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

A national firearms industry trade association challenged the constitutionality of a New Jersey statute enacted in 2022, which imposes civil liability on gun industry members for certain “public nuisance” conduct related to the sale, manufacture, distribution, import, or marketing of firearms and related products. The law allows the state to bring enforcement actions against gun industry members for actions deemed unlawful or unreasonable, as well as for failing to implement “reasonable controls.” The association argued that the statute is unconstitutional under the Interstate Commerce Clause, the First and Second Amendments, and is preempted by the federal Protection of Lawful Commerce in Arms Act (PLCAA).Initially, the United States District Court for the District of New Jersey granted a preliminary injunction against enforcement of the law, but the United States Court of Appeals for the Third Circuit vacated that injunction, holding that the association lacked Article III standing because enforcement of the law was speculative at that time. After the state initiated several enforcement actions under the statute—including suits against two members of the association—the association moved to reopen the case, amend its complaint, and again seek a preliminary injunction. The District Court found standing but abstained from ruling on the merits under the Younger abstention doctrine, which generally prohibits federal courts from interfering with certain ongoing state proceedings.The United States Court of Appeals for the Third Circuit reviewed the case and held that the association now has standing due to the substantial risk of imminent enforcement against its members, evidenced by the state’s recent lawsuits. The court further held that Younger abstention does not apply because the association is not a party to any ongoing state proceeding and does not have the type of control or relationship with its members that would warrant abstention. Accordingly, the Third Circuit reversed the District Court’s order. View "National Shooting Sports Foundation v. Attorney General New Jersey" on Justia Law

A company sought to expand its interstate natural gas pipeline by constructing a new pipeline segment beneath Raritan Bay, New Jersey. This work required dredging the bay floor, which would disturb sediment containing toxic contaminants. Several environmental organizations challenged the state agency’s decision to grant a Water Quality Certification for the project, arguing that the agency reversed a prior denial without adequate explanation, certified the project before resolving essential monitoring and management requirements, inadequately explained how the project would meet state water quality standards, and failed to provide sufficient public participation opportunities.Previously, the New Jersey Department of Environmental Protection (NJDEP) had denied the company’s application in 2019, citing insufficient information to determine compliance with water quality standards, including concerns over contaminants like 4,4’–DDE. The company submitted additional modeling and monitoring plans in subsequent applications, but NJDEP again denied certification in 2020 after New York rejected the corresponding application. In 2025, following New York’s approval, NJDEP granted the Water Quality Certification, imposing several conditions, including post-certification submission of finalized monitoring and adaptive management plans.The United States Court of Appeals for the Third Circuit reviewed the petitions after transfer from the Second Circuit. The court held that NJDEP acted arbitrarily and capriciously by deferring the finalization of material monitoring and adaptive management plans until after certification without requiring agency approval before the start of dredging. The court also found NJDEP failed to adequately explain how the project would comply with water quality standards, particularly regarding toxic contaminant monitoring and shellfish impacts. Accordingly, the Third Circuit granted the petitions, vacated the Water Quality Certification, and remanded the matter to NJDEP for further proceedings. View "Natural Resources Defense Council Inc v. New Jersey Department of Environmental Protection" on Justia Law

Federal agents intercepted a package containing three silencers shipped from China to Joseph Berger’s residence in Bethlehem, Pennsylvania. Upon searching the home with a warrant, agents discovered more than sixty firearms, including thirteen fully automatic guns (mostly AK-47 variants), a dozen silencers, and parts for converting semi-automatic weapons into machine guns. Berger was indicted for possession of machine guns and unregistered silencers, violations of federal law. He is a Navy veteran who lived with his father, and evidence suggested both were involved in acquiring conversion parts.In the U.S. District Court for the Eastern District of Pennsylvania, Berger raised an as-applied Second Amendment challenge. The court denied his challenge, finding that machine guns were “dangerous and unusual weapons” not commonly used for self-defense, and that silencers were not “bearable arms” under the Second Amendment. Berger then pleaded guilty to possessing a machine gun and an unregistered silencer, reserving his right to appeal the Second Amendment issue. The government dismissed the charge of possessing an unregistered machine gun as part of the plea agreement.The United States Court of Appeals for the Third Circuit reviewed Berger’s appeal de novo, focusing on pure issues of law. The court held that the Second Amendment does not protect possession of machine guns because they are not commonly used for lawful purposes and are classified as “dangerous and unusual.” Furthermore, the registration requirement for silencers under the National Firearms Act imposes only a minimal, objective burden and does not infringe upon Second Amendment rights. The court affirmed Berger’s conviction and sentence, holding that both the machine-gun ban and the silencer registration requirement are constitutional as applied to Berger. View "USA v. Berger" on Justia Law

Police investigating a suspicious package at a UPS facility in Pennsylvania discovered it contained methamphetamine after a drug-sniffing dog alerted and a search warrant was obtained for the box. Officers planned to track the package with a GPS device and sought judicial authorization for a “hit-and-hold” procedure: if the package was brought into any location other than the listed delivery address (Apartment 2), they would secure the package there and then apply for a search warrant for the new location. The judge issued a tracker order and a search warrant for Apartment 2 but did not explicitly authorize entry into any other apartment. When the package was instead brought into Apartment 1 by Davone Walker, officers entered Apartment 1 to secure the package, then obtained a search warrant for that apartment and found substantial quantities of drugs.Walker was charged with drug offenses in the United States District Court for the Eastern District of Pennsylvania. He moved to suppress the evidence found in Apartment 1, arguing that the officers’ warrant did not authorize entry into his apartment. The District Court found that Trooper Montz unreasonably believed he was permitted to enter Apartment 1 based on the tracker order but concluded this mistake was at most isolated negligence rather than gross negligence or deliberate misconduct, and thus denied the suppression motion. Walker then entered a conditional guilty plea, reserving the right to appeal.The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and legal conclusions de novo. The Third Circuit held that the exclusionary rule does not apply to evidence obtained through an officer’s isolated or negligent mistake unless the conduct is deliberate, reckless, grossly negligent, or part of systemic misconduct. Because Trooper Montz’s mistake was not grossly negligent, the court affirmed the denial of the suppression motion and Walker’s conviction. View "USA v. Walker" on Justia Law

The case concerns a noncitizen from El Salvador who lawfully entered the United States on a nonimmigrant temporary visa with work authorization. While residing in the United States, he was stopped by a Pennsylvania state trooper for a traffic violation. During the stop, the officer observed a rifle cartridge in the vehicle, leading to a search warrant and the discovery of a loaded pistol without a serial number. The individual admitted to purchasing the pistol in Maryland.He was indicted by a grand jury for violating 18 U.S.C. § 922(g)(5)(B), a statute prohibiting nonimmigrant visa holders from possessing firearms. He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The United States District Court for the Middle District of Pennsylvania denied his motion, holding the statute constitutional. After entering a conditional guilty plea, reserving his right to appeal the constitutional issue, he was sentenced to twenty-four months’ imprisonment and one year of supervised release.On appeal, the United States Court of Appeals for the Third Circuit addressed whether 18 U.S.C. § 922(g)(5)(B) is facially unconstitutional under the Second Amendment. The Court, following the framework from New York State Rifle & Pistol Ass’n v. Bruen, assumed without deciding that some noncitizens may be included among “the people” protected by the Second Amendment. The Court then considered whether the statute is consistent with the nation’s historical tradition of firearm regulation. It found that there is a longstanding historical practice of disarming individuals considered disloyal to the sovereign, including noncitizens with allegiance to another country. Concluding that § 922(g)(5)(B) is relevantly similar to these historical analogues, the Court held that the statute does not violate the Second Amendment and affirmed the conviction. View "USA v. Aleman-Lozano" on Justia Law

The petitioner, a lawful permanent resident admitted to the United States in 1993, was ordered removed in 2011 based on a 1997 New York conviction for attempted third-degree criminal sale of cocaine. He did not appeal the removal order at that time but has since attempted several legal challenges to the order, including collateral attacks on his underlying conviction and multiple motions for reopening and reconsideration of the removal order. None of these efforts were successful, though a gubernatorial pardon in 2017 removed the aggravated felony basis for removal, leaving the controlled substance offense as the remaining ground.Following a 2023 decision by the United States Court of Appeals for the Second Circuit (United States v. Minter) interpreting the New York statute at issue, the petitioner filed new motions with the Board of Immigration Appeals (BIA) in 2024 seeking statutory reopening, statutory reconsideration, and sua sponte reopening, arguing that the Second Circuit’s reasoning undermined the basis for his removal. The BIA denied all motions, finding the statutory motions time-barred without justification for equitable tolling, and declined to exercise its sua sponte authority.The United States Court of Appeals for the Third Circuit reviewed the BIA’s decision. It held that a change in law is not a permissible basis for statutory reopening under 8 U.S.C. § 1229a(c)(7), and, while statutory reconsideration may in rare cases be justified by a change in law, the petitioner’s motion was untimely and did not meet the requirements for equitable tolling. The Third Circuit also concluded it lacked jurisdiction to review the BIA’s denial of sua sponte reopening. Accordingly, the court denied the petition as to the statutory motions and dismissed the petition as to sua sponte reopening. View "Aristy-Rosa v. Attorney General United States of America" on Justia Law

The appellant was injured in a car accident while driving a 2002 Ford Explorer in the U.S. Virgin Islands when the vehicle’s airbags allegedly deployed spontaneously, resulting in a loss of control and a collision with a hillside. She claimed that a defect in the vehicle’s airbag system caused the incident. The vehicle had a lengthy history, having changed ownership multiple times, and had been involved in several prior accidents and repairs. Central to her claim was the vehicle’s restraint control module (RCM), which did not record any crash or deployment event during the incident, though its data was available for inspection. The appellant’s experts suggested further testing of the RCM and its sensors, but this was not performed.The case was originally filed in the Superior Court of the Virgin Islands and was removed to the District Court of the Virgin Islands. After various procedural steps, including a transfer to and from the United States District Court for the Eastern District of Michigan, the District Court of the Virgin Islands granted summary judgment to Ford. The court found that, even assuming the applicability of Section 3 of the Restatement (Third) of Torts (“malfunction theory”), the appellant had not provided sufficient evidence to show a defect existed at the time of sale, that such a defect caused the airbag deployment, or that it was the proximate cause of her injuries.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the malfunction theory’s relaxed evidentiary standard did not apply because the allegedly defective product was available for inspection. Even if the standard applied, the appellant’s evidence was too speculative to create a genuine dispute of material fact. The court affirmed the District Court’s grant of summary judgment in favor of Ford. View "Millentine Coates v. Ford Motor Co" on Justia Law

Several plaintiffs challenged a New Jersey law requiring any doctor who wishes to provide telemedicine services to a patient located in New Jersey to first obtain a license from the state’s Board of Medical Examiners. The plaintiffs included two physicians licensed outside New Jersey and three New Jersey residents who wanted to receive virtual medical consultations from those doctors. The doctors argued that New Jersey’s licensing requirement placed an undue burden on their ability to provide telemedicine services, especially since they were already licensed in their home states. The patients and a parent also raised claims based on their rights to receive medical advice and direct their child’s care.The United States District Court for the District of New Jersey dismissed all the plaintiffs’ claims for failure to state a claim. The court held that the licensing requirement did not violate the First Amendment, the dormant Commerce Clause, the Privileges and Immunities Clause, or substantive due process. The plaintiffs appealed, maintaining that the law, as applied, unconstitutionally restricted their right to free speech and imposed excessive burdens on interstate medical practice.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal of all claims, with one modification. The Third Circuit held that requiring a medical license to provide telemedicine services is a content-based restriction on speech, but such regulations have a long tradition and thus do not warrant strict scrutiny. Instead, the law survives intermediate scrutiny because the burdens imposed are not substantial compared to New Jersey’s interest in ensuring competent medical care. The court further held that the law does not violate the dormant Commerce Clause or the Privileges and Immunities Clause, as it applies equally to all doctors regardless of their state of residence. The court also found that the plaintiff asserting a substantive due process right lacked standing, and that claim was ordered dismissed without prejudice for lack of jurisdiction. View "MacDonald v. President NJ State Board of Medical Examiners" on Justia Law

Two nonprofit organizations that engage in nationwide issue advocacy challenged Delaware’s Elections Disclosure Act, which requires groups spending over $500 on electioneering communications near an election to publicly disclose donors giving more than $100 during the relevant cycle. The law’s disclosure obligations are broad: they are not limited to donors earmarking funds for political ads, nor can donors avoid disclosure by restricting the use of their contributions. The law also looks back several years for purposes of disclosure. The organizations, which have not previously run such communications in Delaware but claim they intend to do so in the upcoming election, argue that the law violates the First Amendment.After the organizations filed suit in the U.S. District Court for the District of Delaware, they sought a preliminary injunction to halt enforcement of the Act. The District Court denied the request, finding no likelihood of success on the facial challenge because prior Third Circuit precedent, Delaware Strong Families v. Attorney General of Delaware, had upheld the Act and the Supreme Court’s subsequent decision in Americans for Prosperity Foundation v. Bonta did not clearly abrogate that ruling. The court also doubted the as-applied challenge, citing the plaintiffs’ failure to offer specific evidence of harm to donors. The District Court emphasized the law’s decade-long enforcement and the lack of urgent need to change the status quo.The United States Court of Appeals for the Third Circuit reviewed the denial. Applying a deferential standard, the court found that the plaintiffs had not made a clear showing of entitlement to a preliminary injunction. It held that even with some likelihood of success and possible irreparable injury, the balance of equities and the public interest favored preserving the longstanding status quo. The court affirmed the District Court’s order denying the preliminary injunction. View "Americans for Prosperity Foundation v. Albence" on Justia Law

Two individuals, who were patients of a regional healthcare provider, filed a class action lawsuit alleging that the provider’s website used tracking software to intercept and share users’ personally identifiable health information with a third-party technology company. This software, known as Meta Pixel, collected data such as IP addresses, device identifiers, and details about users’ interactions with the website, transmitting this information to the technology company, which then used it for commercial purposes, including targeted advertising. The healthcare provider also received data analysis from the technology company and was paid for allowing access to this information. The plaintiffs claimed they did not consent to this sharing of their health information.After the claims against the technology company were transferred to another district, the U.S. District Court for the Eastern District of Pennsylvania reviewed several amended complaints against the healthcare provider. The District Court dismissed the plaintiffs’ second amended complaint with prejudice, concluding that the allegations did not sufficiently specify what personal health information was actually shared and that further amendment would be futile. When the plaintiffs sought reconsideration and submitted a proposed third amended complaint, the District Court denied the motion, citing undue delay because the plaintiffs could have included the new details earlier and had been clearly informed of the deficiencies.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed both orders of the District Court. The Third Circuit held that, although plaintiffs had Article III standing, the District Court did not abuse its discretion in dismissing the second amended complaint with prejudice or in denying the motion for reconsideration. The appellate court concluded that plaintiffs had sufficient notice of the complaint’s deficiencies after oral argument and did not act promptly to address them, justifying denial of further amendment. View "Santoro v. Tower Health" on Justia Law