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

A minor league baseball team in Oregon lost its longstanding affiliation with a Major League Baseball (MLB) club after MLB restructured its relationship with minor league teams in 2020. The team’s owner alleges that a minority owner of an MLB franchise, who also served on the board and a negotiation committee of the national minor league association, acted to reduce the number of minor league clubs for personal gain, which resulted in the team’s exclusion from the new affiliation structure. The owner claims that the association’s rules left it dependent on the board and committee members to protect its interests.The United States District Court for the District of New Jersey dismissed the owner’s complaint, finding that it failed to plausibly allege the existence of a fiduciary relationship between the board member and the team. The owner appealed, arguing that fiduciary duties arose under Florida’s non-profit statute, by contract, or by implication due to the structure of the association and the interactions between the parties.The United States Court of Appeals for the Third Circuit reviewed the District Court’s dismissal de novo. The Third Circuit held that Florida’s non-profit statute does not create a fiduciary duty from a director to the members of the non-profit, only to the corporation itself. The court also found no express or implied fiduciary duty arising from contractual provisions or the surrounding circumstances. The court distinguished direct and derivative actions and concluded that the complaint did not allege facts to support a direct or implied fiduciary relationship. Accordingly, the Third Circuit affirmed the District Court’s dismissal of the complaint for failure to state a claim. View "Sports Enterprises Inc v. Goldklang" on Justia Law

The case concerns an individual who was stopped by police after a reported road-rage incident in which a firearm was allegedly brandished. During the traffic stop, officers observed a loaded firearm in plain view. The defendant, who had prior felony convictions and was still on state parole, was then charged with unlawful possession of a firearm by a felon in violation of federal law.After a jury trial in the United States District Court for the Middle District of Pennsylvania, the defendant was convicted of the charged offense. At sentencing, the District Court calculated the advisory guidelines range based on the defendant’s criminal history and prior convictions, including a prior drug offense and an unlawful wounding conviction. The Court determined that these prior convictions triggered a heightened sentencing range under the guidelines, but imposed a sentence below the statutory maximum. The defendant appealed, challenging both the sufficiency of the evidence regarding the interstate commerce element and the constitutionality of the statute as applied, as well as the classification of his prior unlawful wounding conviction as a “crime of violence” under the guidelines.Reviewing the appeal, the United States Court of Appeals for the Third Circuit held that the defendant’s challenges to his conviction were foreclosed by binding circuit precedent. On the sentencing issue, the court acknowledged that a recent Supreme Court decision, Delligatti v. United States, abrogated prior circuit precedent regarding the interpretation of “crime of violence.” Under Delligatti, the defendant’s prior unlawful wounding conviction qualifies as a crime of violence for purposes of the sentencing guidelines. The Third Circuit accordingly affirmed both the conviction and the sentence. View "USA v. Minter" on Justia Law

Mahmoud Khalil, an Algerian citizen and lawful permanent resident, was arrested in March 2025 by Homeland Security agents at his New York City apartment and charged as removable under the Immigration and Nationality Act’s foreign-policy provision. Khalil, a Columbia University student and vocal advocate for Palestinian rights, was accused of having activities with potentially adverse foreign policy consequences for the United States. After his arrest, he was quickly transferred from New York to New Jersey, and then to Louisiana. His attorney initially filed a habeas petition in the Southern District of New York, seeking to enjoin his detention and removal, arguing retaliation against protected speech, and due process violations.The Southern District of New York, finding Khalil was already detained in New Jersey when the petition was filed, transferred the case to the U.S. District Court for the District of New Jersey. The New Jersey District Court asserted jurisdiction, denied the government’s motion to dismiss, and determined that the INA did not strip it of subject-matter jurisdiction. The court granted Khalil’s motion for a preliminary injunction on the foreign-policy removal charge, ordered that he not be removed, and later ordered his release from custody. Meanwhile, an immigration judge in Louisiana found Khalil removable on both foreign-policy and fraud charges and ordered his removal, resulting in conflicting mandates.Reviewing the case, the U.S. Court of Appeals for the Third Circuit held that the District Court had habeas jurisdiction, as the petition was properly transferred and related back to Khalil’s district of confinement. However, the Third Circuit found that 8 U.S.C. § 1252(b)(9) of the INA strips the District Court of subject-matter jurisdiction over claims arising from removal actions, channeling such claims into a petition for review of a final order of removal in the court of appeals. As a result, the Third Circuit vacated and remanded with instructions to dismiss Khalil’s habeas petition. View "Khalil v. President United States of America" on Justia Law

Nicole Schuster, a mechanical engineer at the Naval Foundry and Propeller Center, led two Navy procurement projects for large machines known as vertical turning centers (VTCs) in 2017 and 2019. In 2017, she favored Company 1, which won the SU22 contract, while Company 2’s bid was rejected as technically unacceptable. In 2019, Schuster again favored Company 1 for the SU25 contract and, after learning Company 2 had bid, she disclosed Company 2’s confidential bid information from the earlier SU22 procurement to an employee of Company 1. This information included cost data and proprietary manufacturing details. Company 1 subsequently won the SU25 contract, with Company 2’s bid deemed too expensive.Schuster was charged in the United States District Court for the Eastern District of Pennsylvania with violating the Procurement Integrity Act, specifically 41 U.S.C. §§ 2102(a) and 2105(a), which prohibit disclosure of contractor bid or proposal information before the award of the procurement to which the information relates. Schuster pled guilty based on a plea agreement, which included a factual basis describing the machines as “virtually identical” but did not detail whether the information she disclosed was the same in substance as that submitted for the pending SU25 procurement. The District Court accepted her guilty plea and sentenced her to one year and one day in prison.The United States Court of Appeals for the Third Circuit reviewed the case, applying plain error review to Schuster’s challenge to the sufficiency of the factual basis for her plea. The Court held that the District Court erred by accepting the guilty plea without sufficient facts to establish that the disclosed information related to the pending procurement as required by statute. The Third Circuit vacated Schuster’s conviction and sentence and remanded the case for repleading, rather than entering judgment of acquittal. View "United States v. Schuster" on Justia Law

Christopher Texidor was charged alongside several codefendants for participating in a large-scale drug trafficking organization that conspired to ship nearly 3,000 kilograms of marijuana from California to Pennsylvania using the United States Postal Service. Texidor used his business, Fastlane Auto Sales, LLC, and his residence to facilitate these activities. He recruited various individuals, including family members, to receive shipments and organized GPS tracking for parcels after noticing thefts. When the group determined a postal employee was responsible for stealing their parcels, Texidor and others organized violent acts to intimidate him, including drive-by shootings and theft of the employee’s vehicle containing drugs and a firearm. During searches, law enforcement discovered drugs, tracking devices, firearms, and cash at Texidor’s properties. Texidor was also separately indicted for wire fraud involving false Paycheck Protection Program loan applications, which he committed while on pretrial release.Following a six-day trial in the U.S. District Court for the Middle District of Pennsylvania, a jury convicted Texidor on most drug and firearm counts, but acquitted him of the cocaine charge and a related firearm count. Texidor later pleaded guilty to one count of wire fraud, with other fraud charges dismissed. The District Court considered both cases at sentencing, calculated a Guidelines range of 292–365 months, and imposed concurrent sentences: 292 months for the drug/firearm offenses and 240 months for wire fraud. The District Court struck one reference to cocaine from the Presentence Investigation Report but overruled objections to other references and applied a four-level leadership enhancement.The U.S. Court of Appeals for the Third Circuit affirmed the District Court’s rulings. It held that recent changes to the Sentencing Guidelines do not prevent consideration of acquitted conduct when determining an appropriate sentence outside of Guidelines calculations. The Court found no clear error in applying the leadership enhancement and concluded that the aggregate sentence was substantively reasonable. Further, under the concurrent sentence doctrine, the Court declined to review the substantive reasonableness of the wire fraud sentence. View "USA v. Texidor" on Justia Law

Ryan Mendoza checked into a Pittsburgh hotel for a two-night stay, receiving a receipt indicating his departure date as February 25. The hotel had a posted noon checkout time, and guests could leave either by visiting the front desk or simply walking out. By noon on February 25, Mendoza had not checked out at the front desk, so hotel staff placed him on a “due-out” list and inspected his room. Later that afternoon, the hotel manager discovered a backpack with packages of white powder and called the police. Around 5:20 p.m., officers entered the room without a warrant and confirmed with the manager that Mendoza’s stay had ended and he no longer had rights to the room. Mendoza returned to the hotel at 10:00 p.m. and was arrested.In the United States District Court for the Western District of Pennsylvania, Mendoza moved to suppress the evidence obtained during the warrantless search of the hotel room, arguing that he retained a Fourth Amendment privacy interest in the room because he had not formally checked out. The District Court denied the motion, finding that Mendoza did not have a reasonable expectation of privacy in the room after checkout time, based on hotel policies and practices.The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and exercised plenary review over its legal determinations. The Third Circuit held that Mendoza’s expectation of privacy in the hotel room five hours after checkout time was not objectively reasonable. The court emphasized that, absent any communication about a late checkout or ambiguous circumstances, society does not recognize an expectation of privacy in a hotel room well after checkout time. Accordingly, the Third Circuit affirmed the District Court’s denial of the motion to suppress. View "USA v. Mendoza" on Justia Law

Ousmane Savane, a citizen of Côte d’Ivoire, entered the United States in 2012 through the Diversity Visa Program. During his initial application (the eDV), and in his subsequent Application for Immigrant Visa and Alien Registration (DS-230), Savane did not disclose that he had two children, despite both forms requiring such information. He later explained that he omitted his children on the advice of a “coach” who helped him complete the forms, believing that doing so would facilitate his entry for financial reasons. The consular officer who interviewed Savane did not ask about his children, and Savane was admitted as a lawful permanent resident.In 2020, Savane applied for naturalization and disclosed all four of his children. He initially denied, but later admitted, that he had previously lied to U.S. officials to gain immigration benefits. The United States Citizenship and Immigration Services (USCIS) denied his naturalization application, finding that his earlier omissions rendered him not “lawfully admitted for permanent residence.” Savane appealed administratively, arguing that the omissions were immaterial, but USCIS affirmed its denial. He then petitioned for review in the United States District Court for the Eastern District of Pennsylvania, which granted summary judgment for the government, holding that Savane’s omission was material because it shut off a line of inquiry relevant to his eligibility.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that, under 8 C.F.R. § 103.2(a)(2), an omission from an immigration application is material if it prevents investigation into a relevant aspect of eligibility, regardless of whether the omitted information would have led to denial. The court concluded that Savane’s failure to disclose his children precluded the consular officer from properly evaluating his eligibility, particularly regarding whether he was likely to become a public charge. The Third Circuit affirmed the District Court’s summary judgment for the government. View "Savane v. Secretary United States Department of Homeland Sec" on Justia Law

In November 2020, a United States Coast Guard cutter intercepted a vessel in international waters, far from Colombia. The vessel attempted to flee but was stopped and boarded. On board, authorities found three occupants—two Costa Rican nationals, including Munoz, and a Colombian national—and seized 383 kilograms of cocaine. The vessel lacked any registration documents, flag, or markings indicating nationality, and all occupants claimed to be the master without asserting the vessel’s nationality when prompted by Coast Guard officials. Based on these facts, the Coast Guard determined the vessel was subject to United States jurisdiction.A grand jury in the District Court of the Virgin Islands indicted Munoz for conspiracy and possession with intent to distribute cocaine under the Maritime Drug Law Enforcement Act (MDLEA). Munoz moved to dismiss the indictment, arguing that the MDLEA was unconstitutional and that the United States lacked jurisdiction over the vessel, requesting an evidentiary hearing. The District Court denied his motion without a hearing. Munoz then entered a conditional guilty plea to the conspiracy charge, preserving his right to appeal the denial of his motion to dismiss. After sentencing, the government dismissed the possession charge per the plea agreement, and Munoz timely appealed.The United States Court of Appeals for the Third Circuit reviewed Munoz’s constitutional challenge to the MDLEA and the District Court’s refusal to hold an evidentiary hearing. The court held that the MDLEA does not exceed Congress’s authority under the Felonies Clause of Article I, Section 8, Clause 10 of the Constitution, because the Felonies Clause is not limited by international law. It also held that the District Court did not abuse its discretion by declining to hold an evidentiary hearing, as the parties had stipulated to all material facts, leaving only legal questions for resolution. The Third Circuit affirmed the judgment. View "USA v. Munoz" on Justia Law

A woman rented a car from a rental company in 2014 and, after a traffic camera recorded a violation during her rental, the company paid the fine and charged her both the fine amount and an administrative fee. She filed a putative class action in the United States District Court for the District of New Jersey on behalf of customers who were charged fines and fees in similar circumstances, alleging state-law claims such as violations of consumer fraud statutes and unjust enrichment. The rental company later updated its rental agreements in 2016 to include an arbitration clause and class-action waiver, but this provision applied only prospectively to rentals after its adoption. The named plaintiffs’ rentals predated this clause.The District Court, after years of litigation that included several amended complaints, discovery, mediation, and a motion to certify a class, ultimately certified a subclass that included some renters whose agreements contained the arbitration provision. The District Court found that the rental company had waived its right to enforce arbitration by participating in litigation for several years without moving to compel arbitration. The company then filed a motion to compel arbitration for the affected class members, which the District Court denied again on waiver grounds, emphasizing that the company had not sought to enforce arbitration until after class certification.On appeal, the United States Court of Appeals for the Third Circuit reviewed the waiver issue de novo. The Third Circuit held that waiver of the right to compel arbitration did not occur here, because the company’s conduct—such as raising arbitration as an affirmative defense and the futility of seeking to compel arbitration prior to class certification—did not evince an intentional relinquishment of that right. The Third Circuit vacated the District Court’s order denying the motion to compel arbitration and remanded for consideration of other unresolved questions about enforceability. View "Valli v. Avis Budget Group Inc" on Justia Law

Police investigating a fatal drive-by shooting in Philadelphia identified several suspects, including T.C., and obtained an arrest warrant for him. Detectives used multiple databases, including CLEAR and police records, to determine T.C.’s last known address, which pointed to 4838 Stenton Avenue. Believing T.C. resided there, detectives and a SWAT team executed the warrant early one morning. Instead of finding T.C., officers encountered Richard Miller and Tonya Crawley, who had lived at the residence for two years and were not connected to T.C. The officers detained Miller and Crawley briefly and then left after learning T.C. was not present. T.C. was later located and cleared of wrongdoing.Miller and Crawley sued the involved officers and the City of Philadelphia in the United States District Court for the Eastern District of Pennsylvania under 42 U.S.C. § 1983, alleging that the officers lacked probable cause and violated the Fourth Amendment, and that the City failed to train or supervise its officers. The District Court dismissed the municipal-liability claim for failure to state a claim and granted summary judgment to the officers on the unlawful-entry claim, holding that they had probable cause to enter the residence.On appeal, the United States Court of Appeals for the Third Circuit reviewed both the dismissal and summary judgment de novo. The court held that, although the District Court incorrectly invoked the good-faith exception, the error was harmless because the officers had probable cause to believe T.C. lived at the address and would likely be home at the early hour. The court also held that the plaintiffs failed to allege facts sufficient to establish municipal liability, as there was no pattern of similar constitutional violations or plausible basis for single-incident liability. The Third Circuit affirmed the District Court’s decisions. View "Miller v. City of Philadelphia" on Justia Law