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

A locomotive engineer had longstanding concerns about her employer’s train scheduling practices, believing they led to unsafe conditions by pressuring employees to cut corners. Over a two-year period, she reported these concerns to her union, federal and state agencies, and the Governor’s office. Following a fatal train crash, she raised the issue again at a safety meeting attended by Liberty Mutual Insurance and New Jersey Transit employees. The specifics of this meeting, including which company personnel attended or knew about her participation, remained unclear.After the safety meeting, the engineer committed two significant infractions: first, she operated a train at a speed well above the limit, resulting in suspension after a disciplinary hearing. Her suspension was upheld by internal review boards. Later, she ran a train through a stop signal, leading to her termination after another disciplinary process. The identities of those responsible for the disciplinary decisions were uncertain, and testimony indicated that the signatory on her termination notice was absent at the time. A review board subsequently upheld the termination. After exhausting administrative remedies, the engineer filed suit under the Federal Railroad Safety Act, alleging retaliation for her whistleblowing. The United States District Court for the District of New Jersey granted summary judgment for the employer, finding insufficient evidence of retaliation.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the employee failed to provide evidence that any person involved in the decision to discipline or terminate her knew of her protected activity. The court clarified that, under the Federal Railroad Safety Act, a plaintiff must show knowledge of protected activity by an agent who influenced the adverse action. Because such evidence was lacking, the court affirmed the District Court’s grant of summary judgment for the employer. View "Asay v. New Jersey Transit Rail Operations Inc" on Justia Law

The dispute centers on the President’s House Exhibit in Independence National Historical Park, which commemorates the history of enslaved Africans who lived there during George Washington’s presidency. The City of Philadelphia and the National Park Service (NPS) had established the exhibit through a series of cooperative agreements, culminating in a 2009 amendment that transferred ownership and maintenance responsibility to NPS. In 2026, following an executive order, NPS unilaterally removed interpretive panels and video exhibits from the site without consulting the City, prompting the City to file a lawsuit seeking restoration of the materials.The United States District Court for the Eastern District of Pennsylvania reviewed the City’s claims and granted a preliminary injunction, ordering NPS to restore the President’s House Site to its previous physical status and prohibiting further changes without mutual agreement. The District Court concluded that it had jurisdiction over four claims brought under the Administrative Procedure Act (APA), found that the City had standing based on statutory and contractual rights to mutual agreement and consultation, and determined that NPS’s actions constituted final agency action subject to judicial review.The United States Court of Appeals for the Third Circuit addressed the appeal by first confirming the City’s standing based on alleged contractual injury. However, the court determined that the APA did not permit review of Counts II through V because the NPS’s removal of exhibits was not “agency action” as defined by the APA, nor did it constitute “final agency action.” The court also clarified that statutory provisions requiring mutual agreement applied only to Independence Hall National Historic Site, not the entire park or the President’s House. Accordingly, the Third Circuit vacated the District Court’s preliminary injunction and remanded with instructions to dismiss Counts II through V for lack of jurisdiction. View "City of Philadelphia v. DOI" on Justia Law

Two individuals were prosecuted for their roles in a violent drug-trafficking organization in the U.S. Virgin Islands. One defendant was identified as the leader, convicted by a jury of 22 counts including drug, firearm, and racketeering charges; the other, an armorer, was convicted of seven counts relating to racketeering and firearms. Their trial occurred in March 2022, shortly after the District Court resumed in-person proceedings following COVID-19 restrictions. Initially, all public spectators were required to observe the proceedings from an overflow room via audiovisual feed, rather than in the courtroom itself. After the first day, some spectators, including family members, were permitted into the courtroom, but for several days, court security personnel prevented the defendants’ mothers from entering, even when seats were available.Following their convictions, the defendants moved for a new trial in the District Court of the Virgin Islands, arguing that their Sixth Amendment right to a public trial was violated by these restrictions. After an evidentiary hearing, the court found that some seating was always available on a first-come basis and that any interruptions in the audiovisual feed were brief. The District Court denied the motions, concluding that the public was not excluded from the trial.On 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, but applied plain error review due to the defendants’ failure to make timely objections. The Third Circuit held that there were errors: the initial exclusion of all public spectators and the subsequent exclusion of the defendants’ mothers were unjustified. However, the court also held that these errors did not seriously affect the fairness, integrity, or public reputation of judicial proceedings and therefore did not warrant reversal. The judgments of conviction were affirmed. View "USA v. Harry" on Justia Law

The appellant, Mark Justman, sought to recover accidental death life insurance benefits following the death of his wife, Karen Justman, who died from septic shock caused by a bacterial infection after eating raw oysters. At the time of her death, she was employed by Accenture LLP and was covered by both basic and optional accidental death and dismemberment (AD&D) insurance through a group plan. Prudential Insurance Company of America served as the Claims Administrator in 2021, while Accenture was designated as the Plan Administrator. After Prudential denied Justman’s claim on the grounds that the death was due to illness rather than an accident, Justman exhausted Prudential’s administrative appeals process without success.Justman then filed suit in the United States District Court for the Eastern District of Pennsylvania against both Prudential and Accenture, asserting wrongful denial of benefits under ERISA § 502(a)(1)(B) and breach of fiduciary duty for allegedly failing to provide required summary plan descriptions (SPDs). Prudential settled, leaving only Accenture as a defendant. The District Court dismissed Justman’s claims, finding insufficient factual allegations that Accenture controlled the benefits determination or failed to provide SPDs within statutory deadlines. The court allowed Justman to amend his complaint multiple times but found that further amendment would be futile and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s rulings. The Third Circuit held that a proper defendant in an ERISA § 502(a)(1)(B) claim is the entity with authority over benefits determinations, which in this case was Prudential, not Accenture. The court also concluded that Justman’s claims regarding failure to provide SPDs and breach of fiduciary duty were not plausibly pleaded. The Third Circuit found no abuse of discretion in the denial of leave to amend or reconsideration and affirmed the dismissal with prejudice. View "Justman v. Accenture LLP" on Justia Law

After being convicted in 2007 of kidnapping, corruption of a minor, and various drug offenses, a Pennsylvania prisoner was sentenced to fifteen to thirty years in state prison. He argued that he deserved additional credit for time served, which led him through a series of challenges in both Pennsylvania and federal courts. The Pennsylvania Superior Court remanded his case for a hearing on the time-credit issue, resulting in a modified sentence from the Court of Common Pleas granting him three months and twelve days of additional credit. His appeal for further credit was denied, and subsequent collateral challenges, including a federal habeas petition contesting his convictions and sentence enhancement, were unsuccessful.The United States District Court for the Western District of Pennsylvania dismissed his 2013 federal habeas petition as an unauthorized second or successive petition, finding that the revised sentence did not constitute a “new judgment” under Magwood v. Patterson. He did not appeal that decision, but later filed additional habeas petitions and applications for certificates of appealability, which were all denied. In 2022, nearly eight years after the dismissal, he moved under Federal Rule of Civil Procedure 60(b) to reopen the prior judgment, arguing that later precedent (Lesko v. Secretary, Pa. Dep’t of Corr.) justified relief. The District Court denied the motion, finding no extraordinary circumstances.The United States Court of Appeals for the Third Circuit reviewed whether the District Court abused its discretion in denying relief under Rule 60(b)(6). The Court of Appeals held that a change in procedural law alone does not constitute an extraordinary circumstance justifying reopening a final judgment absent additional equitable factors. Because the petitioner failed to present any facts showing extreme or unexpected hardship or other supporting circumstances, the Third Circuit affirmed the District Court’s denial of the Rule 60(b) motion. View "Williams v. Superintendent Rockview SCI" on Justia Law

Several plaintiffs brought a class action against BMW of North America, alleging the company sold vehicles with defective timing chains. After partial dismissal of initial claims and additional discovery totaling approximately 12,000 pages, the parties reached a settlement resolving the merits of the dispute. However, they could not agree on attorneys’ fees, so a settlement agreement stipulated that class counsel would apply to the court for “reasonable attorneys’ fees” to be paid separately from class relief, with BMW not opposing fees up to $1.5 million and class counsel requesting up to $3.7 million.The U.S. District Court for the District of New Jersey used the lodestar method to calculate fees, finding the hours and rates reasonable and applying a lodestar multiplier that resulted in a $3.7 million award. BMW appealed, and the U.S. Court of Appeals for the Third Circuit previously vacated the fee award, finding the record insufficient to support it and remanding for further proceedings. On remand, class counsel supplemented their billing records and again sought $3.7 million. The district court approved the hours and rates, applied a reduced multiplier, and awarded the same amount. BMW appealed again, challenging the use and calculation of the multiplier and the reasonableness of the hours.The U.S. Court of Appeals for the Third Circuit held that constraints imposed by the Supreme Court on lodestar multipliers in statutory fee-shifting cases, particularly Perdue v. Kenny A. ex rel. Winn, also apply to contractual fee-shifting arrangements governed by federal law. The court found the district court erred by applying a multiplier without considering Perdue’s “strong presumption” that the unenhanced lodestar is reasonable and by approving excessive hours without sufficient justification. The Third Circuit vacated the fee award and remanded for further proceedings. View "Gelis v. BMW of North America LLC" on Justia Law

Milton Thomas filed for Chapter 13 bankruptcy in 2004, listing the City of Philadelphia as a creditor for liens on several properties. Thomas used a lawful process to reduce (“cram down”) the value of the City’s claims and had a bankruptcy plan confirmed in 2005, after which a discharge order was issued in 2009. Despite receiving notice of the proceedings and participating in them by filing claims, the City later sought to collect on liens relating to two properties, the 1618 Property and the 1620 Property, which Thomas argued violated the discharge order.After the discharge, the City began collection actions in state court for these properties. Thomas sought relief in federal court, claiming the City’s actions violated the bankruptcy discharge. The U.S. District Court for the Eastern District of Pennsylvania initially found for Thomas, but the U.S. Court of Appeals for the Third Circuit vacated that decision, instructing that only the Bankruptcy Court could address contempt allegations. On remand, the Bankruptcy Court declined to hold the City in contempt, relying on its earlier 2013 sua sponte ruling that the City had not received constitutionally adequate notice. The District Court affirmed this decision.The United States Court of Appeals for the Third Circuit reviewed the case. The Third Circuit held that the City had actual notice of the bankruptcy and discharge orders and that the 2013 Bankruptcy Court ruling did not provide a reasonable basis for the City’s subsequent conduct. The court found that civil contempt sanctions were warranted as to the 1618 Property, but not the 1620 Property, because Thomas had not shown he met his payment obligations for the latter. The court affirmed in part, vacated in part, and remanded for further proceedings to determine damages for the 1618 Property. View "Thomas v. City of Philadelphia" on Justia Law

Comprehensive Healthcare Management Services LLC acquired numerous healthcare facilities in Pennsylvania beginning in 2014. The United States Department of Labor investigated these facilities for wage and hour violations under the Fair Labor Standards Act (FLSA). The Department’s Secretary filed suit in 2018 on behalf of nearly 6,000 employees, alleging that Comprehensive failed to maintain accurate records and did not properly compensate employees for all hours worked, including overtime and time worked during meal breaks. Evidence at trial revealed systemic errors in Comprehensive’s payroll and recordkeeping systems, leading to employees being paid for scheduled rather than actual hours, unpaid work during meal breaks, and improper calculation of overtime rates.The United States District Court for the Western District of Pennsylvania held a bench trial and found in favor of the Secretary. The District Court found the Secretary’s witnesses credible and Comprehensive’s witnesses lacking credibility. It concluded that Comprehensive had violated the FLSA by failing to keep accurate records, not compensating for all hours worked, miscalculating overtime, and misclassifying employees as exempt. The court awarded $35,804,438.20 in damages, which included compensation for “overtime gap time”—hours worked in a week beyond 40 for which regular pay was not provided.On appeal, the United States Court of Appeals for the Third Circuit reviewed the case. The court held that claims for “overtime gap time” are not cognizable under the FLSA, as the statute only requires payment of minimum wages and overtime, and does not cover unpaid non-overtime hours in overtime weeks. The court reversed the District Court’s award on that ground. The Third Circuit affirmed the District Court’s findings regarding Comprehensive’s FLSA violations and its application of the burden of proof, finding no clear error. However, it vacated and remanded the exemption analysis for further proceedings, instructing the District Court to apply current legal standards. View "Secretary United States Department of Labor v. Comprehensive Healthcare Management Services LLC" on Justia Law

The case centers on a defendant who was initially charged in the Virgin Islands Superior Court with first-degree murder and a firearm offense, and released pretrial with a condition not to possess weapons. Several months later, the defendant became involved in a shootout with police, resulting in the death of a detective. Upon investigation, authorities found a firearm, ammunition, and drugs in his vehicle. A federal grand jury subsequently indicted the defendant on charges including using a firearm during a crime of violence resulting in death, which made him eligible for the federal death penalty. The predicate crimes underlying these charges were all violations of Virgin Islands territorial law.After indictment, the prosecution indicated it would not recommend the death penalty but acknowledged that only the Attorney General could make the final decision. At the defendant’s request, and with the government’s agreement, the United States District Court of the Virgin Islands set a deadline for the government to provide notice if it intended to seek the death penalty. The government missed this deadline but ultimately filed a notice to seek the death penalty over a year later, after a change in federal policy. The District Court struck the notice as untimely and dismissed several counts relying on territorial offenses as predicate crimes of violence under federal firearm law.The United States Court of Appeals for the Third Circuit reviewed the case. It held that a district court has the authority to set and enforce deadlines for the government to provide notice of intent to seek the death penalty under 18 U.S.C. § 3593(a), and found no abuse of discretion in enforcing the deadline set. The court also held that Virgin Islands territorial offenses qualify as predicate crimes of violence for purposes of 18 U.S.C. § 924(c)(1)(A). The court affirmed the order striking the death penalty notice, but reversed and remanded the dismissal of counts based on territorial predicates. View "USA v. Dangleben" on Justia Law

A citizen of the Dominican Republic entered the United States as a lawful permanent resident in 1994. She suffered abuse from her partner, who later involved her in a drug-trafficking scheme without her consent. In 2007, she pled guilty to conspiracy to possess with intent to distribute one kilogram or more of heroin, served a prison sentence, and was ordered removed from the United States in 2008. She unlawfully reentered the country in 2009 and remained until her 2023 arrest. Following the reinstatement of her prior removal order, she applied for withholding of removal and relief under the Convention Against Torture (CAT), fearing harm from her former partner if returned to the Dominican Republic.An Immigration Judge denied her applications, finding her conviction was a presumptive “particularly serious crime” (PSC) under the Attorney General’s decision in Matter of Y-L-, and that she had not rebutted the presumption. The judge also rejected her CAT claim, concluding she failed to establish it was more likely than not she would face torture with government acquiescence upon return. The Board of Immigration Appeals (BIA) adopted the Immigration Judge’s decision, and dismissed her appeal.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that it had jurisdiction over both the CAT and withholding claims, even though the petitioner did not challenge the underlying removal order and the government did not contest the timeliness of the petition. The court unanimously denied her petition for review of the CAT claim, holding that the BIA did not err in denying relief. However, the panel was evenly divided on the statutory withholding claim: one judge would have denied the petition, one would have granted and remanded, and one would have dismissed for lack of jurisdiction. As a result, the denial of statutory withholding was left intact by an equally divided court. View "Laureano v. Attorney General" on Justia Law