation officer, but this was not framed as a waiver issue by the defense. The court noted it would conduct further proceedings if needed to develop the record on these points.
In this case, petitioner Peter Paese filed a 28 U.S.C. § 2255 petition seeking to set aside his guilty plea conviction on one count of aiding and abetting the use or carrying of a firearm during a bank robbery, which carried a five-year mandatory minimum sentence, and to obtain related sentencing relief. The court denied the petition in full. It reasoned that, although recent Supreme Court decisions had narrowed the scope of § 924(c) liability, Paese's plea remained valid because the record provided an adequate factual basis under the Pinkerton doctrine of co-conspirator liability: he knew his companion in the getaway car was armed and that another participant was using a gun inside the bank. The court also rejected claims of ineffective assistance of counsel and abuse of the writ.
The case concerned whether the Village of Airmont's zoning code violated the Fair Housing Act by discriminating against religious groups through restrictions on home-based religious assemblies. The court decided that the Village had violated the Act and issued a declaratory judgment along with a permanent injunction that required specific amendments to the zoning code, such as adding provisions allowing residential places of worship by right and deleting restrictive language on home professional offices. The reasoning centered on the code's provisions that hindered group prayer in residences and imposed unequal restrictions on religious uses, which denied equal housing opportunities on the basis of religion, necessitating revisions, monitoring, and affirmative relief to prevent such discrimination.
This case concerns claims by Orthodox Jewish residents and the U.S. government that the Village of Airmont was incorporated and later adopted zoning rules with the intent to restrict home synagogues used by Hasidic Jews, in violation of the Fair Housing Act and First Amendment rights. After the Second Circuit reversed earlier district court rulings and remanded for remedies, the court addressed disputes over injunctive relief and related measures. The court granted preventive injunctive relief to bar enforcement of the zoning code in ways that discriminate against religious practices, reasoning that such relief was warranted by the appellate findings of discriminatory purpose in the village's formation and code adoption, even without prior application of the new rules to the plaintiffs. The decision emphasized compliance with the Second Circuit's directives on liability while noting limits on further equitable intervention under precedents like Rizzo v. Goode.