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

Jeffrey Herrera filed a pro se complaint alleging that he was detained for several months beyond his maximum release date, which he claimed violated the Eighth Amendment. Herrera was arrested in September 2012, sentenced in March 2013 to 36 to 72 months’ imprisonment, and released on parole in December 2014. After violating parole, his sentence was reduced in January 2017 to 30 to 66 months, with credit for time served. Despite this, Herrera claimed he was detained until October 2019, seven months past his maximum release date of March 2019.The United States District Court for the Middle District of Pennsylvania dismissed Herrera’s complaint under 28 U.S.C. § 1915(e), reasoning that his claim must be brought as a habeas corpus petition under 28 U.S.C. § 2254 and that his claim for damages was barred by Heck v. Humphrey, 512 U.S. 477 (1994). The court also found that any amendment to the complaint would be futile. Herrera’s motions for reconsideration and relief from judgment were denied, with the court maintaining that his claim was barred by Heck and the statute of limitations.The United States Court of Appeals for the Third Circuit reviewed the case and determined that Heck does not apply to Herrera’s overdetention claim because it does not imply that his conviction or sentence were invalid. The court found that Herrera plausibly pleaded an Eighth Amendment overdetention claim, as he alleged that prison officials were aware of his overdetention and failed to act, resulting in his prolonged detention. However, the court noted that the claim might be time-barred under Pennsylvania’s two-year statute of limitations but remanded the case to allow Herrera to amend his complaint to address potential tolling of the statute of limitations. The Third Circuit vacated the District Court’s order and remanded for further proceedings. View "Herrera v. Pennsylvania Board of Probation and Parole" on Justia Law

Richard Hightower, a pretrial detainee, was attacked by his cellmate, Anthony Tyler, in a Philadelphia jail, resulting in Hightower's paralysis. Hightower was classified as a low-security risk, while Tyler was classified as a high-security risk with a history of violent behavior. Due to a mistake by a prison health services company, Tyler was placed in Hightower's intake cell instead of being transferred to a permanent cell. Tyler's aggressive behavior escalated, culminating in a violent attack on Hightower.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the City of Philadelphia and the guards. Hightower did not appeal the judgment for the guard but did appeal the judgment for the city.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Hightower failed to prove that the city caused any constitutional violation. To succeed in his Monell claim, Hightower needed to show that the city had an unconstitutional policy or custom or was deliberately indifferent to inmates' rights. The court found that the city had no policy of not separating inmates by security-risk level during intake and that the lack of a policy is not a policy. Additionally, Hightower could not show a custom that violated his rights or that the city acted with deliberate indifference. The court concluded that the risk to Hightower was not so obvious that the city could be held liable without a pattern of similar violations.The Third Circuit affirmed the District Court's summary judgment in favor of the City of Philadelphia. View "Hightower v. City of Philadelphia" on Justia Law

Promise Healthcare Group, LLC and its affiliates operated various hospital and nursing facilities. During their Chapter 11 bankruptcy proceedings, Patrick Wassmann filed a $10 million medical malpractice claim based on treatment he received at one of the facilities between March 15 and June 9, 2017. Robert Michaelson, the liquidating trustee, objected to Wassmann’s claim, arguing it was time-barred because it became untimely by the time the Trustee objected to it and it was evaluated. The Trustee also argued that Wassmann’s claim should be barred because he failed to file a timely state court complaint in addition to his Chapter 11 proof of claim.The United States Bankruptcy Court for the District of Delaware set a bar date of May 31, 2019, for filing proof of claims. Wassmann filed his proof of claim on January 4, 2019. The court confirmed the Debtors’ reorganization plan on September 17, 2020, which went into effect on October 1, 2020. Wassmann had until November 1, 2020, to proceed against the Debtors in state court but chose to seek recovery in the Bankruptcy Court alone. The Bankruptcy Court denied the Trustee’s motion for summary judgment, reasoning that the claims allowance process under 11 U.S.C. § 502 evaluates claims as of the petition date and that a timely proof of claim does not require a separate timely non-bankruptcy complaint.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the Bankruptcy Court’s order. The Third Circuit held that the enforceability of a claim under 11 U.S.C. § 502(b) is determined as of the petition date, not the date of the court’s evaluation. The court also held that a creditor who has filed a timely proof of claim is not required to file a separate, timely non-bankruptcy action to preserve the claim. The court concluded that the Bankruptcy Court correctly allowed Wassmann’s claim as it was timely as of the petition date. View "In re: Promise Healthcare Group LLC" on Justia Law

A New York wine retailer, Jean Paul Weg LLC, and its owner, Lars Neubohn, challenged New Jersey's regulations that require wine retailers to have a physical presence in the state and to purchase their products from New Jersey licensed wholesalers. These regulations prevent the retailer from directly shipping wine to New Jersey customers. The plaintiffs argued that these requirements violate the Commerce Clause by discriminating against out-of-state economic interests.The United States District Court for the District of New Jersey denied the plaintiffs' motion for summary judgment and granted summary judgment in favor of the defendants, including the Director of the New Jersey Division of Alcoholic Beverage Control and the Attorney General of New Jersey. The District Court found that New Jersey's regulations were justified by legitimate local purposes, such as ensuring alcohol sold to New Jersey consumers passes through the state's three-tier system and facilitating inspections to ensure compliance with regulations.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit held that New Jersey's regulations, while discriminatory in effect, were justified on legitimate nonprotectionist grounds. The court found that the physical presence requirement facilitates inspections and investigations, while the wholesaler purchase requirement helps quickly identify sources of contamination and facilitates product recalls. Additionally, the court determined that these regulations are essential features of New Jersey's three-tier system of alcohol regulation, which is "unquestionably legitimate" under the Twenty-first Amendment. Therefore, the challenged regulations were upheld as constitutional. View "Jean-Paul Weg LLC v. Director of the New Jersey Division of Alcoholic Beverage Control" on Justia Law

Rodney Ashe was pulled over by police on October 3, 2022, for failing to maintain his lane. During the stop, officers observed a handgun in his sweatshirt pocket, leading to his arrest and the impoundment of his car. Six months later, while Ashe was incarcerated, a duffle bag containing an AK-style pistol and ammunition was found in the trunk of his car by a towing company employee. Ashe pleaded guilty to being a felon in possession of a firearm related to the handgun found during the traffic stop.The United States District Court for the District of New Jersey held a sentencing hearing on December 21, 2023. Both the Government and the defense argued for a total offense level of 12, but the District Court found a total offense level of 17, applying an enhancement for possession of the AK-style pistol. The court determined that a preponderance of the evidence supported Ashe’s constructive possession of the AK pistol, based on its location in his trunk and his history of firearm-related offenses. Ashe was sentenced to 37 months of imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that the District Court erred in applying the enhancement without sufficient evidence that Ashe possessed the AK pistol. The appellate court noted that the six-month gap between Ashe’s arrest and the discovery of the firearm, combined with the lack of direct evidence linking Ashe to the AK pistol, did not meet the preponderance of the evidence standard required for constructive possession. Consequently, the Third Circuit vacated Ashe’s sentence and remanded the case for resentencing without the enhanced base offense level. View "USA v. Ashe" on Justia Law

In the early morning of December 15, 1987, Richard Laird and Frank Chester brutally murdered Anthony Milano in a wooded area in Bristol, Pennsylvania. Milano, a 26-year-old homosexual man, was beaten and had his neck and throat slashed multiple times, leading to his death. Laird and Chester were arrested and tried for first-degree murder, among other charges. Both were convicted and sentenced to death. Laird's defense included claims of ineffective assistance of counsel, particularly regarding the failure to present expert testimony on the sexual abuse he suffered as a child.Laird's initial conviction and death sentence were affirmed by the Pennsylvania Supreme Court in 1991. He sought post-conviction relief, which was denied by the PCRA Court and affirmed by the Pennsylvania Supreme Court in 1999. Laird then filed a federal habeas petition, which resulted in the vacating of his first-degree murder conviction and death sentence in 2001. The case was remanded for a retrial, and in 2007, Laird was again convicted of first-degree murder and sentenced to death. The Pennsylvania Supreme Court affirmed this conviction and sentence in 2010.Laird filed another PCRA petition, claiming ineffective assistance of counsel for failing to present an expert on childhood sexual abuse. The PCRA Court denied relief, and the Pennsylvania Supreme Court affirmed, finding that the additional expert testimony would have been cumulative and not likely to change the outcome. Laird then filed a federal habeas petition, which was denied by the District Court.The United States Court of Appeals for the Third Circuit reviewed the case, focusing on whether counsel was ineffective for not presenting an additional expert on childhood sexual abuse. The court held that the PCRA Court's decision was reasonable and that counsel's performance did not fall below an objective standard of reasonableness. The court affirmed the District Court's denial of the habeas petition. View "Laird v. Secretary of Dept. of Corrections" on Justia Law

Joseph Cammarata and his associates, Eric Cohen and David Punturieri, created Alpha Plus Recovery, LLC, a claims aggregator that submitted fraudulent claims to securities class action settlement funds. They falsely represented that three entities, Nimello, Quartis, and Invergasa, had traded in securities involved in class action settlements, obtaining over $40 million. The fraudulent claims included falsified trade data and fabricated reports. The scheme unraveled when a claims administrator, KCC, discovered the fraud, leading to the rejection of the claims and subsequent legal action.The United States District Court for the Eastern District of Pennsylvania charged the defendants with conspiracy to commit mail and wire fraud, wire fraud, conspiracy to commit money laundering, and money laundering. Cohen and Punturieri pled guilty, while Cammarata proceeded to trial and was found guilty on all counts. The District Court sentenced Cammarata to 120 months in prison, ordered restitution, and forfeiture of certain property.The United States Court of Appeals for the Third Circuit reviewed the case. The court upheld most of the District Court's rulings but found issues with the restitution order and the forfeiture of Cammarata's vacation home. The court held that the restitution order did not fully compensate the victims, as required by the Mandatory Victims Restitution Act (MVRA), and remanded for reconsideration. The court also found procedural error in the forfeiture process, as Cammarata was deprived of his right to a jury determination on the forfeitability of his property. The court vacated the forfeiture order in part and remanded for the Government to amend the order to reflect that the property is forfeitable as a substitute asset under 21 U.S.C. § 853(p). View "USA v. Cammarata" on Justia Law

Malik Moss was convicted of conspiracy to distribute methamphetamine and heroin. The District Court held an evidentiary hearing to determine the quantity and purity of the methamphetamine attributable to Moss for sentencing purposes. The government presented evidence of two purchases by Moss and his co-conspirator, Jacob Santiago, on October 27-28, 2021, and November 11, 2021. The evidence included phone calls, cellphone data, text messages, and recorded statements indicating that Moss and Santiago bought a total of fifteen pounds of methamphetamine. The District Court also considered the purity levels of controlled purchases made directly from Moss, which ranged from 62% to 95%, and applied the lowest purity level of 62% to calculate Moss's sentence.The District Court initially scheduled the evidentiary hearing for December 12, 2022, but rescheduled it for December 21 due to Santiago's absence. During the December 12 proceeding, the government informed the court that a cooperating co-conspirator wished to breach his cooperation agreement and not testify. At the December 21 hearing, U.S. Marshals observed Moss's girlfriend's friend attempting to record the proceeding. The government later submitted evidence from Moss's prison communications showing that he had arranged for the recording to expose the co-conspirator and had sent threatening notes to the co-conspirator's family. Based on this evidence, the District Court applied an obstruction-of-justice enhancement and added two points to Moss's base offense level.The United States Court of Appeals for the Third Circuit reviewed the case and found no clear error in the District Court's factual findings related to the drug quantity, drug purity, and the application of the obstruction-of-justice enhancement. The Third Circuit affirmed the District Court's judgment, upholding Moss's 384-month sentence. View "United States v. Moss" on Justia Law

George Pitsilides, a successful restaurateur and professional poker player, was convicted in 1998 in Pennsylvania for criminal conspiracy to commit pool selling and bookmaking, and two counts of pool selling and bookmaking. These offenses are classified as first-degree misdemeanors in Pennsylvania, punishable by up to five years’ imprisonment. Consequently, under 18 U.S.C. § 922(g)(1), Pitsilides is barred from possessing a firearm. Despite these convictions, Pitsilides continued to engage in illegal gambling activities, leading to further convictions in Virginia in 2011 for operating an illegal gambling enterprise.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the Government, applying the two-step framework from Binderup v. Attorney General. The court concluded that Pitsilides failed to show his convictions were not serious and rejected his argument that his offenses fell within the carveout for business-related offenses under 18 U.S.C. § 921(a)(20)(A).The United States Court of Appeals for the Third Circuit reviewed the case. The court noted that the legal landscape had changed significantly since the District Court's decision, particularly with the Supreme Court's rulings in New York State Rifle & Pistol Ass’n v. Bruen and United States v. Rahimi, and the Third Circuit's en banc decision in Range v. Attorney General. These cases emphasized the need for individualized assessments of whether a felon poses a danger to public safety when challenging firearm prohibitions under the Second Amendment.The Third Circuit concluded that the record was insufficient to determine whether § 922(g)(1) is unconstitutional as applied to Pitsilides. The court affirmed in part, vacated in part, and remanded the case to the District Court for further factual development to assess whether Pitsilides poses a special danger of misusing firearms. View "Pitsilides v. Barr" on Justia Law

Michael Milchin pleaded guilty to healthcare fraud, conspiracy to commit healthcare fraud, conspiracy to distribute oxycodone, and possession of oxycodone with intent to distribute. He was sentenced to 168 months of imprisonment and three years of supervised release. Milchin filed multiple motions for compassionate release and sentence reductions based on various grounds, including his health and the threat of COVID-19, but these were denied. This appeal concerns his motion for a sentence reduction under 18 U.S.C. § 3582(c)(2) based on the new U.S.S.G. § 4C1.1, which allows an offense-level reduction for certain offenders with zero criminal history points at the time of sentencing.The United States District Court for the Eastern District of Pennsylvania first concluded that Milchin was not eligible for the reduction on November 13, 2023, and dismissed his motion without prejudice due to a stay on motions seeking retroactive application of § 4C1.1. Milchin's subsequent request for appointment of counsel was denied on March 1, 2024, as the court determined he did not qualify for a sentence reduction. On March 4, 2024, Milchin filed an "Emergency Motion for Sentence Reduction," which was also denied by the District Court, citing its earlier orders. Milchin then appealed.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Milchin was not eligible for the offense-level reduction under U.S.S.G. § 4C1.1 because he had received an aggravating role adjustment. The court interpreted § 4C1.1(a)(10) to disqualify any defendant who either received an aggravating role adjustment or was engaged in a continuing criminal enterprise. The court affirmed the District Court's judgment, concluding that Milchin did not meet the criteria for a sentence reduction under the new guideline. View "USA v. Michael Milchin" on Justia Law