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

Police officers observed a man and his girlfriend in a car at a location known for drug trafficking. After smelling marijuana and spotting evidence of its use in the vehicle, the officers approached the man inside a store, where he consented to a pat-down search that yielded nothing. Outside the store, the couple initially consented to a search of the car but later revoked consent, leading the officers to arrest and handcuff the man. He was searched again on the hood of the car, with no contraband found. The officers then transported him to the police station, where they conducted a strip search solely for evidence, but nothing was recovered.The U.S. District Court for the Middle District of Pennsylvania reviewed the man’s federal civil-rights claims under 42 U.S.C. § 1983, challenging the stop, arrest, and three searches as unreasonable under the Fourth Amendment and retaliatory under the First Amendment. The District Court granted summary judgment to the officers on all federal claims, finding the initial stop, arrest, and first two searches reasonable, and the strip search protected by qualified immunity. It dismissed the state-law claims for lack of supplemental jurisdiction.The United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that while the initial stop, arrest, and two searches were reasonable, the search-incident-to-arrest doctrine does not justify strip searches outside of a jail or prison without a warrant, exigent circumstances, or consent. A warrant supported by probable cause is required for strip searches in such contexts. However, because this legal limitation was not clearly established at the time, the officers were entitled to qualified immunity. The court also concluded that the First Amendment retaliation claim was barred by qualified immunity. View "Beatty v. Gardner" on Justia Law

Three individuals alleged that New Jersey child protection caseworkers violated their constitutional rights during investigations into suspected child abuse. The caseworkers entered the plaintiffs’ home without a warrant, pressured them to sign family agreements under threat of child removal, and ultimately removed the children from parental custody without prior court authorization. The removal was based on concerns about one parent’s alleged past violence, home conditions, and another parent’s mental health history. The plaintiffs claimed these actions violated their Fourth Amendment rights and their substantive and procedural due process rights under the Fourteenth Amendment.The United States District Court for the District of New Jersey dismissed the complaint, finding the defendants were entitled to qualified immunity. The court relied on facts outside the complaint, including allegations from a child abuse report and statements from caseworkers, to support its ruling. The District Court also dismissed claims for money damages against the Division and its employees in their official capacities and found one plaintiff lacked standing. On appeal, the United States Court of Appeals for the Third Circuit reviewed the dismissal de novo, considering only the facts alleged in the complaint and not external materials.The Third Circuit affirmed the dismissal of most claims, including the substantive and procedural due process claims, holding that the law was not clearly established to put the defendants on notice that their conduct violated constitutional rights. However, the court reversed the dismissal of the Fourth Amendment claim against the caseworker who entered the home without a warrant. The court held that the plaintiffs plausibly alleged a violation of clearly established Fourth Amendment law, and that qualified immunity did not shield the caseworker from liability on this claim. The case was remanded for further proceedings on the Fourth Amendment claim. View "O'Bryant v. DCP&P" on Justia Law

Police officers investigating a suspicious package at a UPS facility in Pennsylvania found it to be heavily taped, sent by next-day air, and addressed to a likely fake recipient. A drug-sniffing dog alerted to the presence of drugs, and a subsequent search warrant revealed six pounds of methamphetamine inside the box. To identify the intended recipient, officers sought and obtained a GPS tracker order and a search warrant for Apartment 2 at the delivery address. The officer’s affidavit also requested permission to secure the package at any secondary location, but neither the warrant nor the tracker order explicitly authorized entry into other residences.When the package was delivered, Davone Walker took it into Apartment 1, a different apartment in the same building. Officers waited but did not see the box opened. Eventually, they entered Apartment 1 without a warrant specific to that location, secured the scene, and applied for a new warrant, which permitted a search of Apartment 1. The search uncovered substantial quantities of methamphetamine, fentanyl, cocaine, and drug paraphernalia. Walker was charged with drug offenses and moved to suppress the evidence, arguing the original warrant did not cover Apartment 1 and the tracker order gave no authority for entry.The United States District Court for the Eastern District of Pennsylvania denied Walker’s suppression motion. It found that the officer’s belief he was authorized to enter Apartment 1 was unreasonable, but concluded the mistake was isolated negligence, not grossly negligent or deliberate misconduct warranting exclusion.The United States Court of Appeals for the Third Circuit reviewed the facts for clear error and legal conclusions de novo. It held that suppression is reserved for deliberate, reckless, or grossly negligent misconduct, not isolated mistakes. Finding Trooper Montz’s error to be, at most, isolated negligence, the court affirmed both the denial of Walker’s suppression motions and his conviction. View "USA v. Walker" on Justia Law

A national firearms industry trade association challenged the constitutionality of a New Jersey statute enacted in 2022, which imposes civil liability on gun industry members for certain “public nuisance” conduct related to the sale, manufacture, distribution, import, or marketing of firearms and related products. The law allows the state to bring enforcement actions against gun industry members for actions deemed unlawful or unreasonable, as well as for failing to implement “reasonable controls.” The association argued that the statute is unconstitutional under the Interstate Commerce Clause, the First and Second Amendments, and is preempted by the federal Protection of Lawful Commerce in Arms Act (PLCAA).Initially, the United States District Court for the District of New Jersey granted a preliminary injunction against enforcement of the law, but the United States Court of Appeals for the Third Circuit vacated that injunction, holding that the association lacked Article III standing because enforcement of the law was speculative at that time. After the state initiated several enforcement actions under the statute—including suits against two members of the association—the association moved to reopen the case, amend its complaint, and again seek a preliminary injunction. The District Court found standing but abstained from ruling on the merits under the Younger abstention doctrine, which generally prohibits federal courts from interfering with certain ongoing state proceedings.The United States Court of Appeals for the Third Circuit reviewed the case and held that the association now has standing due to the substantial risk of imminent enforcement against its members, evidenced by the state’s recent lawsuits. The court further held that Younger abstention does not apply because the association is not a party to any ongoing state proceeding and does not have the type of control or relationship with its members that would warrant abstention. Accordingly, the Third Circuit reversed the District Court’s order. View "National Shooting Sports Foundation v. Attorney General New Jersey" on Justia Law

Federal agents intercepted a package containing three silencers shipped from China to Joseph Berger’s residence in Bethlehem, Pennsylvania. Upon searching the home with a warrant, agents discovered more than sixty firearms, including thirteen fully automatic guns (mostly AK-47 variants), a dozen silencers, and parts for converting semi-automatic weapons into machine guns. Berger was indicted for possession of machine guns and unregistered silencers, violations of federal law. He is a Navy veteran who lived with his father, and evidence suggested both were involved in acquiring conversion parts.In the U.S. District Court for the Eastern District of Pennsylvania, Berger raised an as-applied Second Amendment challenge. The court denied his challenge, finding that machine guns were “dangerous and unusual weapons” not commonly used for self-defense, and that silencers were not “bearable arms” under the Second Amendment. Berger then pleaded guilty to possessing a machine gun and an unregistered silencer, reserving his right to appeal the Second Amendment issue. The government dismissed the charge of possessing an unregistered machine gun as part of the plea agreement.The United States Court of Appeals for the Third Circuit reviewed Berger’s appeal de novo, focusing on pure issues of law. The court held that the Second Amendment does not protect possession of machine guns because they are not commonly used for lawful purposes and are classified as “dangerous and unusual.” Furthermore, the registration requirement for silencers under the National Firearms Act imposes only a minimal, objective burden and does not infringe upon Second Amendment rights. The court affirmed Berger’s conviction and sentence, holding that both the machine-gun ban and the silencer registration requirement are constitutional as applied to Berger. View "USA v. Berger" on Justia Law

The case concerns a noncitizen from El Salvador who lawfully entered the United States on a nonimmigrant temporary visa with work authorization. While residing in the United States, he was stopped by a Pennsylvania state trooper for a traffic violation. During the stop, the officer observed a rifle cartridge in the vehicle, leading to a search warrant and the discovery of a loaded pistol without a serial number. The individual admitted to purchasing the pistol in Maryland.He was indicted by a grand jury for violating 18 U.S.C. § 922(g)(5)(B), a statute prohibiting nonimmigrant visa holders from possessing firearms. He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The United States District Court for the Middle District of Pennsylvania denied his motion, holding the statute constitutional. After entering a conditional guilty plea, reserving his right to appeal the constitutional issue, he was sentenced to twenty-four months’ imprisonment and one year of supervised release.On appeal, the United States Court of Appeals for the Third Circuit addressed whether 18 U.S.C. § 922(g)(5)(B) is facially unconstitutional under the Second Amendment. The Court, following the framework from New York State Rifle & Pistol Ass’n v. Bruen, assumed without deciding that some noncitizens may be included among “the people” protected by the Second Amendment. The Court then considered whether the statute is consistent with the nation’s historical tradition of firearm regulation. It found that there is a longstanding historical practice of disarming individuals considered disloyal to the sovereign, including noncitizens with allegiance to another country. Concluding that § 922(g)(5)(B) is relevantly similar to these historical analogues, the Court held that the statute does not violate the Second Amendment and affirmed the conviction. View "USA v. Aleman-Lozano" on Justia Law

Two nonprofit organizations that engage in nationwide issue advocacy challenged Delaware’s Elections Disclosure Act, which requires groups spending over $500 on electioneering communications near an election to publicly disclose donors giving more than $100 during the relevant cycle. The law’s disclosure obligations are broad: they are not limited to donors earmarking funds for political ads, nor can donors avoid disclosure by restricting the use of their contributions. The law also looks back several years for purposes of disclosure. The organizations, which have not previously run such communications in Delaware but claim they intend to do so in the upcoming election, argue that the law violates the First Amendment.After the organizations filed suit in the U.S. District Court for the District of Delaware, they sought a preliminary injunction to halt enforcement of the Act. The District Court denied the request, finding no likelihood of success on the facial challenge because prior Third Circuit precedent, Delaware Strong Families v. Attorney General of Delaware, had upheld the Act and the Supreme Court’s subsequent decision in Americans for Prosperity Foundation v. Bonta did not clearly abrogate that ruling. The court also doubted the as-applied challenge, citing the plaintiffs’ failure to offer specific evidence of harm to donors. The District Court emphasized the law’s decade-long enforcement and the lack of urgent need to change the status quo.The United States Court of Appeals for the Third Circuit reviewed the denial. Applying a deferential standard, the court found that the plaintiffs had not made a clear showing of entitlement to a preliminary injunction. It held that even with some likelihood of success and possible irreparable injury, the balance of equities and the public interest favored preserving the longstanding status quo. The court affirmed the District Court’s order denying the preliminary injunction. View "Americans for Prosperity Foundation v. Albence" on Justia Law

Several plaintiffs challenged a New Jersey law requiring any doctor who wishes to provide telemedicine services to a patient located in New Jersey to first obtain a license from the state’s Board of Medical Examiners. The plaintiffs included two physicians licensed outside New Jersey and three New Jersey residents who wanted to receive virtual medical consultations from those doctors. The doctors argued that New Jersey’s licensing requirement placed an undue burden on their ability to provide telemedicine services, especially since they were already licensed in their home states. The patients and a parent also raised claims based on their rights to receive medical advice and direct their child’s care.The United States District Court for the District of New Jersey dismissed all the plaintiffs’ claims for failure to state a claim. The court held that the licensing requirement did not violate the First Amendment, the dormant Commerce Clause, the Privileges and Immunities Clause, or substantive due process. The plaintiffs appealed, maintaining that the law, as applied, unconstitutionally restricted their right to free speech and imposed excessive burdens on interstate medical practice.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal of all claims, with one modification. The Third Circuit held that requiring a medical license to provide telemedicine services is a content-based restriction on speech, but such regulations have a long tradition and thus do not warrant strict scrutiny. Instead, the law survives intermediate scrutiny because the burdens imposed are not substantial compared to New Jersey’s interest in ensuring competent medical care. The court further held that the law does not violate the dormant Commerce Clause or the Privileges and Immunities Clause, as it applies equally to all doctors regardless of their state of residence. The court also found that the plaintiff asserting a substantive due process right lacked standing, and that claim was ordered dismissed without prejudice for lack of jurisdiction. View "MacDonald v. President NJ State Board of Medical Examiners" on Justia Law

Two individuals, citizens of Ecuador and Brazil, respectively, entered the United States without inspection in 2001 and 2014. In late 2025 and early 2026, each was arrested by U.S. Immigration and Customs Enforcement and detained, without the possibility of bond, under 8 U.S.C. § 1225(b)(2)(A). This marked a change in government practice, as similar noncitizens had previously been detained or released under 8 U.S.C. § 1226(a), which allows for discretionary bond if the person is not a danger or flight risk. In 2025, the government began applying § 1225(b)(2)(A) to noncitizens already present in the United States who entered without inspection, resulting in mandatory detention without bond.Both individuals filed habeas petitions in the United States District Court for the Eastern District of Pennsylvania, arguing their detentions violated the Immigration and Nationality Act (INA). The district courts granted their petitions, finding that § 1225(b)(2)(A) did not apply to them and that their continued detention without bond violated the INA. One district court also held that such detention violated the Fifth Amendment’s Due Process Clause. Both petitioners were subsequently released, and the government appealed these decisions.The United States Court of Appeals for the Third Circuit reviewed the statutory language and structure of the INA and considered relevant precedent. The court held that § 1225(b)(2)(A) applies only to noncitizens who are both “applicants for admission” and “seeking admission,” meaning those engaged in a present or ongoing attempt to gain lawful entry into the United States. The court concluded that noncitizens already present in the United States who are not actively seeking admission are not subject to mandatory detention under this provision and should be considered under § 1226(a), which allows for bond. The Third Circuit also held that detaining such individuals without a bond hearing violates the Due Process Clause. The court affirmed the district courts’ orders directing the release of the petitioners. View "Morocho v. Warden Philadelphia FDC" on Justia Law

A member of Congress from New Jersey was charged with three counts of violating federal law after allegedly physically interfering with federal officials during an oversight visit to a federal immigration detention facility in Newark. During the visit, the Congresswoman and other Representatives encountered Newark’s Mayor, who was ordered to leave the premises by federal agents. When federal agents attempted to arrest the Mayor, the Congresswoman allegedly placed herself between the Mayor and an agent, forcibly made contact with the agent, and later pushed past another federal officer to reenter the facility. The charges stem from these physical altercations and the Congresswoman’s efforts to impede the Mayor’s arrest.The United States District Court for the District of New Jersey denied the Congresswoman’s motions to dismiss the indictment. The court found that her conduct was not protected by legislative immunity under the Speech or Debate Clause, concluding it was non-legislative in nature. The court also rejected her arguments based on the separation of powers doctrine, distinguishing between Presidential and legislative immunities. Additionally, the court ruled against her selective and vindictive prosecution claims, finding she failed to demonstrate discriminatory effect or personal animus by the prosecution.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit affirmed the denial of legislative immunity for Counts One and Two, holding that prosecution of those charges would not require the Congresswoman to answer for any legislative acts. The court vacated and remanded with respect to Count Three for further consideration as to whether legislative immunity might apply. The court dismissed the remainder of her appeal, including claims of selective and vindictive prosecution, for lack of jurisdiction. View "USA v. McIver" on Justia Law