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

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

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

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

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

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

The case involves a dispute over the Federal Energy Regulatory Commission (FERC) allowing a new auction rule to apply retroactively to a pending auction. This auction was administered by PJM Interconnection L.L.C., an entity responsible for running the auction. The petitioners, electric suppliers and their trade associations, contended that FERC's orders violated the filed rate doctrine, which forbids retroactive rates.The United States Court of Appeals for the Third Circuit found that the Tariff Amendment was retroactive because it altered the legal consequence attached to a past action when it allowed PJM to use a different Locational Deliverability Area (LDA) Reliability Requirement than the one it had calculated and posted. The court noted that the Tariff Amendment, therefore, violated the filed rate doctrine.The court ruled that the doctrine's predictability is crucial because electricity markets depend on it. FERC’s disregard of the filed rate doctrine created unpredictability in the markets, potentially eroding confidence in the markets and ultimately harming consumers who buy electricity in those markets.The court granted the petitions for review and vacated the portion of FERC’s orders that allowed PJM to apply the Tariff Amendment to the 2024/25 capacity auction. View "Constellation Energy Generation LLC v. FERC" on Justia Law

A group of power providers contested orders from the Federal Energy Regulatory Commission (FERC) that permitted a new auction rule to retroactively apply to a pending auction. The petitioners argued that this violated the filed rate doctrine, which forbids retroactive rates. The auction, administered by the PJM Interconnection LLC (PJM), aimed to ensure reliable electric supply at competitive prices. PJM halted the auction, seeking FERC's permission to amend certain auction parameters it had already posted, which, if left uncorrected, might have led to a high clearing price for a specific region. FERC approved the amendment and allowed it to apply to the halted auction, which the petitioners challenged. The United States Court of Appeals for the Third Circuit agreed with the petitioners, stating that the amendment was retroactive as it altered the legal consequence attached to PJM's past action in the auction. The court granted the petitions and vacated the portion of FERC's orders that allowed the amendment to apply to the auction in question. View "NRG Power Marketing v. FERC" on Justia Law

Several power providers and their associations challenged orders from the Federal Energy Regulatory Commission (FERC) that retroactively permitted a new auction rule to apply to a pending auction. The rule was implemented by PJM Interconnection L.L.C., the entity responsible for the auction, to determine the auction's results. The petitioners claimed FERC's orders violated the filed rate doctrine, which prohibits retroactive rates. The case background involves the Federal Power Act (FPA), which grants FERC exclusive jurisdiction over rates for the transmission and wholesale of electric energy in interstate commerce. The FPA requires all related rates, rules, and regulations to be "just and reasonable" and not unduly preferential.The petitioners and FERC agreed that the filed rate was the PJM Open Access Transmission Tariff, which sets the procedures governing PJM’s capacity auctions. PJM administered a capacity auction in December 2022 for capacity in the June 2024 – May 2025 period. A dispute arose when PJM sought to adjust the Locational Deliverability Area (LDA) Reliability Requirement due to perceived anomalies in the auction results, which would have resulted in a high clearing price for a certain region. FERC approved the proposed adjustment, which was challenged by the petitioners.The court agreed with the petitioners and held that the orders of FERC were retroactive and thus violated the filed rate doctrine. The court granted the petitions and vacated the orders in the relevant part. The court emphasized that the equities play no role in the application of the filed rate doctrine and that predictability is of paramount importance in electricity markets. It concluded that FERC’s disregard of the filed rate doctrine creates unpredictability in the markets and may ultimately harm consumers who buy electricity in those markets. View "Electric Power Supply Association v. FERC" on Justia Law

In this case, a group of electricity suppliers and their trade associations challenged orders of the Federal Energy Regulatory Commission (FERC) that permitted PJM Interconnection L.L.C., a wholesale market operator, to apply a new auction rule retroactively to a pending auction. The petitioners argued that FERC's orders violated the filed rate doctrine, which prohibits retroactive rates. The United States Court of Appeals for the Third Circuit agreed and granted the petitions, vacating the relevant parts of the orders.The central issue revolved around the Locational Deliverability Area (LDA) Reliability Requirement, a key parameter in PJM's auction process. Prior to the auction, PJM had miscalculated the LDA Reliability Requirement, which led to a potential price increase for a specific region. To correct this, PJM sought FERC's permission to amend the tariff to allow for a downward adjustment of the LDA Reliability Requirement. FERC granted this permission, allowing the new rule to apply to the ongoing auction, which the petitioners argued was a retroactive change in violation of the filed rate doctrine.The court found that the tariff amendment was indeed retroactive as it altered the legal consequence attached to a past action, specifically, PJM's calculation and posting of the LDA Reliability Requirement. The court held that the filed rate doctrine did not yield to equities and that the tariff amendment's retroactivity created instability in the electricity market. Consequently, the court vacated the portion of FERC's orders that allowed PJM to apply the tariff amendment to the 2024/25 capacity auction. View "NRG Business Marketing LLC v. FERC" on Justia Law

This case involved several petitioners challenging orders of the Federal Energy Regulatory Commission (FERC), which allowed a new auction rule to retroactively apply to an auction that was already underway. The auction was managed by PJM Interconnection L.L.C. (PJM), which ran the auction based on a tariff (filed rate) that set out specific procedures. The petitioners argued that FERC's orders violated the filed rate doctrine, which prohibits retroactive rates.The United States Court of Appeals for the Third Circuit agreed with the petitioners. The court found that the new rule was retroactive because it altered the legal consequences attached to past actions. Specifically, the rule allowed PJM to use a different Locational Deliverability Area (LDA) Reliability Requirement than the one it had calculated and posted.The court noted that, while FERC's orders were seemingly intended to prevent potential economic harm to consumers, the filed rate doctrine's emphasis on predictability and the necessity of adherence to approved rates were paramount. The court concluded that FERC's orders, by allowing a change to the rules of an auction already in progress, introduced unpredictability into the electricity market, potentially eroding market confidence.Therefore, the court granted the petitions for review and vacated the portion of FERC's orders that allowed PJM to apply the new rule to the auction that was already underway. The court did not strike down the rule entirely, leaving open the possibility of it being applied to future auctions. View "Electric Power Supply Association v. FERC" on Justia Law