In this case, Kenneth Locke sued St. Augustine's Episcopal Church and its rector under the Fair Labor Standards Act and New York Labor Law, seeking unpaid minimum wages, overtime, spread-of-hours pay, and liquidated damages for his work as a custodian. The court granted the defendants' motion for summary judgment and dismissed the federal claims. It held that subject matter jurisdiction was lacking because the FLSA did not apply, as neither the church qualified as an enterprise engaged in commerce nor Locke as an employee engaged in commerce or producing goods for commerce under the statute's definitions. The court also declined to exercise supplemental jurisdiction over the state-law claims and dismissed them without prejudice.
In Phelps v. Szubinski, plaintiff sued a police officer under 42 U.S.C. § 1983 for false arrest and excessive force, along with related state law claims, stemming from a 2003 traffic stop where the officer arrested him for driving with a revoked license and allegedly caused injury to his hip and knee while placing him in the patrol car. The court granted summary judgment to the defendants on the federal claims. It reasoned that the officer had probable cause for the arrest based on the DMV records showing the license revocation, and that the force used was not excessive because it was reasonable under the circumstances. The court declined to exercise supplemental jurisdiction over the remaining state law claims.
The case involves a defendant charged with transporting and possessing child pornography who moved to compel the government to provide a mirror image of his seized computer hard drive for his defense. The court denied the motion, holding that the Adam Walsh Child Protection and Safety Act of 2006, which keeps such materials in government custody but requires they be made reasonably available for inspection at government facilities, is constitutional. The court reasoned that the Act does not violate due process or the right to effective assistance of counsel, as it provides ample opportunity for examination by the defendant, counsel, and experts. The court also rejected arguments that the Act violates equal protection or the separation of powers doctrine, noting that Congress has authority to modify procedural discovery rules like those in Federal Rule of Criminal Procedure 16.
This case involved the U.S. Attorney's ex parte application for a pen register order under the Pen/Trap Statute, 18 U.S.C. §§ 3121-3127, seeking access to all dialed digits from a target telephone, including post-cut-through dialed digits (PCTDD) that may contain the contents of communications. The court granted the application in part but denied access to PCTDD, and upon reconsideration reaffirmed that denial after receiving an amicus brief. The court held that the statute prohibits pen registers from obtaining communication content and that allowing such access would violate the Fourth Amendment, rejecting the government's minimization theory that it could collect all digits subject only to internal guidelines if no technology existed to filter content. The decision aligned with rulings from other districts but relied on statutory text, legislative history, and constitutional principles.
This case involves a petition by Robert Skrodzki under the Hague Convention on the Civil Aspects of International Child Abduction seeking the return of his two children to Poland after their mother, Ewa Skrodzka, removed them to New York without his consent. The court granted the father's motion for summary judgment and denied the mother's, ordering the children's return to Poland. The children had been habitual residents of Poland, where both parents shared joint custody rights under Polish law, and the mother's removal violated those rights. Defenses such as the children being well-settled in the new country or the child's objection were rejected because the evidence showed only a preference for life in the US rather than a valid objection, and the petition was filed within one year of removal.
This case involves former employees of New York Foundling Hospital, a nonprofit providing foster care and related services to children referred by the New York City Administration for Children’s Services, who sued for unpaid overtime under the Fair Labor Standards Act (FLSA) and New York labor law, asserting either enterprise coverage or individual coverage. The court granted the defendant’s partial summary judgment motion and denied the plaintiffs’ motion, dismissing the enterprise coverage claims under the FLSA while allowing the individual coverage claims to proceed as a collective action. The state law claims were dismissed without prejudice and with leave to amend. The core reasoning was that, based on the FLSA’s text, legislative history, and relevant case law, Foundling does not qualify as an “enterprise engaged in commerce” because it is not a public agency or acting in connection with one in the manner required by the statute, despite its contracts with ACS and receipt of public funds.
