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

Wilson was convicted of the Swift murder in 1984 and was sentenced to life in prison. Four years later, Wilson was convicted of the unrelated Lamb murder and was sentenced to death. After Wilson exhausted direct and collateral appeals in Pennsylvania state court, he sought habeas relief under 28 U.S.C. 2254 claiming that the Swift jury was empaneled in violation of Batson v. Kentucky. In 2004, the district court granted the writ. The Third Circuit affirmed. The state did not seek a stay or an extension of the 180- day period, but Wilson was neither retried nor released because he was on death row for the Lamb murder. Wilson then sought to invalidate the Lamb conviction, claiming Brady violations. The Third Circuit affirmed issuance of a conditional writ. In 2010, he was re-arraigned for both murders. Wilson moved to enforce habeas corpus. The district court denied the motions, reasoning that after the 180 days passed, the government could no longer imprison Wilson for the Swift murder, but he was held for the Lamb murder. Since 2010, Wilson has been held as a pretrial defendant for both murders. Denying his Rule 60(b) motion, the court reasoned that speedy trial rights exist to protect against claimed prejudice as the result of the delay. Such claims had to be exhausted in state court and Wilson did not establish extraordinary circumstances. The Third Circuit affirmed. The district court had jurisdiction to adjudicate Wilson’s Rule 60(b) motion and did not err in requiring Wilson to exhaust the new claims in state court. View "Wilson v. Sec'y Pa. Dep't of Corrs." on Justia Law

In 2007, Werkheiser was elected to the three-member Pocono Township Board of Supervisors. Supervisor Hess was elected in 2009; Bengel was elected in 2011. Supervisors are permitted to be employed by the Township. Werkheiser was appointed Township Roadmaster by the Board. Hess, as Chairman of the Board, Secretary, and Treasurer, received $36,000 per year in salary and benefits. In 2012, Hess took 10-days leave. Froio was selected to assume Hess’s administrative duties. Over Werkheiser’s objection, Bengel and Hess voted to hire Froio as Township Administrator, with compensation of $70,000. As Froio’s position developed, Hess’s responsibilities and workload decreased. Hess continued to be paid. Werkheiser objected to creation of a new position with greater expense and to paying Hess when his duties were being performed by Froio. Hess and Bengel began private deliberations to deny Werkheiser reappointment and to replace him with Bengel. In 2013, Werkheiser was formally denied reappointment. Werkheiser sued, asserting First Amendment retaliation and state law violations. The district court reasoned that there were important differences between public employees and elected officials; found that Werkheiser had established a constitutional violation; and denied a motion to dismiss. The Third Circuit held that the defendants were entitled to qualified immunity; the contours of the First Amendment right at issue were not clearly established. View "Werkheiser v. Pocono Township" on Justia Law

Fantone was incarcerated in a Pennsylvania state correctional institution. The Parole Board granted him parole, but rescinded that decision because of pending prison discipline proceedings. Fantone sued, alleging that defendants unlawfully caused him to be confined in a prison Restrictive Housing Unit (RHU), which led the Parole Board to rescind his parole. The district court dismissed. The Third Circuit reversed and remanded a claim that correctional officer Burger unlawfully retaliated against Fantone by having him retained in the RHU after the expiration of his disciplinary confinement because Fantone would not confess to the disciplinary charges and because Fantone filed a grievance charging that Burger threatened him. The court affirmed dismissal of Fantone’s due process and conspiracy claims, agreeing that where state law provides parole authorities with complete discretion to rescind parole prior to an inmate’s release, the inmate does not have a constitutionally protected liberty interest in being paroled before his actual release. In addition, an inmate does not have a right to be confined in any particular housing unit in a prison; absent significant hardship, when an inmate is placed in a restrictive custody unit, his liberty interests have not been infringed. View "Fantone v. Latini" on Justia Law

In 1999, Allstate reorganized its business and terminated the at-will employment contracts of about 6,200 sales agents, offering them conversion to independent contractor status; $5,000 and an economic interest in their accounts, to be sold to buyers approved by Allstate; severance pay equal to one year’s salary; or severance pay of 13 weeks’ pay. Employees who chose independent contractor status received a bonus of at least $5,000, were not required to repay any office-expense advances, and acquired transferable interests in their business two years after converting. All employees who chose not to convert and left the company were bound by noncompetition covenants in their original contracts. As a condition of becoming independent contractors, agents were required to sign a release waiving existing legal claims against Allstate. The Equal Employment Opportunity Commission sued, claiming that the company violated federal anti-retaliation laws. The district court reversed. The Third Circuit affirmed, noting the settled rule that employers can exchange consideration for releases of claims and that EEOC established neither protected activity nor an adverse action. View "Equal Emp't Opportunity Comm'n v. Allstate Ins. Co" on Justia Law

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