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

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 The Parole Board granted him parole, but rescinded that decision because of pending prison discipline proceedings.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

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

Defendant Michael Wright was charged with conspiracy to distribute marijuana. He moved to suppress evidence gathered from his apartment, arguing the execution of his arrest warrant was defective, entitling him to relief. The district court agreed the execution of the warrant was defective and granted defendant's motion. On appeal, a panel of the Third Circuit Court of Appeals vacated and remanded, holding that the federal Supreme Court's decision in "Herring v. United States," (555 U.S. 135 (2009)), required an additional analytical step before the exclusionary rule could be applied. Specifically, the District Court could not suppress the evidence unless it evaluated Agent Taylor’s (the organizer of the raid) culpability and found that his conduct was at least grossly negligent. The District Court denied the motion to suppress on remand, finding that Taylor’s failure to review the warrant before executing it was a “simple mistake” that conferred no benefit on the Government and amounted at most to negligence. Defendant was subsequently convicted of drug offenses by a jury, and he appealed. The parties agreed that evidence was seized from defendant's apartment in violation of the Fourth Amendment. The sole question this case presented for the Third Circuit's review was whether the exclusionary rule required suppression. The Court concluded that the District Court was correct to hold that Agent Taylor was not sufficiently culpable for the costs of suppression to outweigh its benefits. View "United States v. Wright" 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

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

The Locomotive Inspection Act (LIA), 49 U.S.C. 20701, provides that “a locomotive … and its parts and appurtenances” must be “in proper condition and safe to operate without unnecessary danger of personal injury.” The Federal Railroad Administration, under the authority of the Secretary of Transportation, has promulgated regulations on the governing standards of care. Canadian Pacific settled lawsuits brought by its employees who had suffered injuries as a result of defective train seats, then brought indemnification, contribution, and breach-of-contract claims against Knoedler Manufacturing, which supplied the seats, and Durham, which tried unsuccessfully to repair the seats. The district court dismissed Canadian Pacific’s claims as preempted by the LIA. The Third Circuit vacated. State law claims of breach of contract, indemnification, contribution based on the LIA are not preempted. To hold that the LIA preempts all breach-of-contract claims would allow, and perhaps encourage, manufacturers to make grand contractual promises to obtain a deal and then breach their duties with impunity. View "Del. & Hudson Ry. Co v. Knoedler Mfrs., Inc" 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

To rob a Philadelphia jewelry store, Burnett obtained a gun and Hankerson borrowed a car from Adams. A store video security system captured Burnett’s face during the robbery. They fled with Hankerson driving, but got lost and drove down a dead-end street. Instead of turning around, they parked the car, placed the loot in its trunk, and left on foot. After visiting the crime scene, police received a call reporting a “suspicious black Honda” on a residential street not far from the robbery. Witnesses described the men leaving the car. Police suspected it was involved in the robbery, tried to contact Adams, had the Honda towed, and executed a warrant. They recovered the jewelry, stolen security videotape, wigs, the bloodstained gun, a wallet containing Hankerson’s identification, latex gloves, and zip ties like those used to bind the robbery victims. One glove contained the DNA of Burnett and the store owner and another contained the DNA of Hankerson and the store owner. Hankerson pleaded guilty and cooperated. Burnett challenged the vehicle search as “fundamentally unfair.” The district court held that Burnett lacked standing, as he merely was a passenger and lacked a privacy interest in the vehicle. The Third Circuit affirmed. View "United States v. Burnett" on Justia Law