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

Articles Posted in Government & Administrative Law
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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

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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

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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

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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

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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

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The case revolves around Victor Cora-Alicea, who was involved in a drug trafficking operation led by Ramone Velazquez. Cora-Alicea, who had no supervisory responsibilities and was merely tasked with bagging drugs, was arrested and pleaded guilty to violations of drug trafficking laws. His sentencing was calculated based on a base offense level of 31, with reductions for his safety-valve eligibility, minor role, and acceptance of responsibility, resulting in a total offense level of 24. His criminal history category I was based on a nonexistent criminal record. The District Court set his Guidelines range at 51–63 months. Cora-Alicea requested a mitigation-based variance from the range, arguing that his life history, personal characteristics, and an anticipated change to the Guidelines for people with zero criminal history points justified a variance to approximately 24 months’ imprisonment.The District Court sentenced Cora-Alicea to 45 months on each count, to be served concurrently, followed by a total of three years on supervised release. The court took into consideration his zero-point status but ignored Cora-Alicea’s other bases for a variance. Cora-Alicea appealed the District Court’s judgment, arguing that the court procedurally erred at sentencing by dismissing the majority of his personal mitigation evidence offered in support of a variance under 18 U.S.C. § 3553(a) on the ground that it was “already taken into account” by the downward adjustments under the Guidelines.The United States Court of Appeals for the Third Circuit found that the District Court had erred in its interpretation of the Guidelines. The court noted that the safety-valve provision, minor-role, and acceptance-of-responsibility adjustments considered in Cora-Alicea’s sentencing had nothing to do with the myriad of mitigating circumstances he raised under § 3553(a). The court concluded that the District Court's erroneous legal conclusion preempted any weighing of the mitigation evidence against the Guidelines range or the other sentencing factors. As a result, the court vacated Cora-Alicea’s sentence and remanded his case to the District Court for resentencing. View "USA v. Cora-Alicea" on Justia Law

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The case involves a dispute over the Environmental Protection Agency's (EPA) decision to implement a Federal Implementation Plan (FIP) to regulate emissions in Pennsylvania. The Commonwealth of Pennsylvania had initially submitted a State Implementation Plan (SIP) to the EPA for approval, as required by the Clean Air Act. The EPA initially approved the plan, but the approval was later vacated by the Third Circuit Court of Appeals, which directed the EPA to either approve a new state-made plan or formulate a new federal plan within two years. The EPA decided to create its own plan, which was challenged by the Commonwealth and one of the three coal power companies affected by the plan.The petitioners argued that the EPA exceeded its statutory authority when it promulgated the plan and that the plan was arbitrary and capricious because the EPA failed to show its work. However, the Third Circuit Court of Appeals found that the EPA acted in accordance with the Clean Air Act and denied the petition for review. The court held that the EPA properly exercised its authority under the Clean Air Act by partially disapproving the 2016 SIP and promulgating the FIP. The court also held that the contents of the FIP were not arbitrary, capricious, or an abuse of the EPA’s discretion. View "Keystone-Conemaugh Projects LLC v. EPA" on Justia Law

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Paul Montemuro was elected as the President of the Jim Thorpe Area School Board. However, a week later, the Board elected someone else without giving Montemuro any prior notice. Montemuro sued the Board members who voted against him and the Jim Thorpe Area School District, alleging that they had deprived him of his property without due process, in violation of 42 U.S.C. § 1983 and the Fourteenth Amendment. The defendants claimed qualified immunity.The District Court held that Montemuro had a clearly established property right in his employment and had been deprived of that right without due process. The defendants appealed this decision, arguing that they were entitled to qualified immunity.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court found that Pennsylvania law clearly established that Montemuro had a property interest in his job as the Board President. The Court also accepted Montemuro's allegation that he was removed from office without notice. Therefore, the Court concluded that the defendants were not entitled to qualified immunity because they had violated Montemuro's clearly established right to due process. View "Montemuro v. Jim Thorpe Area School District" on Justia Law

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Michael Rivera, a Pennsylvania state prisoner, was in an open-air telephone cage when he overheard prison officials preparing to forcibly extract another inmate, Ryan Miller, from a nearby cell. Anticipating the use of pepper spray, Rivera informed the officials that exposure to the spray would trigger his asthma. Despite his pleas to be moved back to his cell, the officials refused, citing the lack of available personnel due to the ongoing preparations for Miller's extraction. After the pepper spray was deployed, Rivera suffered an asthma attack. He sued the prison officials for damages, alleging they had acted with deliberate indifference to the substantial risk of serious harm to him, in violation of the Eighth Amendment.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the prison officials. The court concluded that the law was not clearly established to the extent that the officials would have known that their actions violated the Eighth Amendment.On appeal, the United States Court of Appeals for the Third Circuit affirmed the lower court's decision. The appellate court found that the prison officials were entitled to qualified immunity because their actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. The court noted that the officials were confronted with competing institutional concerns and that the cited case law did not clearly establish that the officials' decision to prioritize one prisoner's health and safety over another's violated the Eighth Amendment. View "Rivera v. Redfern" on Justia Law

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In this case, a group of electricity providers challenged orders by the Federal Energy Regulatory Commission (FERC), arguing that FERC allowed a new auction rule to apply retroactively to a pending auction. The auction was overseen by PJM Interconnection L.L.C., a FERC-regulated wholesale market operator. PJM had halted the auction upon realizing that the results could lead to a high clearing price for a particular region due to a faulty assumption regarding the participation of certain resources. PJM sought and received permission from FERC to amend the tariff to allow it to adjust the Locational Deliverability Area (LDA) Reliability Requirement downward, reflecting the lack of participation of certain resources.The petitioners argued that this violated the filed rate doctrine, which prohibits retroactive rates. The court agreed, finding that the tariff amendment was retroactive because it altered the legal consequence attached to a past action: it allowed for the use of a different LDA Reliability Requirement than the one PJM had calculated and posted. The court noted that equitable considerations did not factor into the application of the filed rate doctrine, emphasizing the importance of predictability in the electricity markets.The court granted the petitions and vacated the orders in relevant part, specifically the portion of FERC’s orders that permitted PJM to apply the tariff amendment to the 2024/25 capacity auction. View "Constellation Energy Generation LLC v. FERC" on Justia Law