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

KalshiEX LLC operates a federally licensed designated contract market (DCM) that allows users to trade event contracts, including those based on sports outcomes. In late 2024, after Kalshi began offering sports-related event contracts similar to those offered by a competitor, New Jersey issued a cease-and-desist letter. The state asserted that Kalshi’s activities violated the New Jersey Constitution and state gambling laws, particularly regarding betting on collegiate sports, and threatened legal action with significant penalties if Kalshi continued its operations within New Jersey.In response, Kalshi initiated proceedings in the United States District Court for the District of New Jersey, seeking a preliminary injunction to prevent enforcement of New Jersey’s gambling laws against its federally regulated contracts. The District Court granted the injunction, finding that Kalshi had a reasonable likelihood of success on the merits, would suffer irreparable harm without relief, and that the public interest favored enjoining enforcement of potentially preempted state law. New Jersey appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error, legal conclusions de novo, and the decision to grant the preliminary injunction for abuse of discretion. The Third Circuit affirmed the District Court’s order. The appellate court held that the Commodity Exchange Act (CEA) grants the Commodity Futures Trading Commission (CFTC) exclusive jurisdiction over swaps, including sports-related event contracts traded on CFTC-licensed DCMs. Both field and conflict preemption principles bar New Jersey from enforcing its gambling laws against these contracts. The court concluded that Kalshi demonstrated a likelihood of success on the preemption claim, irreparable harm in the absence of an injunction, and that the equities and public interest favored injunctive relief. Accordingly, the court affirmed the preliminary injunction. View "Kalshiex LLC v. Flaherty" on Justia Law

A Pennsylvania state prisoner with a history of opioid addiction participated in a prison Medication Assisted Treatment program, receiving Suboxone to help control his cravings. After prison officials twice accused him of possessing contraband and diverting his medication to other prisoners, he was removed from the treatment program. Instead of abruptly ending his medication, a prison doctor tapered his doses over a week to reduce withdrawal symptoms. The prisoner later suffered withdrawal effects and mental health challenges but was not reinstated in the program despite his requests. He claimed the diversion finding was unfair but did not allege personal animus or pretext by the officials involved.He filed a pro se lawsuit in the U.S. District Court for the Middle District of Pennsylvania against various prison officials and a doctor, alleging violations of the Eighth Amendment (cruel and unusual punishment), the Americans with Disabilities Act (ADA), and a state-law negligence claim. The District Court dismissed all claims, finding the federal claims inadequately pleaded and the state-law claim procedurally improper for lack of a certificate of merit under Pennsylvania law.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court affirmed the dismissal of the Eighth Amendment claim, holding that the complaint failed to allege deliberate indifference to medical needs as required by precedent; the officials’ actions were judged to be good-faith medical decisions, not constitutionally blameworthy conduct. The court also affirmed dismissal of the ADA claim, finding no plausible allegation that the prisoner was excluded from treatment “by reason of” his disability, but rather for diversion of medication. However, the court vacated the dismissal of the state-law negligence claim, as recent Supreme Court precedent abrogated the procedural requirement relied upon by the District Court, and remanded for further proceedings on that claim. View "DiFraia v. Ransom" on Justia Law

Law enforcement officers executed a search warrant at a residence where a firearm was discovered in a bag containing the defendant’s identification and two loaded magazines. The defendant was present in the bedroom with the bag and was on parole for a prior state offense. DNA swabs taken from the firearm, along with a sample from the defendant, were analyzed by the Pennsylvania State Police Crime Laboratory, which identified multiple DNA contributors but could not conclusively match the DNA to the defendant. The DNA evidence was then submitted to a private company using TrueAllele probabilistic genotyping software, which calculated an extremely high likelihood ratio indicating the DNA was much more likely to include the defendant as a contributor.The defendant moved to exclude the TrueAllele evidence in the United States District Court for the Middle District of Pennsylvania, arguing it was unreliable under Daubert v. Merrell Dow Pharmaceuticals, Inc. and Rule 702 of the Federal Rules of Evidence. After a two-day Daubert hearing featuring expert testimony from both sides, the District Court found that the government met its burden to demonstrate the reliability of TrueAllele and denied the motion to exclude. The District Court also rejected the defendant’s motion to dismiss the indictment on Second Amendment grounds. The defendant ultimately pleaded guilty, preserving his right to appeal these rulings, and was sentenced to 78 months of imprisonment, consecutive to an anticipated state sentence.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s Daubert ruling for abuse of discretion and its Second Amendment analysis de novo. The Third Circuit held that TrueAllele’s methodology was sufficiently reliable for admissibility, finding that it satisfied factors such as testability, low error rates, presence of governing standards, peer review, and general acceptance in the relevant scientific community. The Court also affirmed the District Court’s rejection of the defendant’s constitutional and sentencing challenges, and the judgment was affirmed. View "USA v. Anderson" on Justia Law

A Texas-based company distributed files online that enabled the 3D printing of functional, untraceable firearms. After New Jersey’s Attorney General issued a cease-and-desist letter and the state legislature enacted a statute prohibiting the distribution of such files to unlicensed individuals, the company and an affiliated nonprofit restricted New Jersey residents from accessing these files. The plaintiffs challenged the actions, alleging violations of the First, Second, and Fourteenth Amendments.Initially, the plaintiffs filed suit in the Western District of Texas, which dismissed the case for lack of personal jurisdiction. Plaintiffs then filed a similar suit in the District of New Jersey, alleging the statute constituted criminal censorship. After complex procedural maneuvers—including appeals and transfers between Texas and New Jersey, and requests for retransfer—the litigation proceeded in the District of New Jersey, which consolidated the relevant cases.The United States Court of Appeals for the Third Circuit reviewed the District of New Jersey’s decision to dismiss the complaint with prejudice. The Third Circuit affirmed the lower court’s rulings. It held that the district court did not abuse its discretion in denying retransfer to Texas. The court further held that the plaintiffs lacked standing to bring a Second Amendment claim, as there were no allegations that any plaintiff or member was prevented from 3D-printing a firearm. The court also found the statute was not void for vagueness under the Due Process Clause, as it provided fair notice of prohibited conduct. Finally, the court held that plaintiffs failed to plead sufficient facts showing that the computer code at issue was expressive and entitled to First Amendment coverage, as the complaint did not detail the nature or expressive use of the files. The dismissal with prejudice was affirmed. View "Defense Distributed v. Attorney General New Jersey" on Justia Law

Two individuals, one a Nigerian citizen and another a Jamaican citizen, were held in U.S. immigration detention for extended periods following the completion of criminal sentences or pending immigration proceedings. Both petitioned for writs of habeas corpus in the United States District Court for the Western District of Pennsylvania, challenging their prolonged detention without individualized bond hearings as violations of their Fifth Amendment rights. The District Court granted both petitions, ordered bond hearings, and both individuals were subsequently released on bond.Following their success, each petitioner sought attorneys’ fees and costs under the Equal Access to Justice Act (EAJA). The District Court found that the government’s position in opposing the habeas petitions was not "substantially justified" and awarded fees: $18,224.58 to the Nigerian petitioner and $15,841.60 to the Jamaican petitioner. The government appealed these fee awards to the United States Court of Appeals for the Third Circuit.The United States Court of Appeals for the Third Circuit addressed whether a habeas corpus petition challenging immigration detention under 28 U.S.C. § 2241 qualifies as a “civil action” under the EAJA, thus entitling prevailing parties to attorneys’ fees and costs. The Third Circuit held that such habeas actions are indeed “civil actions” within the meaning of the EAJA, relying on longstanding legal tradition and statutory interpretation. The court further affirmed that the government’s position in the Nigerian petitioner’s case was not substantially justified, due to the lengthy detention without a bond hearing. Accordingly, the Third Circuit affirmed the District Court’s awards of attorneys’ fees and costs to both petitioners. View "Michelin v. Warden Moshannon Valley Correctional Center" on Justia Law

Mahmoud Khalil, an Algerian citizen and lawful permanent resident, was arrested in March 2025 by Homeland Security agents at his New York City apartment and charged as removable under the Immigration and Nationality Act’s foreign-policy provision. Khalil, a Columbia University student and vocal advocate for Palestinian rights, was accused of having activities with potentially adverse foreign policy consequences for the United States. After his arrest, he was quickly transferred from New York to New Jersey, and then to Louisiana. His attorney initially filed a habeas petition in the Southern District of New York, seeking to enjoin his detention and removal, arguing retaliation against protected speech, and due process violations.The Southern District of New York, finding Khalil was already detained in New Jersey when the petition was filed, transferred the case to the U.S. District Court for the District of New Jersey. The New Jersey District Court asserted jurisdiction, denied the government’s motion to dismiss, and determined that the INA did not strip it of subject-matter jurisdiction. The court granted Khalil’s motion for a preliminary injunction on the foreign-policy removal charge, ordered that he not be removed, and later ordered his release from custody. Meanwhile, an immigration judge in Louisiana found Khalil removable on both foreign-policy and fraud charges and ordered his removal, resulting in conflicting mandates.Reviewing the case, the U.S. Court of Appeals for the Third Circuit held that the District Court had habeas jurisdiction, as the petition was properly transferred and related back to Khalil’s district of confinement. However, the Third Circuit found that 8 U.S.C. § 1252(b)(9) of the INA strips the District Court of subject-matter jurisdiction over claims arising from removal actions, channeling such claims into a petition for review of a final order of removal in the court of appeals. As a result, the Third Circuit vacated and remanded with instructions to dismiss Khalil’s habeas petition. View "Khalil v. President United States of America" on Justia Law

Ryan Mendoza checked into a Pittsburgh hotel for a two-night stay, receiving a receipt indicating his departure date as February 25. The hotel had a posted noon checkout time, and guests could leave either by visiting the front desk or simply walking out. By noon on February 25, Mendoza had not checked out at the front desk, so hotel staff placed him on a “due-out” list and inspected his room. Later that afternoon, the hotel manager discovered a backpack with packages of white powder and called the police. Around 5:20 p.m., officers entered the room without a warrant and confirmed with the manager that Mendoza’s stay had ended and he no longer had rights to the room. Mendoza returned to the hotel at 10:00 p.m. and was arrested.In the United States District Court for the Western District of Pennsylvania, Mendoza moved to suppress the evidence obtained during the warrantless search of the hotel room, arguing that he retained a Fourth Amendment privacy interest in the room because he had not formally checked out. The District Court denied the motion, finding that Mendoza did not have a reasonable expectation of privacy in the room after checkout time, based on hotel policies and practices.The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and exercised plenary review over its legal determinations. The Third Circuit held that Mendoza’s expectation of privacy in the hotel room five hours after checkout time was not objectively reasonable. The court emphasized that, absent any communication about a late checkout or ambiguous circumstances, society does not recognize an expectation of privacy in a hotel room well after checkout time. Accordingly, the Third Circuit affirmed the District Court’s denial of the motion to suppress. View "USA v. Mendoza" on Justia Law

In November 2020, a United States Coast Guard cutter intercepted a vessel in international waters, far from Colombia. The vessel attempted to flee but was stopped and boarded. On board, authorities found three occupants—two Costa Rican nationals, including Munoz, and a Colombian national—and seized 383 kilograms of cocaine. The vessel lacked any registration documents, flag, or markings indicating nationality, and all occupants claimed to be the master without asserting the vessel’s nationality when prompted by Coast Guard officials. Based on these facts, the Coast Guard determined the vessel was subject to United States jurisdiction.A grand jury in the District Court of the Virgin Islands indicted Munoz for conspiracy and possession with intent to distribute cocaine under the Maritime Drug Law Enforcement Act (MDLEA). Munoz moved to dismiss the indictment, arguing that the MDLEA was unconstitutional and that the United States lacked jurisdiction over the vessel, requesting an evidentiary hearing. The District Court denied his motion without a hearing. Munoz then entered a conditional guilty plea to the conspiracy charge, preserving his right to appeal the denial of his motion to dismiss. After sentencing, the government dismissed the possession charge per the plea agreement, and Munoz timely appealed.The United States Court of Appeals for the Third Circuit reviewed Munoz’s constitutional challenge to the MDLEA and the District Court’s refusal to hold an evidentiary hearing. The court held that the MDLEA does not exceed Congress’s authority under the Felonies Clause of Article I, Section 8, Clause 10 of the Constitution, because the Felonies Clause is not limited by international law. It also held that the District Court did not abuse its discretion by declining to hold an evidentiary hearing, as the parties had stipulated to all material facts, leaving only legal questions for resolution. The Third Circuit affirmed the judgment. View "USA v. Munoz" on Justia Law

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

A New Jersey physician wished to provide medical aid in dying to terminally ill patients, including nonresidents seeking this service under New Jersey’s law that permits doctor-assisted suicide. The relevant statute allows only New Jersey residents, with a prognosis of six months or fewer to live, to request and obtain a prescription for life-ending medication. Patients must demonstrate residency through various documents and satisfy several procedural safeguards. The plaintiff, a physician, challenged the law’s residency requirement after two terminally ill nonresidents who had joined the suit died during the course of litigation.The United States District Court for the District of New Jersey dismissed the complaint. The court reasoned that the right to receive medical aid in dying was neither a fundamental privilege nor a fundamental right requiring extension to nonresidents under the Privileges and Immunities Clause or the Equal Protection Clause. It further found the law was not economic protectionism and survived rational-basis review. The plaintiff appealed this decision.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. It held that New Jersey’s restriction of doctor-assisted suicide to its own residents does not violate the Privileges and Immunities Clause because there is no longstanding tradition making such access a fundamental privilege, nor does it violate the Equal Protection Clause, as there is no fundamental right to assisted suicide or to interstate travel for this purpose. The Third Circuit also determined that the law does not offend the dormant Commerce Clause since it is a moral rather than commercial regulation and does not discriminate against out-of-state economic interests. The court concluded that New Jersey’s residency requirement is constitutionally permissible, justified by the state’s interests in protecting doctors, avoiding interstate friction, and safeguarding patients. View "Bryman v. Murphy" on Justia Law