Raymond J. Lohier, Jr.

How Judge Lohier rules, drawn from 40 signed orders. Every observation links to the order it came from.

Court
U.S. Court of Appeals for the Second Circuit
Position
circuit
Appointed by
Barack Obama (Democratic)
Commissioned
2010-12-20
Education
Harvard College (A.B., cum laude, 1988); New York University School of Law (J.D., 1991; Editor in Chief, NYU Annual Survey of American Law)
Signed orders read
40

How Judge Lohier decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

Whether a prison grievance procedure was available for exhaustion purposes is assessed objectively by asking whether a similarly situated person of ordinary firmness would have regarded it as usable.

“[T]he test for deciding whether the ordinary grievance procedures were available” is ‘an objective one: that is, would a similarly situated individual of ordinary firmness have deemed them available.”

Whether a secondary use is transformative for copyright purposes turns on the message a reasonable observer would perceive, not either side's subjective account of its intent.

“But whether a secondary use is transformative turns on what a reasonable observer thinks, not the subjective intent of the copyright holder or that of the secondary user.”

Procedural preferences

Issuing a right-to-sue letter and the charging party's filing of a private action do not terminate the agency's statutory power to continue investigating the underlying discrimination charge.

“We hold that the EEOC retains its statutory investigative authority after it issues a right-to-sue letter and the charging party files a separate suit.”

Cautions

Bare legal title does not necessarily establish constitutional standing to contest civil forfeiture. A claimant must show a colorable property interest that extends beyond acting as a straw owner for someone else.

“Their uncontested legal title in the Amadea alone, they say, constitutes a facially colorable interest sufficient to establish Article III standing. Not quite.”

The thirty-day removal period is not triggered by correspondence that merely prompts further investigation when the jurisdictional basis cannot yet be learned with certainty from the document itself.

“the relevant jurisdictional information could not be ‘found out or learned with certainty’ from Vermont’s email or the DEC letter,”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

UBS Financial Services, Inc. v. West Virginia University Hospitals, Inc.
10-4109-cv · 2011-09-22
Appeal (appellant (plaintiff UBS Financial Services, Inc.)) Denied

“We therefore affirm the District Court's judgment dismissing UBS's claims and affirm its order denying UBS's motion to enjoin arbitration.”

United States v. Zaleski
11-660-cr · 2012-07-13
Appeal (appellant (defendant Alan Zaleski)) Granted in part

“For the foregoing reasons, we VACATE in part and AFFIRM in part the order of the District Court, and we REMAND for further proceedings consistent with this opinion.”

Lopes v. Department of Social Services
10-3741-cv · 2012-10-02
Appeal (appellant (defendant Commissioner of the Connecticut Department of Social Services)) Denied

“Because we conclude that the applicable regulations and the United States Department of Health and Human Services' interpretation of those regulations support Lopes's position, we AFFIRM the judgment of the District Court.”

Psihoyos v. John Wiley & Sons, Inc.
11-4283 · 2014-04-04
Appeal (appellant (defendant John Wiley & Sons, Inc.; photographer Psihoyos cross-appealed)) Denied

“For the foregoing reasons, the judgment of the District Court is AFFIRMED.”

Newton v. City of New York
11-2704-cv · 2015-02-26
Appeal (appellant (plaintiff Alan Newton, exonerated)) Granted

“We therefore vacate and remand with instructions to reinstate the jury verdict with respect to Newton's Fourteenth Amendment claim and to reconsider Newton's First Amendment claim in light of this opinion.”

Fischer v. Smith
13-4197 · 2015-03-17
Appeal (appellant (respondent Superintendent / the State, appealing the habeas grant)) Granted

“We conclude that the State Court decision was, to the contrary, an adjudication on the merits entitled to AEDPA deference and not so lacking in justification as to warrant habeas relief. Accordingly, we reverse the decision of the District Court.”

United States v. Levy
13-2894-cr · 2015-09-29
Appeal (appellant (defendant David Levy)) Denied

“For the foregoing reasons and those set forth in the accompanying summary order, we AFFIRM the judgment of conviction of the District Court.”

Makinen v. City of New York
15-3273-cv · 2017-05-22
Appeal (appellants (defendants City of New York and individual officers; plaintiffs cross-appealed)) Moot / procedural

“For the foregoing reasons, we certify the following question to the New York Court of Appeals: Do sections 8-102(16)(c) and 8-107(l)(a) of the New York City Administrative Code preclude a plaintiff from bringing a disability discrimination claim based solely on a perception of untreated alcoholism? ... Decision is RESERVED.”

Hines v. City of Albany
16-1116 · 2017-07-06
Appeal (appellants (plaintiffs Constance and Marshay Hines)) Granted

“For the foregoing reasons, the order of the District Court is VACATED and the matter is REMANDED to the District Court with instructions to determine a reasonable award of attorneys' fees consistent with this opinion. Plaintiffs-appellants are also entitled to recover reasonable attorneys' fees in connection with this appeal.”

United States v. Caltabiano
16-1275-cr · 2017-09-18
Appeal (appellant (defendant John W. Caltabiano, Jr.)) Denied

“Proceeding to the merits, we conclude that sufficient evidence supported Caltabiano's conviction on the mail fraud counts, that he waived his primary challenge to the District Court's jury instructions, and that his sentence was not procedurally unreasonable. We therefore AFFIRM.”

Arias v. Gutman, Mintz, Baker & Sonnenfeldt LLP
16-2165 · 2017-11-14
Appeal (appellant (plaintiff Franklin Arias)) Granted

“As explained below, we VACATE the judgment of the District Court and REMAND for further proceedings consistent with this opinion.”

United States v. Holcombe
16-1429-cr · 2018-02-23
Appeal (appellant (defendant Thomas Abdul Holcombe)) Denied

“We have considered Holcombe's remaining arguments and conclude that they are without merit. For the foregoing reasons, the judgment of the District Court is AFFIRMED.”

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