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

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

Two individuals, citizens of Ecuador and Brazil, respectively, entered the United States without inspection in 2001 and 2014. In late 2025 and early 2026, each was arrested by U.S. Immigration and Customs Enforcement and detained, without the possibility of bond, under 8 U.S.C. § 1225(b)(2)(A). This marked a change in government practice, as similar noncitizens had previously been detained or released under 8 U.S.C. § 1226(a), which allows for discretionary bond if the person is not a danger or flight risk. In 2025, the government began applying § 1225(b)(2)(A) to noncitizens already present in the United States who entered without inspection, resulting in mandatory detention without bond.Both individuals filed habeas petitions in the United States District Court for the Eastern District of Pennsylvania, arguing their detentions violated the Immigration and Nationality Act (INA). The district courts granted their petitions, finding that § 1225(b)(2)(A) did not apply to them and that their continued detention without bond violated the INA. One district court also held that such detention violated the Fifth Amendment’s Due Process Clause. Both petitioners were subsequently released, and the government appealed these decisions.The United States Court of Appeals for the Third Circuit reviewed the statutory language and structure of the INA and considered relevant precedent. The court held that § 1225(b)(2)(A) applies only to noncitizens who are both “applicants for admission” and “seeking admission,” meaning those engaged in a present or ongoing attempt to gain lawful entry into the United States. The court concluded that noncitizens already present in the United States who are not actively seeking admission are not subject to mandatory detention under this provision and should be considered under § 1226(a), which allows for bond. The Third Circuit also held that detaining such individuals without a bond hearing violates the Due Process Clause. The court affirmed the district courts’ orders directing the release of the petitioners. View "Morocho v. Warden Philadelphia FDC" on Justia Law

A member of Congress from New Jersey was charged with three counts of violating federal law after allegedly physically interfering with federal officials during an oversight visit to a federal immigration detention facility in Newark. During the visit, the Congresswoman and other Representatives encountered Newark’s Mayor, who was ordered to leave the premises by federal agents. When federal agents attempted to arrest the Mayor, the Congresswoman allegedly placed herself between the Mayor and an agent, forcibly made contact with the agent, and later pushed past another federal officer to reenter the facility. The charges stem from these physical altercations and the Congresswoman’s efforts to impede the Mayor’s arrest.The United States District Court for the District of New Jersey denied the Congresswoman’s motions to dismiss the indictment. The court found that her conduct was not protected by legislative immunity under the Speech or Debate Clause, concluding it was non-legislative in nature. The court also rejected her arguments based on the separation of powers doctrine, distinguishing between Presidential and legislative immunities. Additionally, the court ruled against her selective and vindictive prosecution claims, finding she failed to demonstrate discriminatory effect or personal animus by the prosecution.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit affirmed the denial of legislative immunity for Counts One and Two, holding that prosecution of those charges would not require the Congresswoman to answer for any legislative acts. The court vacated and remanded with respect to Count Three for further consideration as to whether legislative immunity might apply. The court dismissed the remainder of her appeal, including claims of selective and vindictive prosecution, for lack of jurisdiction. View "USA v. McIver" on Justia Law

On June 6, 2014, the defendant armed himself and traveled from New York to Pennsylvania, where he attacked his ex-girlfriend (Victim 1), forcibly abducted her, and then drove her across state lines to New Jersey. During this ordeal, he threatened and physically assaulted her, then sexually assaulted her at a rest stop. After Victim 1 managed to escape, the defendant assaulted a National Park Service maintenance worker (Victim 2) and stole his vehicle, then proceeded to commit arson at a business owned by his former partners. He was apprehended after a police chase in New York.A grand jury in the United States District Court for the District of New Jersey initially indicted the defendant on six counts, including kidnapping, aggravated sexual abuse, firearm offenses, assault of a federal employee, and arson. Over nearly eight years, the case was continued multiple times due to plea negotiations, questions of competency, and the defendant’s own motions and changes in counsel. The defendant entered into a plea agreement, pled guilty to several charges, and waived certain statute of limitations defenses, but later moved to withdraw his plea, claiming innocence and coercion. The District Court accepted the withdrawal. The government subsequently filed superseding indictments, and the defendant continued to challenge the timeliness of certain charges and raised speedy trial concerns, but the District Court denied these motions. At trial, the defendant pled guilty to two counts and was found guilty on the remaining charges by a jury.The United States Court of Appeals for the Third Circuit reviewed several claims, including whether the statute of limitations waiver in the earlier plea agreement remained enforceable after the plea was withdrawn, whether the District Court erred in its jury instructions regarding the elements of kidnapping and the status of the assaulted federal employee, and whether the lengthy pretrial delay violated the defendant’s speedy trial rights. The Third Circuit held that the statute of limitations waiver survived the plea withdrawal due to the language of the agreement, and that the guilty plea to one count barred a statute of limitations challenge to that conviction. The court found any jury instruction errors harmless in light of overwhelming evidence, and concluded that, under the Barker v. Wingo factors, the delay did not violate the defendant’s constitutional right to a speedy trial. The Third Circuit affirmed the judgment of the District Court. View "USA v. Figueroa" on Justia Law

A citizen of El Salvador entered the United States illegally in 2015 and later applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). He settled near Baltimore, worked in construction, started a family, but encountered legal trouble, including a conviction for conspiracy to commit armed robbery. The government initiated removal proceedings, and he conceded removability. He argued that, due to his tattoos, criminal history, and a Salvadoran indictment linking him to gang activity, he would face torture in El Salvador, either from the government or gangs, and thus sought CAT relief.An Immigration Judge found the petitioner not credible, denied all forms of relief, and ordered removal. The judge concluded that the poor prison conditions in El Salvador did not amount to torture and found insufficient evidence that the petitioner would be singled out for torture. The Board of Immigration Appeals (BIA) affirmed the Immigration Judge’s decision, and the petitioner challenged only the denial of CAT relief to the United States Court of Appeals for the Third Circuit. While his petition was pending, the Third Circuit lifted a stay of removal, resulting in his deportation to El Salvador, where he was detained.The United States Court of Appeals for the Third Circuit dismissed the petition as moot. The court held that, because the petitioner had already been removed and was incarcerated abroad, there was no longer any removal to defer, and thus no effectual relief could be provided. The court further concluded that the collateral consequences of removal, such as a bar on reentry, were not redressable by granting CAT relief, since CAT relief does not disturb the underlying removal order. The court also found that the government’s policy of facilitating returns did not apply to the petitioner’s circumstances. View "Mejia-Henriquez v. Attorney General United States of America" on Justia Law

Two individuals associated with a Russian nonprofit registered the domain name waronfakes.com through a Russian registrar in March 2022. This domain hosted content focused on Russian political issues. In August 2024, the United States government seized the domain and others, alleging violations of the international money laundering statute and the International Emergency Economic Powers Act (IEEPA). The government claimed the domain was used to promote Russian disinformation on behalf of sanctioned individuals and entities, and that the purchase of the domain involved funds transferred for the benefit of a blocked person under U.S. sanctions. Five days after the seizure, the nonprofit and its director were added to the U.S. Treasury’s blocked persons list, which prohibits the transfer or dealing in their U.S.-based property without a license.The applicants, Timofey V and ANO Dialog, moved in the United States District Court for the Eastern District of Pennsylvania for the return of the domain under Federal Rule of Criminal Procedure 41(g). The government opposed the motion, arguing that the applicants were not lawfully entitled to possess the property as they were now blocked persons under U.S. sanctions and lacked the required license from the Office of Foreign Assets Control (OFAC). The District Court denied the motion without an evidentiary hearing, concluding that the applicants could not lawfully receive the domain.On appeal, the United States Court of Appeals for the Third Circuit held that although the applicants had standing due to a sufficient possessory interest, they failed to establish lawful entitlement to the property because transfer to them was blocked by sanctions and no OFAC license had been obtained. The court further found no abuse of discretion in the District Court’s denial of an evidentiary hearing, as the legal impediment to transfer was undisputed. The judgment of the District Court was affirmed. View "Timofey V v. USA" on Justia Law

Six landowners in Western Pennsylvania, believing that XTO Energy, Inc. was underpaying royalties owed under oil and gas leases, brought a class action in the U.S. District Court for the Western District of Pennsylvania. None of the named plaintiffs’ leases included arbitration clauses, but the proposed class definitions were broad enough to cover leaseholders whose leases did contain arbitration clauses. The plaintiffs sought damages on behalf of themselves and similarly situated landowners.After the suit was filed, the District Court oversaw extensive class discovery and certified classes that included some members whose leases had arbitration clauses. XTO did not assert arbitration as a defense in its answers or move to compel arbitration before class certification or before the expiration of the class opt-out period. It only moved to compel arbitration against those unnamed class members with arbitration clauses after the opt-out period closed. Relying in part on the then-controlling district court decision in Valli v. Avis Budget Rental Car Group, LLC, a Magistrate Judge found that XTO had waived its right to arbitrate by demonstrating a preference for litigation over arbitration, and the District Court adopted that ruling.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s waiver determination de novo as to legal conclusions and for clear error as to factual findings. The Third Circuit held that, under its intervening precedential decision in Valli v. Avis Budget Group, Inc., a defendant does not waive its right to compel arbitration against unnamed class members with arbitration clauses in their leases merely by litigating prior to class certification, where none of the named plaintiffs are subject to arbitration. The court found XTO’s conduct did not constitute an implied waiver. The Third Circuit vacated the District Court’s order denying XTO’s motion to compel arbitration and remanded for further proceedings. View "Salvatora v. XTO Energy Inc" on Justia Law