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

Two commercial fishermen, Raymond Lofstad and Gus Lovgren, challenged the constitutionality of the appointment process for members of the Mid-Atlantic Fishery Management Council. The Council, which oversees fisheries from New York to Virginia, had approved an amendment lowering the catch limits for certain fish species, which the Secretary of Commerce subsequently approved. The fishermen argued that the Council members, who were not appointed by the President or confirmed by the Senate, exercised significant authority and thus should be considered "Officers of the United States" under the Appointments Clause of the Constitution.The United States District Court for the District of New Jersey ruled against the fishermen, holding that the Council members did not exercise significant authority and were therefore not officers. The court granted summary judgment in favor of the government, reasoning that the Council's role was merely advisory and did not involve significant authority.The United States Court of Appeals for the Third Circuit reviewed the case de novo and found that the Council members did exercise significant authority, particularly through their power to veto certain actions by the Secretary of Commerce. The court held that these veto powers made the Council members principal officers who should have been appointed by the President and confirmed by the Senate. To remedy the constitutional violation, the court severed the Council's pocket-veto powers, reducing the members to mere employees who do not require such appointments. The court reversed the District Court's summary judgment for the government and rendered judgment for the fishermen. View "Lofstad v. Secretary United States Department of Commerce" on Justia Law

Raymond Zaborowski, a U.S. Army veteran suffering from anxiety and PTSD, applied for Social Security disability benefits, claiming his conditions have prevented him from working since 2014. An administrative law judge (ALJ) denied his claim, stating that medical evidence indicated he could still perform light work.Zaborowski appealed to the United States District Court for the Eastern District of Pennsylvania, where he consented to jurisdiction by a magistrate judge. The magistrate judge upheld the ALJ's decision, leading Zaborowski to appeal further.The United States Court of Appeals for the Third Circuit reviewed the case. Zaborowski argued that the regulation requiring ALJs to explain their decisions violated the Social Security Act, that the ALJ failed to properly explain the supportability and consistency of medical opinions, and that the ALJ's findings were not supported by substantial evidence. The Third Circuit reviewed the legal issues de novo and the ALJ's factual findings for substantial evidence.The court held that the regulation complies with the statute, as it requires ALJs to explain the dispositive reasons for their decisions, specifically focusing on supportability and consistency. The court found that the ALJ adequately addressed these factors in her analysis, noting that the opinions of two psychologists were consistent with the record, while the treating psychiatrist's opinion was not. The court also found substantial evidence supporting the ALJ's decision, including the psychologists' opinions and evidence of Zaborowski's ability to live independently and assist his mother.The Third Circuit affirmed the decision, concluding that the ALJ's denial of benefits was supported by substantial evidence and that the regulation did not violate the Social Security Act. View "Zaborowski v. Commissioner Social Security" on Justia Law

Judith Maureen Henry was mistakenly arrested on a warrant intended for another woman with the same name who had skipped parole in Pennsylvania. The warrant included Henry's home address and driver’s license photo. Henry was detained for over two weeks, despite her repeated claims of innocence and requests for fingerprint comparison. She was eventually released after Pennsylvania officials confirmed her fingerprints did not match those of the actual parole violator.The United States District Court for the District of New Jersey reviewed the case and denied a motion to dismiss filed by six deputy United States Marshals. The Marshals argued for qualified immunity, claimed that Henry could not pursue her claims under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, and contended that her complaint failed to state a claim. The District Court rejected these arguments, citing a need for further factual development.The United States Court of Appeals for the Third Circuit reviewed the case and reversed the District Court’s decision. The Third Circuit held that Henry’s claims presented a new context under Bivens, as her arrest was based on a valid warrant and her mistaken-identity arrest was constitutionally valid. The court found that the Marshals’ actions did not violate the Fourth Amendment and that Henry’s other claims, including those for failure to investigate her innocence and failure to present her to a magistrate, also presented a new context. The court concluded that separation of powers concerns precluded extending Bivens to this new context. Additionally, Henry’s claims under 42 U.S.C. § 1985(3) and the New Jersey Civil Rights Act were dismissed, as she failed to provide sufficient factual allegations of discriminatory animus and the Westfall Act barred her NJCRA claim. The Third Circuit remanded the case for dismissal of Henry’s claims against the Marshals. View "Henry v. Essex County" 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

The Environmental Protection Agency (EPA) issued a health advisory in 2022 for HFPO-DA, a chemical found in drinking water. The Chemours Company, which uses HFPO-DA in manufacturing, challenged the advisory, arguing it was unlawful. Chemours contended that the advisory violated procedural and substantive requirements of the Administrative Procedure Act (APA) and the nondelegation doctrine.Chemours petitioned the United States Court of Appeals for the Third Circuit for review, invoking the section of the Safe Drinking Water Act (SDWA) that allows for review of final actions by the EPA Administrator. Chemours argued that the health advisory was a final agency action, thus subject to judicial review. The EPA, however, maintained that the advisory was not a final action but rather a nonbinding document meant to provide information to decision-makers.The United States Court of Appeals for the Third Circuit dismissed the petition for lack of subject matter jurisdiction. The court held that the health advisory did not constitute a final agency action because it did not determine any rights or obligations, nor did it have direct and appreciable legal consequences. The court emphasized that the advisory was informational and non-enforceable, and any legal consequences would result from subsequent actions by other entities, not from the advisory itself. Therefore, the court concluded that it lacked jurisdiction to review the advisory under the SDWA. View "The Chemours Company FC, LLC v. EPA" on Justia Law

The case involves Transcontinental Gas Pipe Line Company, LLC (Transco), a natural gas company that sought to abandon and expand its pipeline facilities in Pennsylvania and New Jersey. To do so, Transco needed a Certificate of Public Convenience and Necessity from the Federal Energy Regulatory Commission (FERC), which it obtained. However, the certificate was subject to conditions, including that Transco receive three additional permits from the Pennsylvania Department of Environmental Protection (PADEP). After receiving these permits, Transco began its pipeline project. However, three environmental advocates filed an administrative appeal with the Environmental Hearing Board (EHB) challenging PADEP's issuance of the permits. In response, Transco initiated a lawsuit in the District Court seeking to enjoin the administrative appeal, arguing that the Natural Gas Act preempts the state law allowing the appeal.The District Court rejected Transco's preemption arguments and denied its motion for a preliminary injunction. Transco appealed this decision to the United States Court of Appeals for the Third Circuit. The Court of Appeals affirmed the District Court's decision, finding that none of the theories of preemption advanced by Transco or the state agency applied in this case. The Court held that the Natural Gas Act does not expressly preempt administrative appeals to the EHB, nor does it field preempt such appeals. The Court also found that the possibility of multiple challenges in different fora to PADEP permitting decisions under the Clean Water Act for interstate natural gas pipelines does not impose an obstacle to the purposes of the Natural Gas Act. Therefore, the Court concluded that Transco's motion for a preliminary injunction was correctly denied. View "Transcontinental Gas Pipe Line Co LLC v. Pennsylvania Environmental Hearing Board" on Justia Law

Between 2012 and 2015, Anthony D’Ambrosio and Armando Delgado were involved in a sex trafficking ring that operated across several states. They were responsible for transporting victims, collecting money, providing security, and supplying drugs to the victims. In 2015, a federal grand jury indicted them, and in 2017, a jury convicted them of several crimes, including sex trafficking of children and transportation of an individual to engage in prostitution. As part of their sentences, the District Court required them to comply with the Sex Offender Registration and Notification Act (SORNA) as a condition of their supervised release.Delgado objected to the SORNA registration requirement at his sentencing, arguing that his offenses did not require SORNA registration. The District Court acknowledged that it was unclear whether the SORNA requirement applied to Delgado’s offenses and delegated the determination to the Probation office. Delgado appealed this decision, but the Court of Appeals affirmed the District Court's decision, stating that the District Court did not impose any SORNA requirement. However, following his direct appeal, Probation required Delgado to register under SORNA. Delgado challenged this condition, but the District Court denied his motion, stating that it lacked jurisdiction to consider his legal challenge.D’Ambrosio, on the other hand, did not object to the SORNA registration requirement at his sentencing. The District Court required D’Ambrosio to comply with SORNA as a condition of his supervised release. D’Ambrosio first challenged the SORNA requirement in a motion to modify, which the District Court also denied on the grounds of lacking jurisdiction.The United States Court of Appeals for the Third Circuit reversed the District Court's decisions. The Court of Appeals held that the District Court erred in delegating its responsibility to determine the applicability of SORNA to the Probation office and in concluding that it lacked jurisdiction to consider the defendants' motions to modify the conditions of their supervised release. The case was remanded for further proceedings. View "United States v. D’Ambrosio" on Justia Law

The case involves Smith & Wesson Brands, Inc., Smith & Wesson Sales Company, and Smith & Wesson Inc. (collectively, “Smith & Wesson”) and the Attorney General of the State of New Jersey and the New Jersey Division of Consumer Affairs. The New Jersey Attorney General issued a subpoena to Smith & Wesson under the New Jersey Consumer Fraud Act, seeking documents related to the company's advertising practices. Smith & Wesson filed a federal lawsuit to enjoin enforcement of the subpoena, alleging it violated various constitutional provisions. The New Jersey Attorney General then filed a subpoena enforcement action in state court. The state court rejected Smith & Wesson’s objections and ordered the company to comply with the subpoena.The state court proceedings concluded before the federal case, with the state court ordering Smith & Wesson to comply with the subpoena. The federal court then dismissed Smith & Wesson’s civil rights action on claim preclusion grounds, giving preclusive effect to the state court’s order. The state appellate court later affirmed the state court judgment. Smith & Wesson appealed to the United States Court of Appeals for the Third Circuit, arguing that the District Court should not have given preclusive effect to the state court order.The United States Court of Appeals for the Third Circuit affirmed the District Court’s order. The court found that all elements of New Jersey’s claim preclusion test were satisfied. The court also rejected Smith & Wesson’s argument that it had reserved its right to litigate in federal court, finding that such reservation was unavailable in this case. The court emphasized that litigants get one opportunity to make their arguments, not two, and they cannot file a federal lawsuit to hedge against a potentially unfavorable state ruling. View "Smith & Wesson Brands Inc. v. Attorney General of the State of New Jersey" on Justia Law

James Chandler was convicted for twice robbing on-duty United States Postal Service employees using a fake gun, and in one instance, kidnapping his victim. The District Court enhanced Chandler's sentence for using the replica gun in the robberies and the kidnapping, and for the kidnapping being motivated, at least in part, by the mail carrier being a government employee.Chandler appealed the application of these two enhancements, arguing that the judge erred in holding that a replica of a gun constitutes a dangerous weapon, and further erred in holding that his kidnapping of the second mail carrier was motivated by her status as a government employee. He also appealed his conviction for armed robbery, rather than unarmed robbery, again arguing that a replica firearm is not a dangerous weapon.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals found that the term "dangerous weapon" is genuinely ambiguous and can include a replica firearm. The Court also found that the District Court did not err in accepting Chandler's guilty plea to armed robbery. Finally, the Court of Appeals agreed with the District Court that Chandler was motivated to kidnap the mail carrier because she was a government employee. View "USA v. Chandler" on Justia Law

The case revolves around the tragic death of Tyler Gergler, a recruit in the Marine Corps' Delayed Entry Program. Gergler died in a car accident while driving to a Marine Corps event, despite being ill. His parents, Raynu Clark and Jason R. Gergler, alleged that Sergeant Mitchell Castner, Gergler's recruiter, negligently pressured their son to drive to the event despite his illness, which led to the fatal accident. They argued that since Castner's actions were within the scope of his Marine Corps employment, the Government was liable for their son's death.The case was initially heard in the United States District Court for the District of New Jersey. The Government moved to dismiss the case, arguing that the United States has sovereign immunity for discretionary acts of government agents. They contended that when Castner pressured Gergler to drive, he was acting as Gergler's recruiter, a discretionary function, and thus, sovereign immunity barred the lawsuit. The District Court agreed with the Government's argument and dismissed the case on the grounds that Castner had discretion and was exercising that discretion.The case was then appealed to the United States Court of Appeals for the Third Circuit. The court affirmed the District Court's decision, ruling that the United States and its agents enjoy sovereign immunity from suit. The court found that Castner had discretion to urge Gergler to attend the event and that his function of preparing Marine recruits for training was discretionary. The court also rejected the parents' arguments that Castner's conduct was so egregious that it goes beyond policy consideration and that a narrow carve-out for easy precautions should apply. The court concluded that the United States is immune from suit when its agents commit alleged torts within the discretion accorded by their job function, and Sergeant Castner's actions were within his discretionary function of preparing Marine recruits for training. View "Clark v. Secretary United States Navy" on Justia Law