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

In 2020, Christopher Lamont Stimpson, Jr. contacted Benuel Stoltzfus, an Amish man in Lancaster County, Pennsylvania, to purchase five French bulldog puppies for $23,500. On the day of the sale, Stimpson and his associate, Wilbert Artis, visited the Stoltzfus home. After inspecting the puppies, Stimpson agreed to the purchase, but before the money count was complete, Artis took the puppies to their vehicle. A struggle ensued when Stimpson attempted to leave with the cash, during which he allegedly brandished a handgun. Stimpson and Artis fled with the puppies and most of the cash, leaving the Stoltzfus family with $4,140.The United States District Court for the Eastern District of Pennsylvania convicted Stimpson of Hobbs Act robbery and interstate transportation of stolen goods. Stimpson filed a motion to suppress evidence obtained from search warrants on social media accounts, arguing they were overbroad and lacked probable cause. The District Court denied the motion, but the government did not use the evidence obtained from the warrants at trial. Stimpson was convicted by a jury without the suppressed evidence.The United States Court of Appeals for the Third Circuit reviewed the case. Stimpson appealed the denial of his suppression motion and the application of a sentencing enhancement under USSG §2B3.1(b)(2)(D) for using a dangerous weapon. The Third Circuit found the suppression issue moot since the evidence was not used at trial. The court also upheld the sentencing enhancement, concluding that the District Court did not err in finding by a preponderance of the evidence that Stimpson used a dangerous weapon during the robbery.The Third Circuit affirmed Stimpson’s conviction and sentence. View "USA v. Stimpson" on Justia Law

A man was convicted of first-degree murder and sentenced to death for the killing of a police officer. The incident occurred during a traffic stop, where the officer was shot multiple times. The defendant was apprehended shortly after the shooting, and a firearm matching the bullets found at the scene was recovered from his vehicle. The defendant claimed he acted in self-defense, believing the officer was about to shoot him.The trial court, the Superior Court of California, found the defendant guilty and imposed the death penalty. The defendant appealed the conviction and sentence, arguing that the trial court made several errors, including improper jury instructions and the exclusion of certain evidence that could have supported his self-defense claim. The California Court of Appeal affirmed the conviction and sentence, rejecting the defendant's arguments. The defendant then sought review from the California Supreme Court.The California Supreme Court reviewed the case and upheld the lower court's decision. The court found that the trial court did not err in its jury instructions and that the exclusion of the evidence in question did not prejudice the defendant's case. The court also held that the evidence presented at trial was sufficient to support the conviction and the imposition of the death penalty. The court concluded that the defendant's actions were not justified as self-defense and that the killing of the officer was premeditated and deliberate. The conviction and death sentence were affirmed. View "USA v. Clark" on Justia Law

Cornelius Green, a member of the Infamous Ryders motorcycle club, was involved in an incident where Ishmael Snowell, who had declined membership in the club, was allegedly kidnapped. Green, along with co-defendant William Murphy and Steven Wong, met Snowell at the club's clubhouse. A fight ensued between Snowell and Murphy, with Green refereeing. Wong discovered photos of money on Snowell’s phone and demanded to know its location. Snowell claimed the money was at his aunt’s house in Reading, Pennsylvania. Murphy drove Snowell and Green, who was armed, to the house. Testimonies diverged on whether Murphy and Snowell could have escaped during a stop at a gas station. Upon arrival, they searched for the money, and Snowell claimed Wong ordered Green to shoot him. Snowell attempted to escape, leading to a fight with Green, which ended when neighbors called the police.The grand jury indicted Green, Murphy, and Wong for kidnapping and robbery. Green moved to sever his trial from Murphy and Wong, but the District Court denied the motion. Wong’s trial was later severed due to a change in attorneys, and he was acquitted. During the joint trial of Green and Murphy, Murphy testified that Wong coerced him into the kidnapping and that Green threatened Snowell with a gun. Green renewed his motion to sever, arguing that Murphy’s defense was antagonistic to his own, but the District Court denied it.The United States Court of Appeals for the Third Circuit reviewed the case and found that Green and Murphy presented mutually antagonistic defenses, which prejudiced Green’s right to a fair trial. The court held that the District Court abused its discretion in denying Green’s motion to sever. Consequently, the Third Circuit reversed the denial of the motion to sever, vacated Green’s conviction and sentence, and remanded for further proceedings. View "USA v. Green" on Justia Law

In 2001, the Commonwealth charged Robert Gene Rega with first-degree murder and other crimes for shooting a security guard, Christopher Lauth, during a robbery at the Gateway Lodge in Jefferson County, Pennsylvania. Rega, along with Shawn Bair, Raymond Fishel, and Stanford Jones, planned the robbery, while Jones’s wife, Susan, stayed at Rega’s home. During the robbery, Lauth was killed. The prosecution's case relied heavily on the testimonies of Bair, Fishel, and the Joneses, who identified Rega as the shooter. Additional evidence included a video of Rega purchasing ammunition and testimony from a friend that Rega asked for a false alibi.The Pennsylvania state court convicted Rega of first-degree murder and sentenced him to death. Rega's conviction and sentence were upheld on direct appeal and in a Post-Conviction Relief Act (PCRA) proceeding. Rega then filed a federal habeas petition. The United States District Court for the Western District of Pennsylvania denied his guilt-phase claims but granted relief from his death sentence, ordering a new sentencing hearing or life imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. Rega raised claims that the prosecutor withheld evidence in violation of Brady v. Maryland and presented false testimony in violation of Giglio v. United States and Napue v. Illinois. The Third Circuit affirmed the denial of relief on these claims, concluding that the evidence and testimony in question were not material to Rega’s murder conviction. The court found that the prosecutor’s noncommittal statements to witnesses about considering their cooperation in future plea deals did not significantly undermine their credibility, as the jury was already aware of their potential motives. Additionally, evidence of Susan Jones’s memory problems was deemed not material, as it did not sufficiently undermine her testimony or the overall case against Rega. View "Rega v. Secretary Pennsylvania Department of Corrections" on Justia Law

A Philadelphia police officer stopped Sunny Sok for making an illegal right turn. During the stop, the officer discovered that Sok's vehicle had an expired registration and mistakenly believed there was an active arrest warrant for Sok. The officer arrested Sok and claimed to smell marijuana from the vehicle, leading to a search that uncovered narcotics and a firearm. Sok was charged with drug and firearm offenses and moved to suppress the evidence, arguing the search was unlawful.The United States District Court for the Eastern District of Pennsylvania held a suppression hearing and found the officer's testimony about the marijuana odor not credible, thus ruling there was no probable cause for the search. However, the court denied Sok's motion to suppress, concluding that the evidence would have been inevitably discovered under Philadelphia’s Live Stop Policy, which mandates impounding unregistered vehicles and conducting inventory searches.Sok appealed to the United States Court of Appeals for the Third Circuit, arguing that the inevitable-discovery doctrine should not apply because the Government did not prove that impoundment of his vehicle was lawful or inevitable under the Live Stop Policy. The Third Circuit noted that Sok failed to raise these arguments in the District Court and thus could not consider them unless Sok showed good cause for the failure. The court found that Sok did not demonstrate good cause, as his counsel's misunderstanding of the law did not suffice. Consequently, the Third Circuit affirmed the District Court's judgment, upholding Sok's conviction and sentence. View "United States v. Sok" on Justia Law

Joseph Johnson was convicted of making a false statement and aggravated identity theft after he used a lawyer’s signature without consent to file an exhibit in federal court. This exhibit accused a plaintiff in a separate case of underreporting taxable income. The government prosecuted Johnson, and a jury convicted him. However, the United States Court of Appeals for the Third Circuit later vacated his conviction, finding that the government failed to prove the materiality of Johnson’s false statement.Johnson then sought compensation under 28 U.S.C. § 1495, which requires proving that he did not cause his own prosecution through misconduct or neglect. The United States District Court for the Eastern District of Pennsylvania denied his petition, concluding that Johnson’s use of the lawyer’s signature was misconduct that directly led to his prosecution.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 Johnson’s misconduct was a but-for cause of his prosecution, meaning that if he had not filed the exhibit using the lawyer’s signature, the government would not have prosecuted him. Therefore, Johnson could not satisfy the requirement under 28 U.S.C. § 2513(a)(2) that he did not cause his own prosecution by misconduct or neglect. The court emphasized that the statutory language did not incorporate proximate causation principles and that Johnson’s actions directly led to his prosecution. Consequently, Johnson was not entitled to a certificate of innocence or compensation. View "USA v. Johnson" on Justia Law

In 2016, John O. Kalu, an inmate at FCI Allenwood, alleged that he was sexually assaulted on three separate occasions by Lieutenant K. Middernatch. Kalu reported the first two incidents to Warden Spaulding, who responded that he would investigate but took no further action. Following his report, Kalu was placed in the Special Housing Unit (SHU) and later returned to the general population, where he was assaulted a third time. Kalu also claimed that he was subjected to inhumane conditions of confinement, including being forced to sleep on a cold metal bunk in freezing temperatures without adequate clothing.Kalu filed a pro se complaint in the Middle District of Pennsylvania against Warden Spaulding and Lt. Middernatch, seeking damages under Bivens for violations of his Eighth Amendment rights. The District Court dismissed Kalu’s claims against Warden Spaulding for lack of personal involvement but allowed the sexual assault claim against Lt. Middernatch to proceed. Kalu later amended his complaint, but the District Court ultimately dismissed all claims, determining that they presented new Bivens contexts and that special factors counseled against extending Bivens remedies.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court’s dismissal. The court held that Kalu’s Eighth Amendment sexual assault and conditions-of-confinement claims presented new Bivens contexts. It found that special factors, including the availability of alternative remedies through the Bureau of Prisons’ Administrative Remedy Program, Congress’s omission of a standalone damages remedy in the Prison Litigation Reform Act (PLRA) and the Prison Rape Elimination Act (PREA), and separation of powers principles, counseled against extending Bivens liability. The court also agreed that Kalu’s complaint failed to allege sufficient facts to establish a plausible claim against Warden Spaulding for deliberate indifference or failure to protect. View "Kalu v. Spaulding" on Justia Law

Tony Fisher, a federal inmate, filed a lawsuit against several prison officials, alleging they were deliberately indifferent to the risk of sexual assault by another inmate, resulting in his rape. Fisher entered federal prison in 2013 and was transferred to Fort Dix, where he reported past sexual assault and harassment by other inmates. Despite these reports, prison staff did not classify him as at high risk for sexual assault. Shortly after, Fisher was raped by another inmate. Fisher claimed that a prison official, Captain Fitzgerald, discouraged him from reporting the assaults and seeking legal help, warning him of potential retaliation.The United States District Court for the District of New Jersey dismissed Fisher’s complaint, ruling it was time-barred under New Jersey’s two-year statute of limitations for personal injury actions. Fisher appealed, arguing that the statute of limitations should be tolled due to the prison official’s threats and his mental health issues.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The court held that no Bivens cause of action exists for failure to protect an inmate from another inmate’s violence, following the Supreme Court’s decision in Egbert v. Boule. The court also ruled that even if such a claim were cognizable, Fisher’s complaint was untimely. The court found that Fisher did not qualify for equitable tolling because he was transferred away from the influence of the threatening official shortly after the assaults and did not exercise due diligence in pursuing his claims. Additionally, the court held that New Jersey’s revival statute for sexual assault claims did not apply to Bivens actions. View "Fisher v. Hollingsworth" on Justia Law

In 2015, Eddie Williams was prosecuted in Pennsylvania for crimes related to a drug dispute that resulted in one death and one serious injury. Williams, along with Rick Cannon and Akeita Harden, was implicated in the incident. Cannon pleaded guilty to twenty charges, including homicide and conspiracy, some of which named Williams as a coconspirator. During Williams's trial, his attorney misrepresented Cannon's plea, leading the judge to read Cannon's entire Criminal Information to the jury, which included references to Williams as a coconspirator.Williams was found guilty on all counts and sentenced to life imprisonment plus additional years. He filed a Post-Conviction Relief Act (PCRA) petition, arguing ineffective assistance of counsel due to his attorney's actions. The PCRA court denied relief, finding no Confrontation Clause violation and concluding that the attorney's strategy was reasonable. The Superior Court affirmed, and the Pennsylvania Supreme Court denied further appeal.Williams then filed a habeas corpus petition in the United States District Court for the Middle District of Pennsylvania, which granted relief, finding that the reading of Cannon's Criminal Information violated the Confrontation Clause and that Williams's counsel was ineffective for not objecting. The Commonwealth appealed this decision.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The court held that the reading of Cannon's Criminal Information, which included references to Williams, was testimonial and violated the Confrontation Clause. The court also found that Williams's counsel was ineffective for failing to object to the reading, which prejudiced Williams's defense. The court concluded that these errors had a substantial and injurious effect on the jury's verdict, warranting habeas relief. View "Williams v. Greene" on Justia Law

Jamal Morton was convicted in 2012 in the Virgin Islands Superior Court of second-degree murder and various firearm offenses, receiving a fifty-year sentence. After his conviction was affirmed on direct appeal, Morton filed a territorial habeas petition in 2014, raising twenty claims, including violations of his Fifth and Sixth Amendment rights. Despite his numerous attempts to move the case forward, including motions for default judgment, discovery requests, and status conference requests, the Superior Court took no substantive action for nearly six years.Frustrated by the inaction, Morton filed a federal habeas petition in the U.S. District Court of the Virgin Islands in April 2020, raising the same claims. The District Court dismissed his petition without prejudice, citing his failure to exhaust territorial court remedies. The court reasoned that Morton had not taken sufficient steps, such as seeking a writ of mandamus from the Virgin Islands Supreme Court, to address the delay in the territorial court.The United States Court of Appeals for the Third Circuit reviewed the case and found that the nearly six-year delay in the territorial court, coupled with the lack of progress and Morton’s reasonable efforts to advance his case, constituted inordinate delay. The Third Circuit held that the District Court erred by not requiring the Government to justify the delay before dismissing Morton’s petition. The court vacated the District Court’s dismissal and remanded the case, instructing the lower court to allow the Government to provide any justifications for the delay and proceed accordingly. View "Morton v. Director Virgin Islands Bureau of Corrections" on Justia Law