Toyota Lease Trust v. Village of Freeport

CourtCourt of Appeals for the Second Circuit
DecidedApril 17, 2025
Docket24-488
StatusUnpublished

This text of Toyota Lease Trust v. Village of Freeport (Toyota Lease Trust v. Village of Freeport) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Toyota Lease Trust v. Village of Freeport, (2d Cir. 2025).

Opinion

24-488-cv Toyota Lease Trust v. Village of Freeport

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 17th day of April, two thousand twenty-five.

PRESENT: SUSAN L. CARNEY, MICHAEL H. PARK, MARIA ARAÚJO KAHN, Circuit Judges.

_________________________________________

TOYOTA LEASE TRUST,

Plaintiff - Appellee,

v. No. 24-488-cv

VILLAGE OF FREEPORT,

Defendant - Appellant,

ALL COUNTY HOOK UP TOWING, INC., JOSEPH CALVAGNO,

Defendants. * _________________________________________

FOR APPELLANT: KEITH M. CORBETT (Brian D. Ginsberg, on the brief), Harris Beach PLLC, Uniondale, NY.

FOR APPELLEE: NICHOLAS A. DUSTON (Benjamin D. Schwartz, on the brief), Norris McLaughlin, P.A., New York, NY.

Appeal from a judgment of the United States District Court for the Eastern

District of New York (Gujarati, District Judge; Locke, Magistrate Judge).

UPON DUE CONSIDERATION WHEREOF, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the judgment entered on February 16, 2024,

is VACATED and the case is REMANDED for further proceedings.

Defendant-Appellant Village of Freeport (“the Village”), a municipality

located in Nassau County, New York, appeals from a judgment of the United

States District Court for the Eastern District of New York (Locke, M.J.) awarding

$235,054.25 in attorneys’ fees to Plaintiff-Appellee Toyota Lease Trust (“Toyota”),

a subsidiary of Toyota Motor Credit Corporation. We assume the parties’

familiarity with the underlying facts, procedural history, and arguments on

appeal, to which we refer only as necessary to explain our decision to vacate and

remand.

* The Clerk of Court is directed to amend the caption to conform to the above.

2 Background

Toyota held title to a Camry leased to two residents of the Village. Those

residents allowed more than $1,000 in Village parking tickets to accumulate over

time. In January 2020, the outstanding parking fees triggered the Village’s

seizure of the Camry from a public road under its “scofflaw” policy (the

“Policy”). Under the Policy, the Village or its agent (a towing company) would

impound and retain an offending vehicle until the tickets and related fees were

paid.

In May 2020, Toyota––which by then had displaced the vehicle’s lessees,

who defaulted on the lease––sued the Village under 42 U.S.C. § 1983. It asserted

that the Village’s seizure of the Camry without a warrant was unreasonable, in

violation of its Fourth Amendment rights, and that the Village did not afford it

sufficient process under the Fourteenth Amendment because it provided neither

timely notice nor any opportunity to be heard. More broadly, it argued that the

Policy embodied an unconstitutional application of New York State Vehicle and

Traffic Law § 1224, the state traffic law upon which the Village relied. Finally, it

further alleged that the Policy violated other New York statutory and

constitutional laws. Naming the Village, the towing company, and the towing

company’s owner as defendants, it sought declaratory and injunctive relief,

damages of different kinds, replevin, and certain other relief.

3 In July 2022, Toyota moved for partial summary judgment. 1 It asked for a

ruling that the seizure and impoundment of the Camry, and other similarly

situated vehicles, violated the Fourth and Fourteenth Amendments; a judgment

declaring the Policy violative of the U.S. Constitution; and $3,601 in

compensatory damages. The Village, in turn, sought partial summary judgment

on its opposing legal claims defending the Policy.

Magistrate Judge Locke recommended that the district court: (1) award

summary judgment to Toyota on its Fourth and Fourteenth Amendment claims

that the Village’s impoundment of the Camry was an unreasonable seizure and

that it occurred without due process of law; (2) deny Toyota summary judgment

on its compensatory damages claim; (3) grant judgment declaring the Policy

broadly unconstitutional under the Fourth Amendment’s prohibition against

unreasonable, warrantless seizures and the Fourteenth Amendment’s prohibition

against deprivations of property without due process of law; (4) dismiss the

replevin claim as moot; and (5) permit Toyota to request an inquest on damages.

See Toyota Lease Tr. v. Vill. of Freeport, 2023 WL 4443992, at *5, 12–14 (E.D.N.Y. Jan.

24, 2023). He also recommended that the district court order the Village to submit

legislation, which the court would review, amending the Policy to provide

additional process. Id. at *12–13.

In March 2023, Judge Gujarati adopted this recommendation in part. She

granted summary judgment to Toyota on its federal constitutional claims as

1In November 2020, the Village surrendered the Camry to Toyota. Before seeking summary judgment, Toyota dismissed its claims against the towing company and its owner. Only the Village is a party to this appeal.

4 applied to the Village’s seizure of the Camry. See Toyota Lease Tr. v. Vill. of

Freeport, 2023 WL 4449333, at *2 (E.D.N.Y. Mar. 30, 2023); Toyota Lease Tr., 2023

WL 4443992 at *8 (“Freeport's Scofflaw policy as applied in this case violated

Plaintiff's Fourth Amendment rights”); id. at *10. She denied summary judgment

as to compensatory damages and granted summary judgment to the Village on

the replevin claim. Toyota Lease Tr. v. Vill. of Freeport, 2023 WL 4449333, at *2. She

reserved decision on Toyota’s broad request for declaratory relief as to the

constitutionality of the Policy. Id. 2

In April 2023, the court met with the parties to discuss Toyota’s request for

declaratory relief. The parties agreed to submit a joint letter on that issue.

Two weeks later, Toyota and the Village advised the court by letter from

counsel to Toyota that they had reached agreement on the remaining merits

issues. Counsel reported Toyota’s agreement to withdraw its state constitutional

and statutory claims, and the Village’s agreement that it had “policy-makers

[working on] revising their [P]olicy” to provide more effective notice and to

avoid unreasonable, warrantless seizures. App’x 509. Toyota’s counsel further

advised, “[T]here is no need for Court supervision of the proposed alternate

legislation” because the Magistrate Judge’s “report and recommendation . . .

addressed all major constitutional issues surrounding the current policy” and

that the ruling “should be a sufficient guide” to the Village. Id. The parties later

stipulated that only two issues still required the court’s attention: the amounts

due Toyota as compensatory damages and for its attorneys’ fees and costs under

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