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

A dispute arose over Pennsylvania's rule requiring mail-in and absentee voters to date the return envelope carrying their ballot. The Supreme Court of Pennsylvania had ruled this requirement mandatory and declared that undated or incorrectly dated ballots were invalid under state law. The case centered on whether federal law, specifically Section 10101(a)(2)(B) of the Civil Rights Act of 1964, mandated that these non-compliant ballots be counted. This provision prohibits the denial of the right to vote due to an immaterial error or omission on paperwork related to voting.The District Court granted summary judgment for the plaintiffs, declaring that rejecting timely received mail ballots due to missing or incorrect dates violated the federal provision. They reasoned that the date requirement was immaterial, as it played no role in determining a vote's timeliness.However, the appellate court reversed this decision. The court held that the federal provision only applies when the state is determining who may vote, not how a qualified voter must cast their ballot. They found that the provision does not apply to rules, like the date requirement, that govern how a qualified voter must cast their ballot for it to be counted. The court concluded that a contrary approach could not be reconciled with the text and historic backdrop of the statute. Therefore, the court ruled that the federal provision does not override Pennsylvania's date requirement for casting a mail-in ballot. The case was remanded for further consideration of the plaintiffs' pending equal protection claim. View "Pennsylvania State Conference of NAACP Branches v. Northampton County Board of Elections" on Justia Law

This case involves a dispute between Jennifer Zuch and the Internal Revenue Service (IRS) over the allocation of estimated tax payments and the subsequent application of those payments to pay off her tax liability. Zuch argued that the IRS erroneously applied $50,000 in estimated tax payments, which she and her then-husband had made, to her ex-husband's tax liability instead of hers. As the dispute was litigated over several years, the IRS withheld tax refunds owed to Zuch and applied them to her alleged unpaid balance, thereby satisfying it in full. The IRS then moved to dismiss the Tax Court proceeding, arguing the case was moot since there was no more tax to be paid. The Tax Court granted the motion.In appeal, the U.S. Court of Appeals for the Third Circuit vacated the Tax Court's dismissal and remanded the matter back to the Tax Court. The appellate court found that Zuch's claim was not moot, even though the IRS had satisfied her tax liability by applying her tax refunds to it. The court held that the IRS cannot unilaterally moot a case by withdrawing its proposed collection action, especially when the Tax Court has already obtained jurisdiction of a liability challenge. The court also found that a taxpayer's challenge to the tax liability at issue in an action under § 6330(c)(2)(B) of the Internal Revenue Code cannot be rendered moot by the unilateral action of the IRS. The court concluded that the Tax Court retained jurisdiction to review Zuch's liability and to determine whether she is entitled to receive credit for any amount of the estimated tax payments at issue. View "Zuch v. Commissioner of Internal Revenue" on Justia Law

In a case before the United States Court of Appeals for the Third Circuit, the plaintiff, Troy Moore, Sr., a prisoner, sued Correctional Officer Saajida Walton under 42 U.S.C. § 1983, alleging that she violated his Eighth Amendment rights. The claim was based on an incident where a toilet in Moore’s prison cell exploded and Walton refused to let him out of his cell to clean up for over eight hours. Moore originally filed the complaint under a misspelled version of Walton’s name. The correct spelling was not provided until after the statute of limitations for his claim had expired. The District Court granted summary judgment to Walton based on the statute of limitations.The Circuit Court held that the District Court misapplied the relation back analysis under Federal Rule of Civil Procedure 15(c)(1)(C) by failing to consider the period for service provided by Federal Rule of Civil Procedure 4(m). It held that Rule 15(c)(1)(C)’s reference to “the period provided by Rule 4(m)” includes any extensions for service granted under Rule 4(m) for good cause. The case was remanded to the District Court to determine whether Walton received notice of the action by a certain date and, if so, whether Moore could demonstrate the absence of prejudice—the final element necessary to satisfy the relation back inquiry. If all these conditions were met, the District Court would then need to consider the merits of Moore’s Eighth Amendment claim. View "Moore v. Walton" on Justia Law

The case in question is a petition for a writ of mandamus filed by Abbott Laboratories, Abbvie Inc., Abbvie Products LLC, Unimed Pharmaceuticals LLC, and Besins Healthcare, Inc. These petitioners were involved in a patent and antitrust lawsuit concerning the drug AndroGel 1%. They sought a writ of mandamus after a district judge ruled that the application of the crime-fraud exception to the attorney-client privilege justified an order compelling the production of certain documents. The Petitioners claimed those documents were privileged.The Court of Appeals for the Third Circuit denied their petition. The court reasoned that the petitioners failed to meet the high standard for granting a petition for writ of mandamus. Specifically, they failed to show a clear and indisputable abuse of discretion or error of law, a lack of an alternate avenue for adequate relief, and a likelihood of irreparable injury.The court also found that the district court did not err in its interpretation of the crime-fraud exception to the attorney-client privilege as it applies to sham litigation. The court held that sham litigation, which involves a client’s intentional “misuse” of the legal process for an “improper purpose,” can trigger the crime-fraud exception. The court also rejected the argument that a "reliance" requirement must be applied in this context. View "In re: Abbott Laboratories" on Justia Law

In the case before the United States Court of Appeals for the Third Circuit, the Borough of Longport and the Township of Irvington, two New Jersey municipalities, sued Netflix, Inc. and Hulu, LLC, two popular video streaming companies. The municipalities sought to enforce a provision of the New Jersey Cable Television Act (CTA), which requires cable television entities to pay franchise fees to municipalities. The CTA, however, does not provide an express right of action for municipalities to enforce its provisions. The court had to determine whether the CTA implies such a right. The court concluded that it does not and affirmed the judgment of the District Court. The court found that the CTA expressly vests all enforcement authority in the Board of Public Utilities (BPU) and that it would be inconsistent with the purposes of the CTA to infer the existence of a private right of action for municipalities. The court rejected the municipalities' argument that the New Jersey Constitution recognizes that municipalities have powers of "necessary or fair implication", stating that this cannot change the plain meaning of statutes or provide municipalities with statutory enforcement authority that would directly conflict with the statute. View "Borough of Longport v. Netflix Inc" on Justia Law

The US Court of Appeals for the Third Circuit dealt with two consolidated cases involving two New Jersey parents, who claimed they were retaliated against for protesting school policies related to mandatory masking during the COVID-19 pandemic. One parent, George Falcone, was issued a summons for defiant trespass after refusing to wear a mask at a school board meeting, while another parent, Gwyneth Murray-Nolan, was arrested under similar circumstances. Falcone claimed retaliation for exercising his First Amendment rights, while Murray-Nolan argued the same and also claimed she was deprived of substantive due process. The district court dismissed both cases. On appeal, the court found that Falcone had standing to sue, reversing and remanding the lower court's decision. However, the court affirmed the dismissal of Murray-Nolan's case, concluding that refusing to wear a mask during a pandemic was not protected conduct under the First Amendment. View "Murray-Nolan v. Rubin" on Justia Law

In this case before the United States Court of Appeals for the Third Circuit, the appellant, Paulette Barclift, sued Keystone Credit Services, LLC ("Keystone") for allegedly violating the Fair Debt Collection Practices Act ("FDCPA"). Barclift claimed that Keystone unlawfully communicated her personal information to a third-party mailing vendor, RevSpring, without her consent. She sought to represent a class of similarly situated plaintiffs. The District Court dismissed her suit on the grounds that she did not allege an injury sufficient to establish standing under Article III of the United States Constitution.Upon appeal, the Third Circuit agreed with the lower court that Barclift lacked standing, but modified the District Court's order so that the dismissal would be without prejudice. The court found that Barclift's alleged harm—embarrassment and distress caused by the disclosure of her personal information to a single intermediary (RevSpring)—did not bear a close relationship to a harm traditionally recognized by American courts, such as the public disclosure of private facts. Therefore, the court concluded that Barclift did not suffer a concrete injury and could not establish Article III standing. The court further held that the possibility of future harm was too speculative to establish a concrete injury. The case was dismissed without prejudice, allowing Barclift the opportunity to amend her complaint if she can allege a concrete injury. View "Barclift v. Keystone Credit Services LLC" on Justia Law

In Pennsylvania, four family members, including two elderly parents, were injured during a pre-dawn, no-knock raid by the Special Emergency Response Team (SERT) of the Pennsylvania State Police. The police acted on information about alleged drug sales by a family member, but none of the four injured individuals were suspected of any wrongdoing. They sued the officers for excessive use of force, but the District Court granted summary judgment in favor of the officers, ruling that they were entitled to qualified immunity.Upon review, the United States Court of Appeals for the Third Circuit reversed the District Court's decision. The court found that the officers' conduct was objectively unreasonable as they had used substantial force against individuals who were unarmed, cooperative, outnumbered by law enforcement, not suspected of wrongdoing, and in their own home. Furthermore, the court held that the right to be free from such excessive force was clearly established at the time of the officers' conduct, and that any reasonable officer would have known that their actions were unlawful. Hence, the court concluded that the officers were not entitled to qualified immunity.The case has been remanded to the District Court for further proceedings. View "Anglemeyer v. Ammons" on Justia Law

In this case, two New Jersey parents sued various school and law enforcement officials, alleging that their First Amendment rights were violated when they were punished for refusing to wear masks at school board meetings. George Falcone was issued a summons and Gwyneth Murray-Nolan was arrested. The United States Court of Appeals for the Third Circuit held that Falcone had standing to sue because his alleged injuries were directly traceable to the defendants who allegedly conspired to violate his First Amendment right to engage in political and symbolic speech. The court reversed and remanded the lower court's order dismissing Falcone's complaint for lack of standing.However, the court affirmed the lower court's dismissal of Murray-Nolan's complaint. The court held that refusing to wear a mask is not expressive conduct protected by the First Amendment. Further, Murray-Nolan's retaliation claim failed because the police had probable cause to arrest her and she did not link her constitutionally protected speech activities (such as her social media posts) to any of the defendants' allegedly retaliatory actions. View "Falcone v. Dickstein" on Justia Law

In this case before the United States Court of Appeals for the Third Circuit, a US citizen, Abdoulai Bah, had his life savings of $71,613 seized by the U.S. Customs and Border Protection (CBP) under suspicion of being the proceeds of illegal activities. The CBP returned the money with interest two-and-a-half years later. Bah then sued the United States under the Federal Tort Claims Act (FTCA), seeking damages for personal injury and property damage, arguing that the seizure of his money prevented him from conducting business, caused him to lose his livelihood, and resulted in health problems.The District Court dismissed Bah's case, asserting that the United States was immune from Bah's claims. The court held that the FTCA did not permit Bah's claims as they were seeking prejudgment interest— a type of relief for which the United States has not waived sovereign immunity.Upon appeal, the United States Court of Appeals for the Third Circuit upheld the District Court's decision. The appellate court held that the Detention Exception of the FTCA, under which Bah's claim was filed, only waives sovereign immunity for "injury or loss of goods, merchandise, or other property while in the possession of any officer of customs or excise or any other law enforcement officer," but it does not waive immunity for personal "injury" or "loss" incurred due to the government's seizure of property. As such, the court concluded that Bah's cash was not injured or lost in the sense meant by the FTCA, and his personal injuries were not covered under the Act. Furthermore, the court determined that Bah's claim of "loss" was really a claim for "loss of use" of his cash, which is not covered under the FTCA. Thus, the court affirmed the dismissal of Bah's case. View "Bah v. USA" on Justia Law