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

Appellees in these consolidated appeals challenged under the Religious Freedom Restoration Act (RFRA) the requirement under the Patient Protection and Affordable Care Act (ACA) that contraceptive coverage be provided to their plan participants and beneficiaries. Appellees included a nonprofit institution of higher learning established by the Reformed Presbyterian Church and certain Catholic Dioceses and nonprofit organizations affiliated with the Catholic Church. Because they provided coverage to the Catholic nonprofits, the Dioceses, which were otherwise exempt, were required to comply with the contraceptive coverage requirement as to the nonprofits. The nonprofit appellees were eligible for an accommodation to the contraceptive coverage requirement, under which the contraceptive services will be independently provided by an insurance issuer or third-party administrator once the appellees advise that they will not pay for those services. Appellees argued that the accommodation places a substantial burden on their religious exercise because it forces them to facilitate the provision of insurance coverage for contraceptive services and has the impermissible effect of dividing the Catholic Church. The district courts granted Appellees’ motions for a preliminary injunction. The Third Circuit reversed, concluding that the accommodation places no substantial burden on Appellees, and therefore, Appellees did not show a likelihood of success on the merits of their RFRA claim. View "Geneva College v. Sec’y U.S. Dep’t of Health & Human Servs." on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder. The jury sentenced Defendant to death. The Pennsylvania Supreme Court affirmed the convictions on appeal, thus rejecting Defendant’s claims that the prosecution violated Brady v. Maryland. The Supreme Court subsequently denied Defendant’s application for postconviction relief. Thereafter, Defendant filed an application under 28 U.S.C. 2254 in federal district court, raising several claims. The district court granted Defendant a conditional writ of habeas corpus and directed the Commonwealth to retry Defendant or release him, concluding that the prosecution had breached its obligations under Brady by withholding three pieces of exculpatory and material information. The Third Circuit vacated the district court’s order, holding that the Pennsylvania Supreme Court reasonably concluded that Defendant was not entitled to relief on his Brady claims. Remanded for consideration of Defendant’s remaining claims. View "Dennis v. Sec’y, Pa. Dep’t of Corr." on Justia Law

Heffernan joined the Paterson Police Department in 1985 and became a detective. In 2006, Spagnola, a former Paterson police chief and Heffernan’s friend, sought to unseat the incumbent mayor. Heffernan hoped that Spagnola would win, but was unable to vote for Spagnola based on his city of residence, did not work on the campaign, and did not consider himself “politically involved.” At the request of his bedridden mother, Heffernan picked up a Spagnola campaign sign, to replace one that had been stolen from her lawn. An officer assigned to the Mayor’s security staff observed Heffernan’s encounter with the Spagnola campaign manager. The next day, Heffernan was demoted to a “walking post” because of his “overt[] involvement in a political election.” Heffernan sued under 42 U.S.C. 1983. His free-association claim resulted in a jury verdict of $105,000. The judge retroactively recused himself and vacated the verdict. A new judge granted the defendants summary judgment on a free-expression claim; on remand, another judge concluded that Heffernan had adequately pleaded and prosecuted his free-association claim, but found that Heffernan did not establish that he actually exercised his First Amendment rights. The Third Circuit affirmed; claims of retaliation based only on the perceived exercise of those rights are foreclosed. View "Heffernan v. City of Paterson" on Justia Law

The Bureau of Prisons terminated Kannikal on September 3, 1999. In 2001, Kannikal filed a formal complaint with the EEOC, but he did not receive an administrative hearing until 2006. Kannikal’s case was then held in abeyance because it was considered part of a pending class action complaint. In 2007, the Department of Justice informed Kannikal that his case would no longer be held in abeyance. Kannikal asked the EEOC about his case status in 2008 and 2009, but never received a response. He filed suit on March 28, 2012. The district court dismissed, citing 28 U.S.C. 2401(a), which provides that “every civil action commenced against the United States shall be barred unless the complaint is filed within six years after the right of action first accrues.” The court held that Kannikal’s cause of action accrued on October 17, 2001, 180 days after he filed his EEOC complaint, and expired six years later. The Third Circuit vacated, finding that section 2401’s six-year limitations period does not apply to suits brought under Title VII. View "Kannikal v. Att'y Gen. of the United States" on Justia Law

Daniels is an African-American educator born in 1950. She has a masters degree in elementary education and is certified as a reading specialist. She sued her former employer, the School District of Philadelphia, alleging violations of the Age Discrimination in Employment Act, 29 U.S.C. 621; Title VII of the Civil Rights Act, 42 U.S.C. 2000e; and the Pennsylvania Human Relations Act, substantively and by retaliating against her because she opposed what she believed was SDP’s discriminatory conduct in violation of the acts. The district court entered summary judgment in favor of the district. She appealed only the retaliation claim. The Third Circuit affirmed. Daniels failed to establish a causal link between her protected activities and the adverse actions; she did not show an “unusually suggestive” temporal proximity. View "Daniels v. Philadelphia Sch. Dist." on Justia Law

Flora worked as Luzerne County Public Defender from 1980- 2013. He became Chief Public Defender in 2010, maintaining a private practice. His predecessor had tried to secure additional funding by submitting weekly reports concerning excessive caseloads and staffing deficiencies. Flora obtained grant funding for representing juveniles, but was not able to obtain additional money for adult offenders. Flora reported that the existing level of resources did not allow the Office to provide constitutionally adequate representation. The County was unresponsive, so Flora refused representation to those not faced with incarceration. In 2012 Flora initiated a class action lawsuit on behalf of indigent defendants and sought an injunction to prevent his firing. The state court ordered the County to provide adequate funding and prohibited refusing representation to indigent defendants. While the parties were in mediation, the County approved new positions. The funding litigation followed the “Kids for Cash” scandal. From 2003-2008, about 50% of Luzerne County juvenile offenders appeared in court without counsel. Virtually all were adjudicated delinquent. Federal investigators uncovered that judges had accepted kickbacks from for-profit juvenile detention facilities to send unrepresented juveniles to those facilities. The Pennsylvania Supreme Court ordered vacatur and expungement of thousands of delinquency adjudications. Flora alleges that, in 2013, he learned that 3,000 adjudications had not been expunged and reported the matter. Flora was relieved of his duties. Flora sued, alleging retaliation for his funding lawsuit and for reporting noncompliance with the expungement order. The district court dismissed. The Third Circuit vacated, finding that, under the Supreme Court’s 2014 decision, Lane v. Franks, Flora pled facts sufficient to allege that he spoke as a citizen. View "Flora v. County of Luzerne" on Justia Law

Pearson is serving a life-term and alleged, in a 2009 suit under 42 U.S.C. 1983, a two-year campaign of harassment against him in retaliation for the filing of a 2006 civil lawsuit and grievances in 2006-2007. Pearson claimed that he was subjected to cell searches and relocations, denied a meal, and denied a job in retaliation for the filings. The district court dismissed on the basis that Pearson’s “non-trivial” allegations occurred before March, 2007 and were time-barred under Pennsylvania’s two year statute of limitations; that Pearson’s allegation based on his termination from his position was timely, but failed to state a claim because there were no facts that allow a plausible inference that it was caused by any protected activity. Pearson objected that the judge failed to toll the limitations period while Pearson exhausted his administrative remedies pursuant to 42 U.S.C. 1997e(a), the Prison Litigation Reform Act, and erred by not accepting the complaint’s allegations as true with respect to retaliatory discharge. The Third Circuit reversed, holding that the PLRA is a statutory prohibition under Pennsylvania’s tolling statute. If the court determines that Pearson has exhausted administrative remedies with respect to the retaliatory discharge claim, it should proceed to discovery. View "Pearson v. Sec'y Dep't of Corrs." on Justia Law

The Special Management Unit housing unit within the Lewisburg U.S. Penitentiary houses inmates identified as having violent tendencies or having a history of gang involvement while incarcerated. Inmates assigned to the SMU are confined to their cells for 23 hours a day, but can spend the remaining hour in a recreation cage. When first assigned to the SMU, inmates are interviewed by prison officials to ensure that inmates who may be hostile to each other are not housed in the same cell. Shelton, a USP inmate, filed a purported class action, alleging that the defendants have engaged in a pattern, practice, or policy of improperly placing inmates who are known to be hostile to each other in the same cell. He also claims that the defendants fail to intervene when the predictable inmate-on-inmate violence erupts, and that defendants improperly restrain inmates who refuse cell assignments with inmates who are known to be hostile to them. The district court denied Shelton’s motion for class certification and granted defendants’ motion for summary judgment. The Third Circuit affirmed dismissal of a Federal Tort Claims Act claim, but vacated the denial of class certification and summary judgment as to an Eighth Amendment claim. View "Shelton v. Bledsoe" on Justia Law

Dougherty, the Business Officer for Operations for the Philadelphia School District, was accountable for the Office of Capital Programs (OCP), which developed projects for School Reform Commission (SRC) approval. Dougherty reported to Nunery, who reported to Superintendent Ackerman. Ackerman directed OCP to install security cameras in “persistently dangerous” schools. Due to a short time frame, OCP could not use its bidding process and was required to select a pre-qualified contractor. Dougherty identified SDT as such a contractor, prepared a proposal, and submitted a resolution to Nunery. Under District policy, the Superintendent must approve the resolution before it is presented to the SRC. Dougherty did not receive a response from Nunery or Ackerman, nor was the resolution presented to the SRC. Ackerman allegedly rejected the SDT proposal for lack of minority participation, and directed that IBS, a minority-owned firm, be awarded the contract. IBS was not pre-qualified. SRC ratified the plan. Conflicts arose. Dougherty met with reporters, resulting in articles accusing Ackerman of violating state guidelines, and contacted the FBI, state representatives, and the U.S. Department of Education. Ackerman placed Dougherty on leave pending an investigation, which concluded that there was no unlawful motive in the contract award, but that Dougherty violated the Code of Ethics confidentiality section. SRC terminated Dougherty. In his suit, alleging First Amendment retaliation and violations of the Pennsylvania Whistleblower Law, the district court denied motions for summary judgment on the basis of qualified immunity. The Third Circuit affirmed. View "Dougherty v. Philadelphia Sch.Dist." on Justia Law

Working for “Cali Connect,” Thompson transported cocaine from California to Pittsburgh. Cooperating witnesses named Thompson. In wiretapped phone conversations, Thompson made drug-related comments. Texas troopers on I-40 near Amarillo, a “known corridor for narcotics,” stopped his truck, traveling eastbound at 84 mph in a 70 mph zone, and ran Thompson’s criminal history, which showed dated narcotics offenses, and a firearm offense. Thompson declined to consent to a search, but accepted responsibility for anything discovered in the truck. A K-9 unit dog alerted. The officers opened the truck-bed and smelled marijuana. Beneath a tarp lay five tubs containing marijuana. After speaking with DEA investigators, troopers searched the tailgate and found six kilograms of cocaine. Thompson was charged locally for the marijuana and was not informed about the discovery of cocaine. Weeks later, DEA officers executed search warrants on residences associated with Cali Connect, including Thompson’s. Investigators recovered two kilograms of cocaine. At DEA offices, six hours later, Thompson offered information about his sources and co-conspirators. He received a written waiver of his right to prompt presentment 12 hours after his arrest. Thompson continued to cooperate the next day and was presented 48 hours after his arrest. After denial of motions to suppress, Thompson pled guilty to conspiracy to distribute five kilograms or more of cocaine and conspiracy to launder monetary instruments. The Third Circuit affirmed denial of the motion to suppress the fruits of a search, finding reasonable suspicion, but vacated as to statements made while in custody, prior to being presented to a magistrate judge. View "United States v. Thompson" on Justia Law