Skadden secured a victory for the Nassau County Interim Finance Authority (NIFA), a New York state financial control board, when the U.S. Court of Appeals for the Second Circuit vacated a district court's grant of summary judgment to three police unions. The unions alleged that a 2011 NIFA wage freeze imposed upon county employees was unconstitutional and the board's statutory power to impose it had expired. On September 20, the Second Circuit unanimously held that the district court had abused its discretion in exercising pendent jurisdiction over the state statutory claim and directed that it be dismissed.

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