Justia U.S. 3rd Circuit Court of Appeals Opinion Summaries

Ephriam Rodriquez, a bus operator, was terminated by the Southeastern Pennsylvania Transportation Authority (SEPTA) after accumulating excessive negative attendance points under his union’s Collective Bargaining Agreement. His final absence on June 8, 2018, was due to a migraine headache. Following an informal hearing on June 26, where his discharge was recommended, Rodriquez applied for leave under the Family and Medical Leave Act (FMLA) and sought medical documentation to support his claim. Despite this, SEPTA held a formal hearing and approved his termination.Rodriquez filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania, alleging FMLA retaliation and interference. The jury found in favor of Rodriquez on the interference claim, awarding him $20,000 in economic damages, but ruled in favor of SEPTA on the retaliation claim. SEPTA then moved for judgment as a matter of law, arguing that Rodriquez did not have a “serious health condition” under the FMLA at the time of his absence. The District Court granted SEPTA’s motion, leading to Rodriquez’s appeal.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. The appellate court affirmed the lower court’s ruling, holding that Rodriquez failed to demonstrate that his migraines constituted a “chronic serious health condition” as defined by the FMLA. Specifically, Rodriquez did not provide evidence of periodic visits to a healthcare provider for his migraines before his termination, which is a requirement under the FMLA regulations. The court concluded that there was no legally sufficient evidence for the jury to find that Rodriquez had a qualifying serious health condition at the time of his June 8 absence. View "Rodriquez v. SEPTA" on Justia Law

William Valentin, along with four other men, robbed a jewelry store in New Jersey, during which Valentin pointed a loaded gun at a store employee. The robbers stole nearly $900,000 in jewelry and left behind substantial evidence, including video footage, fingerprints, DNA, and cell phone records. A jury convicted Valentin of Hobbs Act robbery, conspiracy to commit Hobbs Act robbery, use of a firearm during a crime of violence, and conspiracy to use a firearm during a crime of violence. The District Court sentenced him to a term of imprisonment within the applicable sentencing guidelines range.The District Court for the District of New Jersey initially tried Valentin and his cousin Jonathan Arce together, but the jury acquitted Arce and failed to reach a verdict for Valentin, resulting in a mistrial. Valentin was retried a year later, and the jury found him guilty on all counts. The District Court sentenced him as a career offender, calculating the applicable sentencing guidelines range as 360 months to life imprisonment. Valentin did not object to the stated basis for the sentence, and the Court imposed a within-guidelines sentence of 360 months’ imprisonment, 5 years’ supervised release, and $889,844.33 in restitution.The United States Court of Appeals for the Third Circuit reviewed the case. Valentin raised several challenges to his convictions and sentence, including the admission of certain identification testimony, the exclusion of other similar testimony, the admission of evidence of a prior criminal relationship, and the reasonableness of his sentence. The Court of Appeals found that any potential errors in the District Court’s evidentiary rulings were harmless given the overwhelming evidence of Valentin’s guilt. The Court also held that brandishing a firearm during a robbery qualifies as a crime of violence under the sentencing guidelines. Consequently, the Court of Appeals affirmed the District Court’s judgment of conviction and sentence. View "USA v. Valentin" on Justia Law

Glenn O. Hawbaker, Inc. (GOH) engaged in a scheme to underpay its employees by misappropriating fringe benefits owed under the Pennsylvania Prevailing Wage Act (PWA) and the Davis-Bacon Act (DBA). This led to two class-action lawsuits against GOH. GOH sought coverage under its insurance policy with Twin City Fire Insurance Company (Twin City), which denied coverage and sought a declaratory judgment that it had no duty to provide coverage. GOH and its Board of Directors counterclaimed, alleging breach of contract and seeking a declaration that certain claims in the class actions were covered under the policy.The United States District Court for the Middle District of Pennsylvania dismissed GOH's counterclaims, concluding that the claims were not covered under the policy due to a policy exclusion for claims related to "Wage and Hour Violations." The court also granted Twin City's motion for judgment on the pleadings, affirming that Twin City had no duty to defend or indemnify GOH for the class-action claims.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's judgment. The Third Circuit agreed that the claims in question were not covered under the policy because they were related to wage and hour violations, which were explicitly excluded from coverage. The court emphasized that the exclusion applied broadly to any claims "based upon, arising from, or in any way related to" wage and hour violations, and found that the factual allegations in the class actions were indeed related to such violations. Thus, Twin City had no duty to defend or indemnify GOH under the terms of the policy. View "Twin City Fire Insurance Co. v. Glenn O. Hawbake, Inc." on Justia Law

A criminal defendant, convicted of aggravated manslaughter and sentenced to thirty years in prison, twice instructed his attorney to file a plenary appeal. However, his intake appellate counsel designated the appeal for the expedited sentence-review track (ESOA). The ESOA panel did not transfer the case to the plenary calendar and affirmed the sentence. The defendant's subsequent post-conviction relief applications in state court, which included claims of ineffective assistance of counsel, were unsuccessful.The United States District Court for the District of New Jersey denied the defendant's habeas corpus petition under 28 U.S.C. § 2254, which included claims related to the ESOA designation. The court also denied his Rule 60(b) motion, which specifically challenged the intake appellate counsel's decision to place the appeal on the ESOA calendar.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the Rule 60(b) motion was not a second or successive habeas application because it was filed within 28 days of the underlying judgment. However, the court found that the defendant's claim of ineffective assistance of counsel was procedurally defaulted because it was not exhausted in state court and he could not show the requisite prejudice to overcome the default. The court applied the Strickland standard for prejudice, requiring a reasonable probability that the result of the proceeding would have been different but for counsel's errors, rather than the Flores-Ortega standard, which applies when the entirety of direct appellate review is rendered unavailable. The court affirmed the denial of the habeas petition and the Rule 60(b) motion. View "Ross v. Administrator East Jersey State Prison" on Justia Law

William Webb, an inmate at James T. Vaughn Correctional Center (JTVCC) in Delaware, sued prison officials for failing to schedule court-ordered visits with his daughter. A Delaware family court had granted Webb visitation rights in October 2020, but since then, only one visit occurred in 2021, lasting fifteen minutes and concluding without incident. Webb filed a grievance through the prison’s internal process, which was returned unprocessed. He then wrote to three prison officials but received inadequate responses. Webb, representing himself, filed a lawsuit alleging that prison officials violated his constitutional right to reunification with his daughter.The United States District Court for the District of Delaware dismissed Webb’s complaint under the screening provisions of 28 U.S.C. §§ 1915A(b) and 1915(e)(2)(B). The court held that Webb failed to exhaust JTVCC’s internal grievance process and did not state a valid constitutional claim. The court also determined that allowing Webb to amend his complaint would be futile.The United States Court of Appeals for the Third Circuit reviewed the case. The court first addressed the timeliness of Webb’s appeal, applying the prison mailbox rule to JTVCC’s electronic filing system. The court held that Webb’s notice of appeal was timely filed when he placed it in the designated mailbox on November 22, 2022. On the merits, the court found that Webb’s complaint did not definitively show a failure to exhaust administrative remedies and plausibly alleged a constitutional claim under the First and Fourteenth Amendments. The court reversed the District Court’s dismissal and remanded the case for further proceedings. View "Webb v. Department of Justice" on Justia Law

Plaintiffs Marla Knudsen and William Dutra, representing a class of similarly situated individuals, filed a class action lawsuit under the Employee Retirement Income Security Act (ERISA) against MetLife Group, Inc. They alleged that MetLife, as the administrator and fiduciary of the MetLife Options & Choices Plan, misappropriated $65 million in drug rebates from 2016 to 2021. Plaintiffs claimed this misappropriation led to higher out-of-pocket costs for Plan participants, including increased insurance premiums.The United States District Court for the District of New Jersey dismissed the case for lack of standing. The court concluded that the plaintiffs did not demonstrate a concrete and individualized injury. It reasoned that the plaintiffs had no legal right to the general pool of Plan assets and had not shown that they did not receive their promised benefits. The court found the plaintiffs' claims that they paid excessive out-of-pocket costs to be speculative and lacking factual support.The United States Court of Appeals for the Third Circuit affirmed the District Court's dismissal. The Third Circuit held that the plaintiffs failed to establish an injury-in-fact, as their allegations of increased out-of-pocket costs were speculative and not supported by concrete facts. The court noted that the plaintiffs did not provide specific allegations showing how the misappropriated drug rebates directly caused their increased costs. The court emphasized that financial harm must be actual or imminent, not conjectural or hypothetical, to satisfy Article III standing requirements. Consequently, the plaintiffs lacked standing to pursue their ERISA claims. View "Knudsen v. MetLife Group Inc" on Justia Law

Two commercial fishermen, Raymond Lofstad and Gus Lovgren, challenged the constitutionality of the appointment process for members of the Mid-Atlantic Fishery Management Council. The Council, which oversees fisheries from New York to Virginia, had approved an amendment lowering the catch limits for certain fish species, which the Secretary of Commerce subsequently approved. The fishermen argued that the Council members, who were not appointed by the President or confirmed by the Senate, exercised significant authority and thus should be considered "Officers of the United States" under the Appointments Clause of the Constitution.The United States District Court for the District of New Jersey ruled against the fishermen, holding that the Council members did not exercise significant authority and were therefore not officers. The court granted summary judgment in favor of the government, reasoning that the Council's role was merely advisory and did not involve significant authority.The United States Court of Appeals for the Third Circuit reviewed the case de novo and found that the Council members did exercise significant authority, particularly through their power to veto certain actions by the Secretary of Commerce. The court held that these veto powers made the Council members principal officers who should have been appointed by the President and confirmed by the Senate. To remedy the constitutional violation, the court severed the Council's pocket-veto powers, reducing the members to mere employees who do not require such appointments. The court reversed the District Court's summary judgment for the government and rendered judgment for the fishermen. View "Lofstad v. Secretary United States Department of Commerce" on Justia Law

Roy Lee Williams, a death-row inmate with a history of mental illness, was held in solitary confinement for twenty-six years. Williams filed a lawsuit claiming that his prolonged solitary confinement without penological justification violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Americans with Disabilities Act (ADA). The District Court granted summary judgment in favor of the defendants, ruling that the former Secretary of the Pennsylvania Department of Corrections (DOC) was entitled to qualified immunity on the Eighth Amendment claim and that Williams could not prove deliberate indifference under the ADA.Before the summary judgment, the District Court dismissed Williams' Fourteenth Amendment claim for failure to state a claim. Williams appealed both the summary judgment and the dismissal of his Fourteenth Amendment claim.The United States Court of Appeals for the Third Circuit reviewed the case. The court concluded that the Secretary had "fair and clear warning" that keeping Williams in solitary confinement without penological justification was unconstitutional, thus rejecting the qualified immunity defense. The court held that it was clearly established that someone with a known preexisting serious mental illness has a constitutional right not to be held in prolonged solitary confinement without penological justification.Regarding the ADA claim, the court found that the District Court erred in concluding that a trier of fact could not find the DOC deliberately indifferent to the risk of harm caused by placing and keeping Williams in solitary confinement despite his mental illness. The court vacated the District Court's grant of summary judgment on both the Eighth Amendment and ADA claims and remanded for further proceedings. However, the court affirmed the dismissal of Williams' Fourteenth Amendment claim. View "Williams v. Secretary Pennsylvania Department of Corrections" on Justia Law

The case involves hundreds of plaintiffs who allege that they were injured by the drug Fosamax, manufactured by Merck Sharp & Dohme Corp. (Merck), due to inadequate warnings about the risk of atypical femoral fractures. The plaintiffs claim that they would not have taken the drug if they had been properly warned. Merck contends that it proposed a label change to the Food and Drug Administration (FDA) to address this risk, but the FDA rejected the proposed change due to insufficient scientific support.The United States District Court for the District of New Jersey granted summary judgment in favor of Merck, concluding that the plaintiffs' state law claims were preempted by federal law. The court found that Merck had fully informed the FDA of the justifications for the proposed warning and that the FDA had rejected the proposed label change, thus preempting the state law claims. The court relied on the FDA's Complete Response Letter and other communications to determine that the FDA's rejection was based on a lack of sufficient scientific evidence linking Fosamax to atypical femoral fractures.The United States Court of Appeals for the Third Circuit reviewed the case and vacated the District Court's judgment. The Third Circuit concluded that the District Court erred in its preemption analysis by giving too little weight to the presumption against preemption. The appellate court found that the FDA's Complete Response Letter was ambiguous and that the District Court placed too much reliance on informal FDA communications and an amicus brief to interpret the letter. The Third Circuit emphasized that the presumption against preemption is strong and that Merck did not meet the demanding standard of showing that federal law prohibited it from adding any and all warnings that would satisfy state law. The case was remanded for further proceedings. View "In re: Fosamax" on Justia Law

Raymond Zaborowski, a U.S. Army veteran suffering from anxiety and PTSD, applied for Social Security disability benefits, claiming his conditions have prevented him from working since 2014. An administrative law judge (ALJ) denied his claim, stating that medical evidence indicated he could still perform light work.Zaborowski appealed to the United States District Court for the Eastern District of Pennsylvania, where he consented to jurisdiction by a magistrate judge. The magistrate judge upheld the ALJ's decision, leading Zaborowski to appeal further.The United States Court of Appeals for the Third Circuit reviewed the case. Zaborowski argued that the regulation requiring ALJs to explain their decisions violated the Social Security Act, that the ALJ failed to properly explain the supportability and consistency of medical opinions, and that the ALJ's findings were not supported by substantial evidence. The Third Circuit reviewed the legal issues de novo and the ALJ's factual findings for substantial evidence.The court held that the regulation complies with the statute, as it requires ALJs to explain the dispositive reasons for their decisions, specifically focusing on supportability and consistency. The court found that the ALJ adequately addressed these factors in her analysis, noting that the opinions of two psychologists were consistent with the record, while the treating psychiatrist's opinion was not. The court also found substantial evidence supporting the ALJ's decision, including the psychologists' opinions and evidence of Zaborowski's ability to live independently and assist his mother.The Third Circuit affirmed the decision, concluding that the ALJ's denial of benefits was supported by substantial evidence and that the regulation did not violate the Social Security Act. View "Zaborowski v. Commissioner Social Security" on Justia Law