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

In 2000, Bronowicz was charged with crimes ranging from terroristic threats to driving under the influence. He entered a negotiated plea, served his term of imprisonment, and was released. A complicated sequence of probation revocation and sentencing proceedings allegedly had the cumulative effect of unlawfully imposing additional penalties for criminal judgments that had already been satisfied. Bronowicz successfully appealed his additional prison sentence in state court and then filed a federal suit, seeking damages for wrongful incarceration under 42 U.S.C. 1983. The district court dismissed his claims as barred by the 1994 Supreme Court decision, Heck v. Humphrey. The Third Circuit reversed in part, holding that an order from the Superior Court of Pennsylvania vacating a sentence imposed by a court of common pleas constitutes a favorable termination of the proceedings against a plaintiff within the meaning of Heck v. Humphrey, notwithstanding the fact that the order failed expressly to address the inmate’s specific legal challenges to the sentence, so that any section 1983 claims stemming from the invalidated sentence are not barred by Heck. View "Bronowicz v. County of Allegheny" on Justia Law

J.B., age 12, got into a fight and brandished a homemade knife over a neighborhood girl, stating that could kill her. A parent called the state police. J.B. admitted to threatening to break a girl’s arms and to holding the knife. J.B.’s father was told that charges of terroristic threats and summary harassment would be filed. Three weeks later, a juvenile allegation was filed. J.B. was transported to the Lancaster County Youth Intervention Center, processed, and subjected to a strip search pursuant to LYIC policy to look for signs of “injuries, markings, skin conditions, signs of abuse, or further contraband.” J.B. stood behind a curtain so that only the officer conducting the search could observe him, removed his pants and underwear for approximately 90 seconds, and was asked to bend over, spread his buttocks, and cough. J.B. was detained for three days. He ultimately entered into a consent decree with an opportunity to have his record expunged. In his suit under 42 U.S.C. 1983 for false arrest, unreasonable search and seizure, false imprisonment, and violations of due process, the Third Circuit concluded that defendants were entitled to partial summary judgment. The Supreme Court holding in Florence v. Board of Chosen Freeholders, that all arrestees committed to general population of a detention center may be subject to a close visual inspection while undressed, applies to juvenile offenders admitted to general population in a juvenile detention center. View "J. B. v. Fassnacht" on Justia Law

Saranchak entered open plea of guilty to murdering his grandmother and uncle and was convicted on two counts of first-degree murder following a non-jury degree-of-guilt hearing. A jury found that Saranchak should be sentenced to death for his crimes. The Pennsylvania Supreme Court affirmed Saranchak’s conviction and sentence on direct appeal. Saranchak then sought state post-conviction relief, asserting that his attorney, Watkins, had been constitutionally ineffective. The same judge who had presided over both phases of his trial denied relief under the Pennsylvania Post-Conviction Relief Act, 42 Pa. Cons. Stat. 9541–9546, The PCRA court—the same judge who presided over both phases of Saranchak’s trial. The Pennsylvania Supreme Court affirmed. The district court denied Saranchak’s federal habeas petition. The Third Circuit affirmed in part, rejecting an argument that the degree-of-guilt phase of his trial was suffused with prejudice from the cumulative errors arising out of his counsel’s performance at trial. The Third Circuit reversed with respect to the death sentence, finding that the court did not adequately evaluate mitigation evidence concerning Saranchak's childhood and mental health. View "Saranchak v. Sec'y Pa. Dep't of Corrs." on Justia Law

Young, a Pennsylvania prisoner with a long history of mental illness, filed suit, alleging violation of his Eighth Amendment rights by securing him in a four-point restraint chair, naked, for 14 hours, although he did not pose a threat to himself or others. Since childhood, Young has been diagnosed with various forms of mental illness, including bipolar disorder and schizo-affective disorder. Since his detention in solitary confinement, consisting of isolation for 23 hours per day and one hour of recreation time in a solitary pen on weekdays, for several years, Young’s symptoms of mental illness have intensified, including visual and auditory hallucinations, paranoid thoughts, throwing and smearing his own feces, episodes of self-harm, and suicidal impulses. The Third Circuit vacated summary judgment in favor of the defendants. Applying the use of excessive force test, analyzing the record under the criteria identified in Supreme Court precedent, and drawing all inferences in favor of Young as the non-moving party, there were genuine disputes as to material facts. View "Young v. Martin" on Justia Law

Munroe was an English teacher, generally considered to be effective and competent. The District granted Munroe tenure in 2010. In 2009, Munroe began a blog, using the name “Natalie M.” She did not expressly identify where she worked or lived, the name of the school or the names of her students. According to Munroe, her blog was meant to be viewed by friends that she had asked to subscribe. There were fewer than 10 subscribed readers, but no password was required for access. Most of the blog posts were unrelated to her school or work. Some postings included complaints about students, her working conditions, and related matters. The District administration first learned of Munroe’s blog in February 2011 when a reporter from a local newspaper began to ask questions; students apparently were commenting on social media.” Munroe was placed on paid suspension and, later, fired. The District had no regulation specifically prohibiting a teacher from blogging on his or her own time. The Third Circuit affirmed dismissal of Munroe’s 42 U.S.C. 1983 suit; under the Pickering balancing test, Munroe’s speech, in both effect and tone, was sufficiently disruptive so as to diminish any legitimate interest in its expression, and did not rise to the level of constitutionally protected expression. View "Munroe v. Central Bucks Sch. Dist." on Justia Law

Before 2003 Doe pled guilty to two simple assaults in Pennsylvania. In 2003, he pled guilty in federal court to distribution and possession with intent to distribute at least five grams of crack cocaine. His sentence as a career offender occurred under precedent categorically designating his prior convictions as crimes of violence. He did not appeal his 262-month sentence. In 2004 the government moved to reduce Doe’s sentence for “substantial assistance” in a different criminal investigation. While that Rule 35 motion was pending, Doe filed a section 2255 motion arguing that his assault convictions were not crimes of violence. The 2008 Supreme Court decision, Begay, held that a DUI conviction is not a “violent felony” under the Armed Career Criminal Act (ACCA) because it does not involve “purposeful, violent, and aggressive conduct.” The career-offender Sentencing Guideline was similar to the ACCA. In 2009, the district court granted Doe Rule 35 relief; counsel withdrew the 2255 motion. The Third Circuit then held that courts must inquire into the part of the statute to which the defendant actually pled guilty to determine whether the career-offender enhancement applies. In 2012 Doe filed a section 2255 motion, again raising his Begay argument. The statute of limitations on Doe’s Begay argument expired in 2009, when he withdrew his 2008 motion. The court concluded that there was no basis to toll the limitations period because Doe’s 2008 counsel was not deficient. The Third Circuit remanded. The court noted that while Doe has been released from prison, his case is not moot; proceeded under an assumption that the 2255 motion was not a second or successive motion over which the district court lacked jurisdiction; held that Doe had not procedurally defaulted his claim; and held that claims of Begay error are cognizable on collateral review. View "United States v. Doe" on Justia Law

Juanya, age 15, participated in a mandatory swimming class run by his physical education teacher, Rodgers. Juanya, a non-swimmer, was submerged for a few seconds, possibly inhaling or swallowing water. Juanya exited the pool and told Rodgers that his chest hurt. Rodgers told Juanya to sit on the bleachers. Several minutes later, Rodgers went over to check on Juanya, who requested to remain out of the pool for the rest of class. Rodgers denied the request. Juanya followed instructions and stayed in the shallow end for the remainder of the period. In his next class, nearly an hour and a half after leaving the pool, Juanya fell backward and hit the desk behind him. As he rolled off his chair and onto the floor, he had a seizure. A school nurse attempted to revive Juanya. Paramedics took Juanya by ambulance to a hospital, where he died that day, apparently of a rare form of asphyxiation called “dry” or “secondary drowning.” Juanya’s mother sued Rodgers and the Bethlehem Area School District, under 42 U.S.C. 1983. Rodgers moved for summary judgment on the basis of qualified immunity, which the court denied. The Third Circuit reversed, holding that Rodgers’s conduct did not violate a clearly established constitutional right, View "Spady v. Bethlehem Area Sch. Dist." on Justia Law

In 2007 fraudulent checks in the amount of $181,577 were cashed against the accounts of seven Citizens Bank customers in New York, Pennsylvania, and Delaware. Fraud investigator Swoyer discovered that Tolliver’s employee number was the only one used to access all of the accounts; only Tolliver and one assistant manager worked on all of the days on which the accounts were accessed.. Swoyer, Postal Inspector Busch, and a Secret Service agent interviewed Tolliver. At trial, Swoyer testified that he reviewed Tolliver’s entire logbook with her and that Tolliver told him that she had not given her password to anyone and that she always logged off her computer when she walked away from a terminal. Seven of Tolliver’s former co-workers testified they never knew Tolliver’s password or saw it written down. A jury convicted Tolliver of bank fraud, 18 U.S.C. 1344, aggravated identity theft, 18 U.S.C. 1028A(a), and unauthorized use of a computer, 18 U.S.C. 1030. The court imposed a below-Guidelines sentence of 30 months’ imprisonment and restitution. The Third Circuit affirmed. Tolliver, represented by newly appointed counsel, filed a 28 U.S.C. 2255 motion, claiming that her trial counsel was ineffective by failure to investigate. The district court granted her motion without holding an evidentiary hearing. The Third Circuit vacated. View "United States v. Tolliver" on Justia Law

Taylor, working at Dollar Express in 2000, observed that manager Ritterson routinely arrived at 5:00 a.m. and would smoke a cigarette on the loading dock with the door open before starting work and that the store contained a safe, but no other security measures. Washington, Johnson, Waddy and Taylor planned a robbery. Johnson carried the gun; Washington drove. Washington and Taylor remained in the car while Waddy and Johnson entered and confronted Ritterson and another employee. Johnson shot them. Washington then ran into the store and helped remove $750 from the safe. Waddy filled a bag with merchandise. When the others returned to the car, Taylor did not take any money. Taylor surrendered and agreed to testify. Waddy also gave a statement. Johnson, Waddy, and Washington were tried together. Washington was convicted of second-degree murder, robbery, and criminal conspiracy. After exhausting state remedies, Washington obtained conditional federal habeas corpus relief, based on his argument that introduction of a jointly-tried non-testifying coconspirator’s confession violated his Confrontation Clause rights. The redacted confession replaced Washington’s name with “someone I know” or “the driver.” The Third Circuit affirmed; no reasonable reading of Supreme Court Confrontation Clause jurisprudence would permit introduction of the redacted confession. Following remand for consideration under the Supreme Court’s decision in White v. Woodall (2014), the Third Circuit again affirmed. View "Washington v. Sec'y PA Dept. of Corrs." on Justia Law

WICO was founded as a coal bunkering business before the U.S. acquired the Virgin Islands (VI) in 1917 and grew to serve as “Port Agent” for cruise lines that visit the port of Charlotte Amalie and to manage the port's Havensight Mall. In 1986, WICO began dredging St. Thomas harbor, leading to public opposition and litigation. In 1993, the VI Government purchased all of the shares of WICO. The purchase was approved by the VI Legislature. The Act stated that “the Company is hereby granted the status and authority of a public corporation and governmental instrumentality … and shall be deemed to be a public entity operating on behalf of the Government, rather than a private corporation.” All WICO shares were transferred to the VI Public Finance Authority, a public corporation and governmental instrumentality. Two former WICO employees filed suit, alleging violations of First and Fourteenth Amendment rights. The district court dismissed, finding that “WICO cannot be considered a purely public entity,” and that its employees are not public employees, so its conduct could not be considered to have been “under color of state law” for purposes of liability under 42 U.S.C. 1983. The Third Circuit reversed in part, applying the 1995 Supreme Court decision, Lebron v. National Railroad Passenger Corporation, to hold that WICO is a government entity for the purposes of Sprauve’s and Smith’s constitutional claims. View "Gershwain Sprauve v. West Indian Company Limited" on Justia Law