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

Rajeri Curry was investigated for drug trafficking after purchasing heroin and fentanyl in bulk from two brothers, Al-Tariq and Shadee Brown. Following a fatal overdose linked to drugs Curry sold, police arrested her and seized her iPhone. After being read her Miranda rights, Curry requested a lawyer. Detectives then asked for consent to search her phone, explaining that refusal would lead to a warrant and possible data loss. Concerned about losing her files, Curry provided her passcode and signed a consent form. The detectives did not question her about the charged offenses during this interaction.Curry was indicted in the United States District Court for the District of New Jersey for conspiracy to distribute heroin and fentanyl, possession with intent to distribute, and distribution resulting in death. Before trial, she moved to suppress evidence obtained from her phone, arguing it was inadmissible due to a violation of the Edwards v. Arizona rule. The District Court denied the motion, admitted the evidence, and allowed the prosecution to introduce Curry’s prior drug convictions. After trial, the jury convicted Curry of conspiracy and possession with intent to distribute, but did not reach a verdict on the distribution resulting in death count. The District Court denied Curry’s motion for judgment of acquittal and sentenced her as a career offender to 216 months’ imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that evidence derived from Curry’s phone was not subject to suppression under Edwards v. Arizona because Curry voluntarily provided her passcode and consented to the search. The court affirmed the District Court’s judgment, finding no error in the denial of the suppression motion, the sufficiency of evidence for conspiracy, the admission of prior convictions under Rule 404(b), and the application of the career-offender sentencing enhancement. View "USA v. Curry" on Justia Law

Marquis Smalls pleaded guilty in 2013 to conspiring to distribute heroin and was sentenced by the United States District Court for the District of New Jersey to 110 months’ imprisonment followed by five years of supervised release. His supervised release was conditioned on compliance with certain terms, including not committing new crimes or illegally possessing controlled substances. After his release in December 2020, Smalls repeatedly violated these conditions, resulting in multiple periods of home detention. In June 2024, he was arrested by state officials on heroin-trafficking charges, and the United States Probation Office charged him with eight violations of supervised release, successfully petitioning for a federal arrest warrant. Upon release from state custody, Smalls was transferred to federal custody and presented before the District Court for an initial appearance, where he was ordered detained pending a final revocation hearing. Smalls waived his right to a preliminary hearing.Smalls later moved for release from custody, citing a district court opinion from the District of Connecticut in United States v. Mercado, which held that no statute authorized pre-revocation detention for supervised release violations. The District Court for the District of New Jersey denied Smalls’s motion, finding it had authority to detain him under Federal Rule of Criminal Procedure 32.1(a)(6) and 18 U.S.C. § 3143(a)(1), based on flight risk and danger to the community. Smalls appealed to the United States Court of Appeals for the Third Circuit, which denied his motion for release in a summary order. Smalls then filed a petition for rehearing.The United States Court of Appeals for the Third Circuit granted the petition for rehearing to provide a precedential explanation but again denied Smalls’s motion for release. The court held that 18 U.S.C. § 3143(a)(1) authorizes detention of a defendant alleged to have violated supervised release pending revocation proceedings, as such detention is part of the execution of the original sentence. The court affirmed the District Court’s authority to detain Smalls pending his final revocation hearing. View "USA v. Smalls" on Justia Law

Two employees of a debt-collection firm, one of whom was out sick with COVID-19, collaborated to resolve an urgent licensing issue for their employer. The employee at home, unable to access her work computer, asked her colleague to log in using her credentials and retrieve a spreadsheet containing passwords for various company systems. The colleague, with express permission, accessed the computer and emailed the spreadsheet to the employee’s personal and work email accounts. Both actions violated the employer’s internal computer-use policies. Separately, the employee at home had, over several years, moved accounts into her workgroup to receive performance bonuses, believing she was eligible for them. Both employees also alleged persistent sexual harassment at work, which led to internal complaints, one employee’s resignation, and the other’s termination.After these events, the employer, National Recovery Agency (NRA), sued both employees in the United States District Court for the Middle District of Pennsylvania, alleging violations of the Computer Fraud and Abuse Act (CFAA), federal and state trade secrets laws, civil conspiracy, breach of fiduciary duty, and fraud. The employees counterclaimed for sexual harassment and related employment claims. On cross-motions for summary judgment, the District Court entered judgment for the employees on all claims brought by NRA, finding no violations of the CFAA or trade secrets laws, and stayed the employees’ harassment claims pending appeal.The United States Court of Appeals for the Third Circuit reviewed the case. It affirmed the District Court’s judgment in full. The Third Circuit held, first, that the CFAA does not criminalize violations of workplace computer-use policies by employees with authorized access, absent evidence of hacking or code-based circumvention. Second, it held that passwords protecting proprietary business information do not, by themselves, constitute trade secrets under federal or Pennsylvania law. The court also affirmed the dismissal of the state-law tort claims. View "NRA Group LLC v. Durenleau" on Justia Law

Two individuals operated a large-scale heroin trafficking operation, transporting significant quantities of heroin from New Jersey to Pennsylvania. Law enforcement, using information from an informant, initiated an investigation that included wiretaps on the suspects’ phones. The wiretap application was signed by the First Deputy Attorney General, acting on the authority of the Pennsylvania Attorney General, who was out of the country at the time. The investigation led to the arrest of both men, the seizure of heroin, cash, and firearms, and the discovery of their involvement in witness tampering, including the murder and attempted murder of two women connected to the case.The United States District Court for the Western District of Pennsylvania denied the defendants’ motion to suppress the wiretap evidence, finding that the First Deputy Attorney General was properly authorized under state law to submit the application. After a jury trial, both defendants were convicted of drug and firearm offenses, with one also convicted of witness tampering resulting in death and attempted murder. The court sentenced one defendant to 380 months in prison and the other to life imprisonment plus additional consecutive terms. Both appealed, raising issues regarding the wiretap’s legality, alleged constructive amendment of the indictment, jury instructions, sufficiency of the evidence, and sentencing errors.The United States Court of Appeals for the Third Circuit affirmed the convictions and sentences for one defendant in full. For the other, the court affirmed all convictions and sentences except for the consecutive 25-year sentence imposed for using a firearm to commit murder under 18 U.S.C. § 924(j). The court held that, in light of the Supreme Court’s decision in Lora v. United States, a consecutive sentence is not mandatory under § 924(j), and thus vacated and remanded for resentencing on that count. All other claims for relief were rejected. View "USA v. Perrin" on Justia Law

Carl Rose was serving a term of supervised release after completing a federal sentence for drug and firearm offenses. During this period, he was alleged to have violated the terms of his supervision by testing positive for marijuana, absconding from supervision, and, most significantly, committing aggravated assault and possessing a firearm. The aggravated assault allegation stemmed from an incident in which a victim reported that Rose entered her bedroom, brandished a firearm, demanded money, and stabbed her multiple times before fleeing. Although state charges for aggravated assault were dismissed when the victim failed to appear in court, Rose pled guilty to prohibited possession of a firearm.The United States District Court for the Eastern District of Pennsylvania held a supervised release revocation hearing. Rose did not contest the firearm possession violation, so the hearing focused on the aggravated assault allegation. The government presented testimony from law enforcement officers and introduced body camera footage showing the victim identifying Rose as her attacker. The victim did not testify at the hearing, and her out-of-court statements were admitted over Rose’s objection. The District Court found that the government had made diligent efforts to locate the victim, who was herself a fugitive, and concluded that her statements were sufficiently reliable and that there was good cause for her absence. The court revoked Rose’s supervised release and sentenced him to 48 months’ imprisonment.On appeal, the United States Court of Appeals for the Third Circuit reviewed whether the District Court erred in admitting the victim’s hearsay statements without live testimony, considering Rose’s confrontation rights. The Third Circuit held that the District Court did not abuse its discretion. It found the victim’s statements reliable due to corroborating evidence and determined that the government had shown good cause for her absence. The judgment of the District Court was affirmed. View "United States v. Rose" on Justia Law

Philadelphia police officers stopped a car driven by Raphael Ross for having illegally tinted windows in a high-crime area. During the stop, Ross appeared extremely nervous, displaying shaking hands, a stammering voice, and erratic movements with his jacket inside the car. After Ross produced expired insurance and registration and claimed to have left his license elsewhere, Officer Smart complimented Ross’s Rolex watch and asked where he worked. Ross replied that he owned a home health aide business. Officer Smart then returned to his patrol car to check Ross’s information, discovering a recent firearm arrest. Meanwhile, Officer Foreman observed continued nervous behavior and noncompliance with her instructions. After backup arrived, officers frisked Ross and searched his car, finding a gun and drugs.Ross was charged in the United States District Court for the Eastern District of Pennsylvania with firearm and drug offenses. He moved to suppress the evidence, arguing that the officer’s questions about his watch and employment unlawfully extended the stop under the Fourth Amendment, as interpreted by Rodriguez v. United States. The District Court denied the motion, finding the brief exchange to be permissible small talk aimed at calming Ross and not an unconstitutional extension of the stop. Ross pleaded guilty but reserved his right to appeal the suppression ruling.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that brief, safety-related small talk—such as complimenting a watch and asking about employment—does not violate the Fourth Amendment if it is intended to deescalate tension and does not measurably prolong the stop. The court found that the officers’ actions were reasonable given Ross’s nervous behavior and affirmed the District Court’s denial of the suppression motion and Ross’s conviction. View "USA v. Ross" on Justia Law

Paul Harmon, who had worked for decades as an accountant and controller at a family-owned electrical engineering firm, embezzled over a million dollars from the company. His actions led to significant financial losses for the business and its employees, including legal and accounting costs, overpaid taxes, and the eventual closure of the company. The president of the company detailed these hardships in a victim impact statement and letter submitted at Harmon’s sentencing.After Harmon pled guilty to wire fraud in the United States District Court for the Western District of Pennsylvania, the court imposed an upwardly varied sentence of 72 months, citing the severe impact of his crimes on the victims and the business. The presentence report and the government did not recommend, and the court did not apply, a sentencing enhancement for causing “substantial financial hardship.” In 2024, Harmon sought a sentence reduction under 18 U.S.C. § 3582(c)(2) based on a new, retroactive Sentencing Guideline provision, U.S.S.G. § 4C1.1, which excludes defendants who caused substantial financial hardship. The government did not oppose the motion. The District Court denied the reduction, relying on the earlier victim impact materials to find Harmon ineligible, and did not provide him an opportunity to contest those materials at this stage.The United States Court of Appeals for the Third Circuit reviewed the case. It held that due process protections under U.S.S.G. § 6A1.3(a)—requiring notice and an opportunity to contest new information—apply to sentence reduction motions under § 3582(c)(2). However, the court concluded that the victim impact statement and letter were not “new information” because they had already been relied upon at the original sentencing to find material facts. Therefore, the Third Circuit affirmed the District Court’s denial of Harmon’s motion for a sentence reduction. View "USA v. Harmon" on Justia Law

A Pennsylvania prisoner sentenced to death sought to reopen his federal habeas corpus proceedings to present expert evidence obtained in 1999, which he argued would support his claim that he was incompetent at the time of his guilty plea and sentencing. This evidence was not presented during his initial state postconviction proceedings due to his counsel’s alleged ineffectiveness. The prisoner contended that a subsequent Supreme Court decision, Martinez v. Ryan, should allow him to introduce this evidence in federal court, despite statutory restrictions.The United States District Court for the Middle District of Pennsylvania denied the prisoner’s motion under Federal Rule of Civil Procedure 60(b)(6), finding it untimely and concluding that Martinez did not apply because the ineffective assistance of trial counsel claim had already been adjudicated on the merits and was not procedurally defaulted. The District Court also determined that no extraordinary circumstances justified reopening the habeas proceedings and declined to issue a certificate of appealability. The United States Court of Appeals for the Third Circuit granted a certificate of appealability and reviewed the case.The United States Court of Appeals for the Third Circuit held that, while the prisoner could use Rule 60(b)(6) to challenge the District Court’s failure to hold an evidentiary hearing, his motion was timely. However, the court concluded that Martinez does not permit reopening the case to introduce new evidence where the underlying claim was already decided on the merits. Furthermore, even if Martinez applied, the Antiterrorism and Effective Death Penalty Act (AEDPA) bars the introduction of new evidence unless strict statutory requirements are met, which the prisoner could not satisfy. The Third Circuit affirmed the District Court’s order in part, vacated in part, and remanded with instructions to dismiss the portion of the motion constituting a successive habeas petition. View "Taylor v. Commissioner of Pennsylvania" on Justia Law

The appellant was charged, along with two others, with robbing a restaurant in Pennsylvania, in violation of federal statutes prohibiting Hobbs Act robbery and the use of firearms during a crime of violence. He pleaded guilty to both charges. At sentencing, the United States Probation Department recommended that he be classified as a career offender under the United States Sentencing Guidelines, based on two prior Pennsylvania state court robbery convictions—one in Dauphin County and one in Cumberland County. The appellant, through counsel, objected to the career offender designation, arguing that the two prior convictions should be treated as a single predicate. The United States District Court for the Middle District of Pennsylvania overruled this objection, designated him a career offender, and sentenced him to 210 months in prison.On direct appeal to the United States Court of Appeals for the Third Circuit, appellate counsel filed an Anders brief, asserting no nonfrivolous grounds for appeal. The Third Circuit affirmed the sentence and granted counsel’s motion to withdraw. The court also dismissed the appellant’s claim for relief under Johnson v. United States, finding no indication that the residual clause of the Guidelines was used in his designation. The court declined to rule on the ineffective assistance of counsel claim, noting it could be raised in a collateral proceeding. The appellant then filed a motion under 28 U.S.C. § 2255, arguing that his trial counsel was ineffective for failing to challenge whether his prior convictions qualified as crimes of violence. The District Court denied the motion without an evidentiary hearing, finding the records showed both prior convictions were for robbery under Pennsylvania law and qualified as crimes of violence.The United States Court of Appeals for the Third Circuit reviewed the denial of the § 2255 motion. The court held that the District Court did not err in finding that both prior convictions were for robbery under 18 Pa. Cons. Stat. § 3701(a)(1)(ii), which qualifies as a crime of violence under the Guidelines. The court also held that trial counsel was not ineffective for failing to challenge the career offender designation on the grounds raised. The Third Circuit affirmed the District Court’s judgment. View "USA v. Dobbin" on Justia Law

Juan Montas, a citizen of the Dominican Republic, entered the United States as a toddler in 1996. In 2017, he was convicted in the U.S. District Court for the District of New Jersey for conspiracy to distribute heroin and was subsequently deported in 2020. Montas reentered the U.S. illegally before April 2023 and was arrested by New Jersey State Police for possession of a false driver’s license, drug offenses, and money laundering. He pled guilty in 2023 to illegally reentering the United States.The U.S. District Court for the District of New Jersey sentenced Montas in 2024. During the sentencing, the court relied on the Presentence Investigation Report (PSR) and the hearing transcript from Montas’s 2017 sentencing without prior notice to Montas or his counsel. Montas’s counsel did not object to this reliance during the sentencing. The court imposed a 34-month imprisonment sentence, noting Montas’s previous statements and actions from the 2017 sentencing.Montas appealed to the United States Court of Appeals for the Third Circuit, arguing that the District Court violated Federal Rule of Criminal Procedure 32 by relying on information from the 2017 sentencing without prior notice. The Third Circuit reviewed the issue for plain error since Montas did not raise the objection in the lower court. The Third Circuit found that the District Court erred and that the error was clear. However, Montas failed to demonstrate that the error affected his substantial rights, as he could not show that the sentence would have been different with proper notice. Consequently, the Third Circuit affirmed the sentence. View "USA v. Montas" on Justia Law