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

Articles Posted in Civil Rights
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Around 2:00 a.m., Philadelphia Police Officers Cannon and Gonzalez, patrolling a “very violent” North Philadelphia area, saw a pickup truck roll through a stop sign and fail to signal a turn. They stopped the truck. While collecting the driver's license and registration, the officers smelled alcohol. The front seat passenger was heavily intoxicated; Hurtt, from behind, attempted to calm him. Hurtt volunteered his identification. When the driver stepped out for a sobriety test, leaving the door open. Cannon got into the truck and pointed his flashlight around the vehicle. Cannon instructed the two passengers to keep their hands visible three times. They did not comply and kept putting their hands in their pockets or the front of their pants. Although he had not yet run the driver’s license or vehicle identification nor finished the sobriety test, Gonzalez put the driver in the patrol car to help clear the passengers. After Hurrt twice appeared to be reaching into a tool bucket, Cannon searched him and found a loaded handgun in his waistband. After being arrested Hurtt made several statements without any Miranda warnings. Hurtt was charged as a felon in possession of a firearm, 18 U.S.C. 922(g)(1).The Third Circuit reversed the denial of Hurtt’s motion to suppress. Cannon created a safety concern while off-mission from the purpose of the original traffic stop and thereby wrongfully prolonged Hurtt’s detention. The disputed evidence was only uncovered after the officers went off-mission. View "United States v. Hurtt" on Justia Law

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Keles was admitted into Rutgers’s Civil and Environmental Engineering (CEE) Department’s graduate program and received his M.S. degree in 2014. While pursuing this degree, Keles expressed his interest in continuing his studies as a Ph.D. student. To continue their studies as Ph.D. students, M.S. students in the CEE Department must submit a “Change-in-Status” form, identifying advisors and describing their research plans. At the end of the M.S. program, Keles submitted an incomplete Change-in-Status form. Keles disputed that he needed to submit a completed Change-in-Status form due to his claimed enrollment as an M.S.-Ph.D. student. Members of the CEE Department and the University’s administration informed him that he needed to satisfy the admission prerequisites. Keles neither found an advisor nor submitted a completed form but sought to register for classes in 2015. Rutgers’s Administration informed Keles that his lack of academic standing prevented him from registering.Keles sued, alleging contract, tort, statutory, and due process claims. The Third Circuit affirmed the dismissal of his suit, finding that Rutgers adhered to its own policies and did not act in bad faith. All M.S. students were subject to the same departmental requirements. Rutgers afforded Keles sufficient process and did not venture “beyond the pale of reasoned academic decisionmaking.” View "Keles v. Bender" on Justia Law

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Becker’s pregnant girlfriend was shot to death on August 12, 2011. In an interview immediately after the shooting, Becker waived his Miranda rights and stated that he only wanted to clean the gun and “play around.” On August 18, after Becker’s discharge from a psychiatric hospital, he went voluntarily for a second interview. In a video-recorded interview, police repeated the Miranda warnings and neither placed Becker in handcuffs nor arrested him. The door to the interview room was unlocked. Police offered Becker drinks, cigarettes, and breaks. After approximately one hour, Becker stated: “I have nothing more to say ‘cause no matter what I say, youse trying to make me something I’m not.” Investigators left the room for several minutes. About an hour later, Becker responded to questions regarding his abusive history: “OK. I’m done now.” He never explicitly asked or attempted to leave. Police continued to question Becker, who was convicted of murder in the first degree and murder in the third degree. Becker unsuccessfully appealed the denial of his motion to suppress the second interview.The district court rejected his federal habeas petition and found “no basis” for a Certificate of Appealability (COA). The Third Circuit affirmed, applying the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2254 deferential standard to the state trial court’s findings when considering a request for a COA. Becker cannot meet that standard. View "Becker v. Secretary Pennsylvania Department of Corrections" on Justia Law

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The New Jersey Attorney General, investigating Smith & Wesson under the state's Consumer Fraud Act, issued a subpoena seeking documents related to Smith & Wesson’s advertisements. Instead of producing the documents, Smith & Wesson filed suit in federal court under 42 U.S.C. 1983, alleging the subpoena violated the First, Second, Fourth, Fifth, and Fourteenth Amendments. The state trial court subsequently ordered Smith & Wesson to show cause and threatened the company with contempt and a ban on sales in New Jersey; the court rejected the constitutional arguments presented in the federal suit. Smith & Wesson unsuccessfully sought an emergency stay of production. In federal court, Smith & Wesson added claims that the Attorney General’s suit was “retaliation" for the exercise of its First Amendment right to petition a court for redress.The Attorney General moved to dismiss the federal suit, citing “Younger” abstention. The district court dismissed the complaint, stating “the subpoena-enforcement action involves orders in the furtherance of state court judicial function.” Smith & Wesson eventually produced the subpoenaed documents under a protective order. The Third Circuit vacated the dismissal, citing the district court’s “virtually unflagging obligation . . . to exercise the jurisdiction given.” Abstention was not warranted in this case because the document production order was not “uniquely in furtherance of the state courts’ ability to perform their judicial functions.” View "Smith & Wesson Brands Inc v. Attorney General New Jersey" on Justia Law

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The Albanian-born brothers lived in New Jersey illegally. They came to the FBI’s attention because of a 2006 video that depicted them at a firing range in the Pocono mountains shooting weapons and shouting “jihad in the States.” The FBI deployed cooperating witnesses to monitor their activities and arranged a controlled sale of semi-automatic weapons. Based on a plot to attack the Fort Dix Army base and other military facilities, they were convicted of conspiracy to murder members of the U.S. military, 18 U.S.C. 1114, 1117; possession or attempted possession of firearms in furtherance of a crime of violence, 18 U.S.C. 924(c)(1)(A) and 924(c)(1)(B)(ii); possession of machineguns, 18 U.S.C. 922(o); and possession of firearms by an illegal alien, 18 U.S.C. 922(g)(5).The Third Circuit affirmed the denial of their habeas petitions, in which they argued that their 18 U.S.C. 924(c) convictions must be vacated under the Supreme Court’s 2019 “Davis” holding. Because each defendant was subject to an unchallenged life sentence, any potential vacatur of their Section 924(c) convictions would result in no practical change to their confinement. The “concurrent sentence doctrine” provides a court “discretion to avoid resolution of legal issues affecting less than all of the counts in an indictment where at least one count will survive and the sentences on all counts are concurrent.” View "Duka v. United States" on Justia Law

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Dongarra, incarcerated for bank robbery, was transferred to a new prison and went through the onboarding process, supervised by Officer Smith. Smith gave him an ID card that indicated “Registered Offender,” and a T-shirt “know[n]” to be a “sex offender T-shirt.” The shirt falsely suggested that he had been imprisoned at Terre Haute, “a sex offender prison.” Dongarra stated that he “could be killed” if prisoners mistook him for a sex offender. Smith said he did not care and that he “hope[d] [Dongarra] kn[e]w how to fight.” Dongarra appealed to other staff, who asked Smith for another T-shirt. Smith refused. Frightened, Dongarra skipped meals and lost weight and stopped going out for recreation. Dongarra filed a grievance. Though he never got a response, a few weeks later the prison replaced his ID card and T-shirt.Dongarra sued Smith and two unnamed officers, seeking damages and an injunction, citing “Bivens.” The Third Circuit affirmed the dismissal of his 42 U.S.C. 1983 case. Injunctive relief is not available because Dongarra had not sued anyone who could fire or discipline Smith and by the time Dongarra sued, the prison had corrected the error. No court has extended Bivens to cover similar facts; “special factors” bar extending Bivens here. Although the officer violated Dongarra’s rights, the feared risk never materialized. Damages cannot be awarded to compensate him for an assault that never happened. View "Dongarra v. Smith" on Justia Law

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In 2016, the out-of-state petition circulators challenged Section 2869 of the Pennsylvania Election Code, which requires that any circulator of nomination petitions be “a qualified elector of the Commonwealth, who is duly registered and enrolled as a member of the party designated in said petition.” The district court found that the ban was not facially unconstitutional, but was unconstitutional as applied to the plaintiffs for the 2020 election only. The plaintiffs did not appeal the conclusion that the ban was not facially unconstitutional. The court declined to expand the injunctive relief to cover future elections for the plaintiffs and all similarly situated individuals. The Third Circuit held that permanent injunctive relief for all future elections is appropriate for the plaintiff circulators only, not to all similarly situated individuals, and only if the plaintiffs continue to submit to Pennsylvania’s jurisdiction. The request for permanent relief for the plaintiffs and all similarly situated individuals goes beyond the specific plaintiffs and circumstances of this litigation and seeks facial relief. A factual record specific to each similarly situated individual circulator will be necessary to determine the appropriate relief in future elections. Each individual circulator will need to demonstrate their willingness to submit to Pennsylvania’s jurisdiction for the purpose of nomination circulation. View "Benezet Consulting LLC v. Secretary Commonwealth of Pennsylvania" on Justia Law

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Williams and Burton each filed civil rights complaints in the Western District of Pennsylvania against employees of the Pennsylvania Department of Corrections and moved to proceed in forma pauperis (IFP). Burton alleged that the defendants retaliated against him after he filed a grievance, concerning his use of the law library. Williams alleged that prison staff refused to accommodate his special dietary needs. Both plaintiffs consented to have their cases heard by magistrate judges, who dismissed the cases before the defendants consented to magistrate judge jurisdiction.The Third Circuit vacated. A magistrate judge can acquire jurisdiction to decide a case only by the consent of the parties, 28 U.S.C. 631(c)(1); “consent of the parties” does not mean consent just of the prisoner-plaintiff. The jurisdictional requirement cannot be waived by the parties. If the requirements of Section 636(c)(1) are not satisfied, the “magistrate judge [is deprived] of jurisdiction over the case” and the appellate court is statutorily deprived of appellate jurisdiction over the magistrate judge’s orders. Consent could not be implied in this case and retroactive, post-judgment consent cannot satisfy the statutory requirement. View "Burton v. Schamp" on Justia Law

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June’s son, Brenden, suffers from severe bipolar disorder and is prone to violent outbursts. He has repeatedly been jailed and institutionalized. In 2017, he was involuntarily admitted to Greystone, a New Jersey state-run psychiatric hospital, where Brenden’s condition worsened. He stalked the halls, made an aggressive sexual comment to a staffer, and attacked other patients, sending one to the intensive care unit. Greystone staff encouraged June’s visits as part of Brenden’s treatment. Before one visit, June asked if it was safe to visit Brenden. Though Brenden had severely beaten another patient days earlier, his psychiatrist, Dr. Young, assured her that it was safe. Greystone employees were supposed to supervise all patient meetings but no one was assigned to monitor June’s visit. Initially, Brenden’s head nurse, Oglesby accompanied June, During June’s visit, Oglesby left the room. Brenden then attacked June, who suffered brain trauma, broken ribs, and PTSD.The district court dismissed June’s suit under 42 U.S.C. 1983. Sovereign immunity barred the claims against Greystone and state officials in their official capacity. The Third Circuit reversed as to Oglesby, who abandoned June mid-visit. June’s injury was fairly direct as well as foreseeable. Oglesby’s affirmative act endangered June; her departure deprived June of the freedom to avoid an unsupervised visit or to take other precautions. Dr. Young took no affirmative acts. View "Mears v. Connolly" on Justia Law

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Martin’s state conviction became “final” in April 2002, triggering the one-year limitations period on state prisoners seeking federal habeas corpus relief, 28 U.S.C. 2244(d)(1). The clock ran for 193 days, until October 21, 2002, when Martin filed a petition for state post-conviction relief (PCR). The clock was paused until June 14, 2004, the last day on which Martin could have appealed (but did not) the trial court’s denial of his petition—and expired 172 days later, on December 3, 2004. In June 2015, Martin filed a petition seeking federal habeas relief. The state appellate court had accepted Martin’s April 2012 motion for leave to appeal “as within time” the denial of his 2002 PCR petition; he argued that the ruling retroactively tolled the limitations period. Martin essentially argued that a “properly filed” PCR petition is “pending” under section 2244(d)(2) for the period between the expiration of time under state law in which a prisoner could have timely appealed the denial of a PCR petition, and the prisoner’s submission of a motion for leave to file a PCR appeal “as within time.”.The Third Circuit affirmed the dismissal of his petition as untimely. Section 4 2244(d)(2)’s tolling mechanism looks forward, not backward, and a state court’s acceptance of an appeal “as within time” does not rewind the one-year clock. View "Martin v. Administrator New Jersey State Prison" on Justia Law