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

Roger Esteban Real, a native and citizen of Colombia, participated in protests in his home country, leading to his arrest and mistreatment by police. Fearing for his safety, he fled to the United States with his family in March 2022. Upon arrival, he surrendered to immigration authorities, who did not issue him a Notice to Appear (NTA) or inquire about his fear of returning to Colombia. He was instructed to attend a court hearing in 2025 and to check in regularly using a cell phone provided by the authorities.Real was later arrested for crimes related to a domestic dispute, and two months after this arrest, the Department of Homeland Security (DHS) issued him an NTA. An Immigration Judge (IJ) found him removable and, in July 2023, Real applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The IJ granted him withholding of removal but denied his asylum application, citing his failure to meet the one-year filing deadline and lack of extraordinary circumstances to excuse the delay. The Board of Immigration Appeals (BIA) dismissed his appeal, agreeing with the IJ's findings.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the government's failure to notify Real of the one-year asylum application deadline did not constitute a due process violation. Additionally, the court determined that it lacked jurisdiction to review Real's claim of extraordinary circumstances excusing his late filing, as such determinations are discretionary and not subject to judicial review. Consequently, the court denied the petition in part and dismissed it in part. View "Real v. Attorney General" on Justia Law

Sun Valley Orchards, a New Jersey farm, was accused by the U.S. Department of Labor (DOL) of breaching an employment agreement under the H-2A nonimmigrant visa program. The DOL alleged that Sun Valley failed to provide adequate housing, meal plans, transportation, and guaranteed work hours to its workers, as stipulated in the job order. The DOL imposed civil penalties and back wages totaling hundreds of thousands of dollars through administrative proceedings.The case was first reviewed by an Administrative Law Judge (ALJ), who affirmed most of the DOL's findings but slightly modified the penalties and back wages. Sun Valley then appealed to the Administrative Review Board, which upheld the ALJ's decision. Subsequently, Sun Valley challenged the DOL's decision in the United States District Court for the District of New Jersey, arguing that the administrative proceedings violated Article III of the Constitution, among other claims. The District Court dismissed Sun Valley's claims, holding that the DOL's actions fit within the public-rights doctrine and that the agency had statutory authority to impose penalties and back wages.The United States Court of Appeals for the Third Circuit reviewed the case and held that Sun Valley was entitled to have its case decided by an Article III court. The court found that the DOL's enforcement action resembled a common law breach of contract suit, which traditionally would be heard in a court of law. The court also determined that the case did not fit within the public rights exception to Article III adjudication, as the H-2A labor certification regulations primarily concern domestic employment law rather than immigration control. Consequently, the Third Circuit reversed the District Court's decision and remanded the case with instructions to enter judgment in favor of Sun Valley. View "Sun Valley Orchards LLC v. United States Department of Labor" on Justia Law

Safehouse, a Pennsylvania nonprofit corporation, was established in 2018 to address opioid abuse in Philadelphia by providing overdose prevention services, including supervised illegal drug use. Safehouse argues that its activities are motivated by a religious belief in the value of human life and that government intervention substantially burdens its religious exercise.The United States District Court for the Eastern District of Pennsylvania initially determined that Safehouse’s proposed activities did not violate 21 U.S.C. § 856(a)(2). However, the Third Circuit Court of Appeals reversed this decision, holding that Safehouse’s activities would indeed violate the statute. On remand, the District Court dismissed Safehouse’s Religious Freedom Restoration Act (RFRA) and Free Exercise counterclaims, reasoning that non-religious entities are not protected by these provisions. Safehouse appealed this dismissal.The United States Court of Appeals for the Third Circuit reviewed the case and held that the District Court erred in its interpretation. The Third Circuit determined that RFRA and the Free Exercise Clause extend protections to non-natural persons, including non-religious entities like Safehouse. The court emphasized that RFRA’s plain text and Free Exercise doctrine protect any “person” exercising religion, which includes corporations and associations. The court reversed the District Court’s dismissal of Safehouse’s RFRA and Free Exercise counterclaims and remanded the case for further consideration of whether Safehouse has plausibly pleaded these claims. The appeal by José Benitez, President of Safehouse, was dismissed due to lack of appellate standing. View "United States v. Safehouse" on Justia Law

CoreCivic, Inc. has contracted with the federal government since 1996 to operate a private immigration detention center in Elizabeth, New Jersey. In 2023, CoreCivic planned to renew its contract, but New Jersey passed a law (AB 5207) prohibiting new, expanded, or renewed contracts for civil immigration detention. CoreCivic sued, arguing that the law violates the Supremacy Clause by infringing on intergovernmental immunity and being preempted by federal law. The United States supported CoreCivic, emphasizing the detention center's critical role in federal immigration enforcement.The United States District Court for the District of New Jersey granted summary judgment in favor of CoreCivic. The court found that AB 5207 interferes with the federal government's discretion in detaining aliens, violating intergovernmental immunity and being preempted by federal law. New Jersey appealed the decision.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit held that AB 5207 directly regulates the federal government by effectively banning contracts for immigration detention, a core federal function. The court emphasized that the law's impact on federal operations is substantial, as it would cripple ICE's ability to detain and remove aliens efficiently. The court concluded that New Jersey's law violates intergovernmental immunity and is unconstitutional as applied to CoreCivic. View "CoreCivic, Inc. v. Governor of New Jersey" on Justia Law

Axalta Coating Systems LLC ("Axalta") provided a can of flammable paint to FedEx for air shipment. The paint spilled during transit due to a loose lid. The Federal Aviation Administration (FAA) filed an administrative complaint alleging Axalta failed to package the paint according to the Hazardous Materials Regulations (HMR). An Administrative Law Judge (ALJ) found Axalta in violation and imposed a $1,900 penalty, which the FAA Administrator affirmed. Axalta petitioned for review, arguing the administrative adjudication violated the Seventh Amendment's jury trial guarantee, referencing the Supreme Court's decision in SEC v. Jarkesy.The ALJ denied Axalta's motion to dismiss the complaint and a motion to disqualify the ALJ. After a hearing, the ALJ concluded Axalta violated 49 C.F.R. § 171.2(e) and 49 C.F.R. § 173.24(b)(1), assessing a $1,900 penalty. Axalta appealed, and the FAA cross-appealed for a higher penalty. The Administrator affirmed the ALJ's decision. Axalta then petitioned the United States Court of Appeals for the Third Circuit for review.The Third Circuit held that the administrative adjudication did not violate the Seventh Amendment. The court distinguished the case from Jarkesy, noting that the HMR's technical standards were not derived from common law, unlike the securities fraud provisions in Jarkesy. The court concluded that the FAA's enforcement action was a public right that could be adjudicated administratively without a jury. The court also rejected Axalta's additional arguments, including claims of unconstitutional delegation of legislative power, improper ALJ appointment, statute of limitations issues, and due process violations. The petition for review was denied. View "Axalta Coating Systems LLC v. Federal Aviation Administration" on Justia Law

Erik Harris, a frequent marijuana user, purchased three pistols over a short period. Each time, he falsely stated on federal forms that he was not an unlawful user of marijuana. After losing one of the guns while intoxicated, Harris reported it stolen and bought a replacement. When the missing gun was found with a felon, Harris admitted to regular marijuana use during police questioning.The United States District Court for the Western District of Pennsylvania denied Harris's motion to dismiss the charges, which included three counts under 18 U.S.C. §922(g)(3) for possessing guns as an unlawful drug user and three counts under §922(a)(6) for lying to obtain the guns. The court concluded that §922(g)(3) was constitutional as applied to Harris, using means-end scrutiny. Harris then pleaded guilty to all counts but preserved his right to appeal the denial of his motion to dismiss.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that history and tradition justify §922(g)(3)’s restrictions on those who pose a special danger of misusing firearms due to frequent drug use. However, the court found insufficient facts to determine whether the law's restrictions are constitutional as applied to Harris. The court affirmed the statute's constitutionality in general but vacated Harris's conviction under §922(g)(3) and remanded the case for further fact-finding. The court also held that §922(g)(3) is not unconstitutionally vague as applied to Harris and upheld his convictions under §922(a)(6) for lying on the federal forms. View "United States v. Harris" on Justia Law

Ronell Moses was driving through his Pittsburgh suburb when Officer Dustin Hess, in a marked police SUV, smelled burnt marijuana and saw that Moses's car windows were tinted very dark, both of which are illegal. The officer followed Moses to his home, where Moses parked in his driveway. The officer walked up the driveway, searched Moses's car, and found a loaded, stolen pistol. Moses, a felon on probation, was arrested and charged with possessing a gun and ammunition as a felon.The United States District Court for the Western District of Pennsylvania denied Moses's motion to dismiss the indictment, which challenged the constitutionality of the law under the Second Amendment. The court also denied his motion to suppress the gun, rejecting his claim that the officer had invaded his home's curtilage without a warrant. Moses then pleaded guilty conditionally, preserving his right to appeal the curtilage issue and the constitutionality of the law.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the officer did not invade Moses's curtilage by walking halfway up the driveway, as the driveway was not an extension of Moses's home. The court applied a de novo standard of review to curtilage decisions, aligning with other circuits. The court also held that the officer's actions were constitutional and that Moses, as a felon on parole, could be prosecuted for possessing a gun. The court affirmed Moses's conviction. View "United States v. Moses" on Justia Law

AstraZeneca Pharmaceuticals LP and AstraZeneca AB challenged the Drug Price Negotiation Program created by the Inflation Reduction Act of 2022, which directs the Centers for Medicare & Medicaid Services (CMS) to negotiate prices for certain high-expenditure drugs. CMS issued guidance on selecting qualifying drugs for 2026, including Farxiga, manufactured by AstraZeneca. AstraZeneca sued the Secretary of the Department of Health and Human Services and the CMS Administrator, claiming the Negotiation Program violated procedural due process and that parts of CMS’s guidance violated the Administrative Procedure Act (APA).The United States District Court for the District of Delaware ruled that AstraZeneca failed to state a due process violation and lacked standing to pursue its APA claims. The court entered judgment in favor of the government.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that AstraZeneca lacked Article III standing to challenge the CMS guidance under the APA because the company did not demonstrate a concrete and particularized injury. AstraZeneca's claims about the impact on its business decision-making and difficulty valuing Farxiga in negotiations were deemed hypothetical and conjectural.Regarding the due process claim, the court held that AstraZeneca did not have a protected property interest in selling its drugs at a market rate. The court noted that federal patent laws do not confer a right to sell at a particular price, and the Negotiation Program only sets prices for drugs reimbursed by CMS, not private market transactions. Consequently, the court affirmed the District Court’s judgment, granting summary judgment in favor of the government on both the APA and due process claims. View "AstraZeneca Pharmaceuticals LP v. Secretary United States Department of Health and H" on Justia Law

Libby Hilsenrath sued the Board of Education of the School District of the Chathams, claiming that the inclusion of instructional videos about Islam in her son's seventh-grade World Cultures and Geography class violated the Establishment Clause of the First Amendment. The class covered various world regions and their predominant religions, including Christianity, Buddhism, Hinduism, and Islam. The specific lessons on Islam included PowerPoint presentations and two YouTube videos, "Intro to Islam" and "The 5 Pillars of Islam," which Hilsenrath argued were proselytizing.The United States District Court for the District of New Jersey granted summary judgment to the Board, finding no Establishment Clause violation. The court applied the Lemon test and later, following a remand due to the Supreme Court's decision in Kennedy v. Bremerton School District, applied a historical analysis. The District Court concluded that the curriculum did not resemble any traditional hallmarks of religious establishment, such as coercion or preferential treatment of one religion over others.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's judgment. The Third Circuit held that the curriculum did not constitute proselytization or coercion, as the videos were part of a secular educational program covering multiple religions. The court also found no evidence of favoritism towards Islam, noting that the curriculum included teachings on various world religions. The court emphasized that the curriculum did not bear any hallmarks of religious establishment and upheld the District Court's decision. View "Hilsenrath v. School District of the Chathams" on Justia Law

The appellants, Robin and Louie Joseph Aquilino, filed for Chapter 7 bankruptcy in April 2020 and retained the law firm Spector Gadon Rosen & Vinci P.C. (Spector Gadon) as their counsel. They agreed to pay a flat fee of $3,500 and a $335 filing fee, which Spector Gadon disclosed to the Bankruptcy Court. However, due to the complexity of the case, Spector Gadon billed the Aquilinos for additional post-petition services, resulting in a fee agreement of $113,000, which was not disclosed to the Bankruptcy Court as required by 11 U.S.C. § 329(a) and Bankruptcy Rule 2016(b).The Bankruptcy Court for the District of New Jersey found that Spector Gadon violated the disclosure requirements and sanctioned the firm by ordering the disgorgement of collected fees and cancellation of the remaining fee agreement. Spector Gadon appealed, and the United States District Court for the District of New Jersey reversed the Bankruptcy Court's decision, concluding that Spector Gadon was entitled to a jury trial under the Seventh Amendment.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the Bankruptcy Court had "core" jurisdiction over the fee disclosure issue under 28 U.S.C. § 157(b)(1). The Third Circuit held that the Seventh Amendment did not entitle Spector Gadon to a jury trial in the § 329(a) proceeding because the sanctions imposed were equitable in nature, designed to restore the status quo, and did not involve legal claims. The Third Circuit also found that the Bankruptcy Court did not abuse its discretion in imposing sanctions, as it considered all relevant factors, including the Debtors' misconduct.The Third Circuit reversed the District Court's judgment and reinstated the Bankruptcy Court's sanctions order. View "In re Aquilino" on Justia Law