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

Police investigating a fatal drive-by shooting in Philadelphia identified several suspects, including T.C., and obtained an arrest warrant for him. Detectives used multiple databases, including CLEAR and police records, to determine T.C.’s last known address, which pointed to 4838 Stenton Avenue. Believing T.C. resided there, detectives and a SWAT team executed the warrant early one morning. Instead of finding T.C., officers encountered Richard Miller and Tonya Crawley, who had lived at the residence for two years and were not connected to T.C. The officers detained Miller and Crawley briefly and then left after learning T.C. was not present. T.C. was later located and cleared of wrongdoing.Miller and Crawley sued the involved officers and the City of Philadelphia in the United States District Court for the Eastern District of Pennsylvania under 42 U.S.C. § 1983, alleging that the officers lacked probable cause and violated the Fourth Amendment, and that the City failed to train or supervise its officers. The District Court dismissed the municipal-liability claim for failure to state a claim and granted summary judgment to the officers on the unlawful-entry claim, holding that they had probable cause to enter the residence.On appeal, the United States Court of Appeals for the Third Circuit reviewed both the dismissal and summary judgment de novo. The court held that, although the District Court incorrectly invoked the good-faith exception, the error was harmless because the officers had probable cause to believe T.C. lived at the address and would likely be home at the early hour. The court also held that the plaintiffs failed to allege facts sufficient to establish municipal liability, as there was no pattern of similar constitutional violations or plausible basis for single-incident liability. The Third Circuit affirmed the District Court’s decisions. View "Miller v. City of Philadelphia" on Justia Law

Two Philadelphia police officers responded to reports of drug dealing and observed what they believed to be a drug transaction. When the suspected dealer, Tahir Ellison, saw the officers, he fled in his SUV. The officers pursued Ellison, initially at normal speeds, but the chase escalated when Ellison ran a red light, drove the wrong way down a one-way street, and sped up significantly. The officers followed, also running red lights and reaching high speeds. The chase lasted less than a minute and ended when Ellison crashed into another car, killing an uninvolved bystander, Virgen Martinez. Ellison later pleaded guilty to criminal charges relating to the incident.After the incident, Joshua Otero, as administrator of Martinez’s estate, filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania. The suit alleged that the officers, by engaging in a high-speed chase in a densely populated area, violated Martinez’s Fourteenth Amendment rights under 42 U.S.C. § 1983. The officers moved for partial summary judgment based on the absence of intent to harm and on qualified immunity. The magistrate judge found no evidence of intent to harm but denied summary judgment on both the constitutional and qualified immunity arguments, certifying the case for interlocutory appeal.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that police officers engaged in a high-speed chase are constitutionally liable for injuries to bystanders only if they acted with intent to harm. Because the officers did not intend to harm anyone, they could not be liable under the Fourteenth Amendment. The court also held that qualified immunity applied, as no clearly established law prohibited the officers’ conduct under these circumstances. The Third Circuit reversed the district court and instructed it to enter partial summary judgment for the officers. View "Otero v. Kane" on Justia Law

Rocky Freeman was involved in a Brooklyn drug ring and was hired to kill a rival dealer, Freddie Gonzalez, in 1993. He was later arrested and charged in the United States District Court for the Eastern District of New York with drug conspiracy, the Gonzalez murder, and the unrelated murder of Augustin Sosa. At trial, Freeman was convicted of the drug and Gonzalez murder counts but acquitted of the Sosa murder. However, his presentence report (PSR) incorrectly stated that he had committed both murders. Although a judge ordered the error corrected, the PSR was not amended, and the inaccurate report was transmitted to the Bureau of Prisons (BOP). Freeman subsequently endured heightened security conditions in prison, including solitary confinement and severe restrictions, which he later attributed to the erroneous PSR.Freeman discovered the error in 2015 and pursued administrative remedies, including filing an SF-95 form alleging a Federal Tort Claims Act (FTCA) violation. He then filed a civil complaint in the United States District Court for the Middle District of Pennsylvania against the BOP, the U.S. Probation Office (USPO), his unit manager, and probation officers, alleging FTCA and Bivens claims. The District Court dismissed his FTCA claim for lack of jurisdiction and on the merits, and dismissed his Bivens claim for failure to serve the probation officers. Freeman appealed.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that the District Court erred in dismissing Freeman’s FTCA claim for lack of jurisdiction, finding that he had properly presented his claim to the appropriate agency. The court also held that the District Court improperly applied the Prison Litigation Reform Act’s physical injury requirement to the FTCA presentment phase. The Third Circuit reversed the dismissal of the FTCA claim and remanded for further proceedings. However, the court affirmed the dismissal of Freeman’s Bivens claim, concluding that his claim was not cognizable under current Supreme Court precedent. View "Freeman v. Lincalis" on Justia Law

A woman with a lifelong hearing impairment obtained a commercial driver’s license (CDL) in New Jersey after receiving a federal exemption from the standard hearing requirement. This exemption allowed her to drive commercial vehicles in interstate commerce but specifically prohibited her from operating passenger vehicles or school buses. Despite this, she was mistakenly issued state endorsements permitting her to drive such vehicles and worked as a campus shuttle bus driver for about eight months. When the New Jersey Motor Vehicle Commission (NJMVC) realized the error, it revoked her passenger and school bus endorsements without providing a pre-revocation hearing.Instead of seeking review in New Jersey Superior Court, the woman filed suit in the United States District Court for the District of New Jersey. She alleged violations of Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and New Jersey’s Law Against Discrimination, as well as a procedural due process claim under 42 U.S.C. § 1983. The District Court dismissed some claims and ultimately granted summary judgment to the defendants on all remaining claims, finding she was not “qualified” for the endorsements and had no property interest in them.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The court held that the plaintiff was not a “qualified individual with a disability” under the relevant statutes because she could not meet the essential eligibility requirement of passing the hearing test for the endorsements. The court also held that, even assuming a property interest in the endorsements, due process did not require a pre-revocation hearing given the state’s strong safety interests and the availability of post-deprivation remedies. The court affirmed summary judgment for the defendants on all claims. View "Parker v. New Jersey Motor Vehicle Commission" on Justia Law

A nonprofit organization that assists individuals recovering from alcoholism and substance abuse sought to establish a group home in a New Jersey township by leasing a two-family dwelling. Before residents could move in, the township required a Certificate of Continuing Occupancy (CCO). The organization’s application for the CCO was denied by the township’s zoning officer, who stated that the intended use violated local zoning ordinances. The township’s attorney later explained that the group home was considered a “Community Residence” under state law and thus could not operate in a two-family dwelling. The organization disputed this classification but received no further response from the township.After the denial, the organization filed suit in the United States District Court for the District of New Jersey, alleging discrimination under the Americans with Disabilities Act (ADA) and the Fair Housing Act (FHA), and sought a preliminary injunction. The District Court denied the preliminary injunction, finding the organization had not shown a likelihood of success on the merits, and the United States Court of Appeals for the Third Circuit affirmed that denial. The organization then filed a First Amended Complaint, which the township moved to dismiss. The District Court granted the motion, holding that the amended complaint failed to state a claim and denied leave to amend further, reasoning that prior rulings had already provided notice of deficiencies and that amendment would be futile.On appeal, the United States Court of Appeals for the Third Circuit affirmed the dismissal of the First Amended Complaint for failure to state a claim, finding insufficient factual allegations to support a plausible inference of discriminatory intent or disparate impact. However, the court vacated the denial of leave to amend, holding that the District Court erred in concluding amendment would be futile, and remanded for further proceedings. View "Oxford House Inc v. Township of North Bergen" on Justia Law

Jose Montanez, an inmate in Pennsylvania state prisons, experienced sudden paralysis and incontinence while incarcerated at SCI-Huntingdon. After collapsing in his cell, he was taken to the medical unit but received minimal assistance and was denied hospital care. He was left in his cell, unable to walk or reach the toilet, for three days before receiving an MRI that revealed spinal cord stenosis and edema, necessitating surgery. Following surgery and a brief rehabilitation, Montanez was returned to prison, where he suffered a fall and herniated a disc. He alleged that prison medical staff denied him adequate pain medication and accommodations for his disabilities, such as a double mattress, mobility aids, and access to physical therapy.Montanez filed a pro se complaint in the United States District Court for the Middle District of Pennsylvania, asserting claims under the Eighth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act (RA) against the Commonwealth of Pennsylvania, its employees, Wellpath Care LLC (a private medical contractor), and Wellpath employees. The District Court dismissed all claims with prejudice, finding the complaint insufficient to state a claim and denying leave to amend, citing futility.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Montanez’s complaint, liberally construed, stated viable Eighth Amendment claims against certain individual defendants (Dr. Mahli, Nurse Wagman, and Administrator Ellers), a Section 504 RA claim against Wellpath, and ADA and RA claims against the Commonwealth. The court found that the District Court erred in dismissing these claims and in denying leave to amend for other claims, as amendment would not be futile. The Third Circuit affirmed in part, reversed in part, and remanded with instructions to allow Montanez to amend his complaint. View "Montanez v. Price" on Justia Law

A car leasing company leased a vehicle to an individual who defaulted on payments soon after the lease began. Despite having the right to repossess the car, the company did not do so. Two years later, the lessee was stopped by police in Butler, New Jersey, for driving with a suspended license, suspended registration, and no insurance. The police seized the car and had it towed by a contractor, Malanga’s Automotive. The lessee was informed of the tow but did not retrieve the vehicle. The towing company did not notify the leasing company that it possessed the car until nearly a year later, at which point it demanded payment of towing and storage fees before releasing the vehicle.The leasing company filed suit in the Superior Court of New Jersey against the towing company, later adding the Borough of Butler as a defendant and asserting claims under 42 U.S.C. § 1983 for violations of the Fourteenth Amendment’s Due Process Clause, the Fourth Amendment, and the Fifth Amendment. The case was removed to the United States District Court for the District of New Jersey, which granted summary judgment to Butler on all claims. The District Court found that the company had a property interest in the vehicle but concluded that Butler’s policies provided sufficient notice and opportunity to be heard, and that the seizure and retention of the vehicle were reasonable and did not constitute a taking.On appeal, the United States Court of Appeals for the Third Circuit held that Butler’s policies violated the Fourteenth Amendment’s Due Process Clause because they failed to require prompt notice to all holders of property rights in seized vehicles and did not provide an opportunity for a hearing to challenge the lawfulness of the tow or the fees. The court reversed and remanded the due process claim. However, it affirmed the District Court’s judgment on the Fourth and Fifth Amendment claims, finding no unreasonable seizure or unconstitutional taking. View "Honda Lease Trust v. Malanga's Automotive" on Justia Law

Five teenage boys disappeared in Newark, New Jersey, in 1978, and the case remained unsolved for decades. In 2008, police charged Lee Evans with their murders, relying primarily on a confession from Philander Hampton, Evans’s cousin. Evans was later acquitted at trial. He then filed a civil lawsuit, alleging that Detectives Lou Carrega and William Tietjen coerced Hampton’s confession and fabricated evidence to implicate him. Hampton later recanted, stating that his confession was false and coerced by the detectives.The United States District Court for the District of New Jersey reviewed the case after Evans brought claims for malicious prosecution against the detectives. The detectives moved for summary judgment, arguing they were entitled to qualified immunity. The District Court denied summary judgment on the malicious prosecution claims, finding that a reasonable jury could conclude the detectives made reckless, material omissions by failing to disclose that Hampton’s confession was coerced, and that these omissions led to Evans’s prosecution without probable cause. The detectives appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s denial of summary judgment. The Third Circuit held that qualified immunity does not shield law enforcement officers from liability for malicious prosecution when the prosecution is based on evidence that was allegedly manufactured or coerced. The court affirmed the District Court’s order denying summary judgment to the detectives on the malicious prosecution claim, concluding that a reasonable jury could find the officers violated Evans’s constitutional rights by arresting and prosecuting him without probable cause, based on fabricated evidence. The court also remanded for further consideration of the timeliness of Evans’s separate fabrication of evidence claim. View "Evans v. City of Newark" on Justia Law

An incarcerated individual alleged that, while detained at a county jail, he was assaulted by corrections officers, resulting in a fractured orbital bone, denied proper medical care, and unlawfully restrained for an extended period. He claimed to have submitted a grievance regarding the incident by placing it in the slot of his cell door, as he was in segregated housing and could not access the grievance box directly. The jail officials disputed his account, asserting that their use of force was justified, that he received prompt medical attention, and that he was restrained for a shorter period than he claimed.The United States District Court for the Western District of Pennsylvania reviewed the case after both parties moved for summary judgment. The defendants argued that the plaintiff failed to exhaust administrative remedies as required by the Prison Litigation Reform Act, supporting their position with a declaration that no grievance from the plaintiff was found in the jail’s records. The plaintiff, proceeding without counsel, reiterated his claim of submitting a grievance, but did so only in unsworn statements within his complaint and opposition brief. The District Court concluded that these unsworn statements could not be considered as evidence and granted summary judgment in favor of all defendants on the basis of non-exhaustion.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decision. The Third Circuit held that, while unsworn statements cannot create a genuine dispute of material fact at summary judgment, the District Court erred in concluding it was entirely barred from considering such statements for other purposes, such as deciding whether to permit the plaintiff an opportunity to cure procedural defects under Federal Rule of Civil Procedure 56(e). The Third Circuit vacated the District Court’s grant of summary judgment and remanded the case for further proceedings consistent with its opinion. View "Lauria v. Lieb" on Justia Law

After the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, which struck down New York’s “proper cause” requirement for public handgun carry, New Jersey enacted Chapter 131. This law removed its own “justifiable need” standard but imposed new licensing requirements, increased permit fees, mandated liability insurance for handgun carriers, and designated numerous “sensitive places” where firearms are prohibited, such as parks, entertainment venues, healthcare facilities, and private property without express consent. Two groups of plaintiffs, including individuals and gun rights organizations, challenged these provisions under 42 U.S.C. § 1983, arguing they violated the Second Amendment.The United States District Court for the District of New Jersey consolidated the cases and allowed legislative leaders to intervene as defendants. The District Court preliminarily enjoined enforcement of several “sensitive place” restrictions, the vehicle carry ban, the liability insurance requirement, and the private property default rule, finding these likely unconstitutional under Bruen’s historical tradition test. The State and some plaintiffs appealed, and the Third Circuit Court of Appeals granted a partial stay, allowing most of the law to take effect pending appeal.The United States Court of Appeals for the Third Circuit reviewed the District Court’s preliminary injunction, applying de novo review to the underlying Second Amendment questions. The Third Circuit held that most of New Jersey’s “sensitive place” restrictions—such as those covering parks, entertainment venues, healthcare facilities, libraries, museums, and places serving alcohol—are likely constitutional, finding them consistent with a historical tradition of regulating firearms in locations set aside for civic, educational, or recreational purposes. However, the court affirmed the injunction against the liability insurance mandate, the portion of the permit fee allocated to the Victims of Crime Compensation Office, the private property default rule as applied to places open to the public, and the ban on carrying operable firearms in private vehicles, holding these provisions likely violate the Second Amendment. The court vacated the injunction as to film sets and certain hunting regulations for lack of standing or mootness, and remanded for further proceedings consistent with its opinion. View "Koons v. Attorney General New Jersey" on Justia Law