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

An electronics technician employed by a regional transit authority was killed while working at a maintenance yard. His estate, through its administrator, brought suit against the transit authority and its parent entity, seeking recovery under the Federal Employers Liability Act (FELA), which provides a federal cause of action for employees of “common carriers by railroad” injured or killed during their employment. The transit line in question, known as the Speed Line, operates a 14.5-mile route between Philadelphia, Pennsylvania, and Lindenwold, New Jersey, providing frequent, high-capacity passenger service within a single metropolitan area. The Speed Line uses a third-rail electric system incompatible with other regional railroads, does not carry freight, and is not integrated with other rail lines.The United States District Court for the District of New Jersey initially denied the defendants’ motion to dismiss for lack of subject-matter jurisdiction, allowing jurisdictional discovery. After discovery, the District Court granted the renewed motion to dismiss, holding that the Speed Line is an urban rapid transit system rather than a railroad, and therefore FELA does not apply. The estate appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s legal conclusions de novo and its factual findings for clear error. The Third Circuit affirmed the District Court’s judgment, holding that the Speed Line is not a “common carrier by railroad” within the meaning of FELA. The court reasoned that the Speed Line’s services—short-haul, high-frequency passenger transportation within a single urban area—and its lack of integration with other railroads or freight operations, place it outside the scope of FELA. The court concluded that, as a rapid transit system, the Speed Line is not subject to FELA, and thus the federal courts lack subject-matter jurisdiction over the estate’s FELA claim. View "Estate of Schroeder v. Port Authority Transit Corp." on Justia Law

Axalta Coating Systems LLC ("Axalta") provided a can of flammable paint to FedEx for air shipment. The paint spilled during transit due to a loose lid. The Federal Aviation Administration (FAA) filed an administrative complaint alleging Axalta failed to package the paint according to the Hazardous Materials Regulations (HMR). An Administrative Law Judge (ALJ) found Axalta in violation and imposed a $1,900 penalty, which the FAA Administrator affirmed. Axalta petitioned for review, arguing the administrative adjudication violated the Seventh Amendment's jury trial guarantee, referencing the Supreme Court's decision in SEC v. Jarkesy.The ALJ denied Axalta's motion to dismiss the complaint and a motion to disqualify the ALJ. After a hearing, the ALJ concluded Axalta violated 49 C.F.R. § 171.2(e) and 49 C.F.R. § 173.24(b)(1), assessing a $1,900 penalty. Axalta appealed, and the FAA cross-appealed for a higher penalty. The Administrator affirmed the ALJ's decision. Axalta then petitioned the United States Court of Appeals for the Third Circuit for review.The Third Circuit held that the administrative adjudication did not violate the Seventh Amendment. The court distinguished the case from Jarkesy, noting that the HMR's technical standards were not derived from common law, unlike the securities fraud provisions in Jarkesy. The court concluded that the FAA's enforcement action was a public right that could be adjudicated administratively without a jury. The court also rejected Axalta's additional arguments, including claims of unconstitutional delegation of legislative power, improper ALJ appointment, statute of limitations issues, and due process violations. The petition for review was denied. View "Axalta Coating Systems LLC v. Federal Aviation Administration" on Justia Law

Plaintiffs Charles and Grant Adler, through their business entity CM Adler LLC, distributed tortillas and other food products of Defendant Gruma Corporation to grocery stores in central New Jersey under a "Store Door Distributor Agreement" (SDDA). When Defendant terminated the relationship, Plaintiffs filed a lawsuit alleging retaliatory termination due to their organizing efforts with other distributors. Plaintiffs claimed violations of state and federal labor laws, including failure to pay minimum wages and unlawful deductions, and argued that the SDDA was a franchise agreement subject to New Jersey's Franchise Practices Act, which forbids termination without cause.The United States District Court for the District of New Jersey dismissed the case, concluding that Texas law governed under the SDDA and the case should proceed to arbitration. The District Court did not address the applicability of the Federal Arbitration Act (FAA) or Plaintiffs' exemption argument under 9 U.S.C. § 1. It found the parties had contracted for Texas law, under which the arbitration agreement was enforceable, and rejected Plaintiffs' bid to apply New Jersey law instead. The District Court also decided that Charles and Grant Adler, who did not sign the contract, were estopped from challenging its arbitration provision because they acted as parties to the contract when they performed the LLC’s work.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the FAA does not apply to the SDDA because Plaintiffs are transportation workers engaged in interstate commerce. The Court of Appeals found that the District Court erred in its choice-of-law analysis by failing to consider the impact of New Jersey public policies on its arbitrability ruling. The Court of Appeals vacated the order compelling arbitration and remanded for the District Court to complete the choice-of-law analysis under the correct framework and to reevaluate whether the individual Plaintiffs, who did not sign the arbitration agreement, are bound by its terms. View "Adler v. Gruma Corporation" on Justia Law

A group of petitioners, including several municipalities, private individuals, and organizations, challenged the Federal Aviation Administration's (FAA) approval of a new terminal for the Trenton-Mercer Airport. The petitioners alleged that the FAA’s decision violated the National Environmental Policy Act (NEPA) by failing to fully consider the environmental impact of the new terminal, among other things. The United States Court of Appeals for the Third Circuit found that the FAA had adequately considered the environmental impact of the new terminal and had not violated NEPA. The court found that the FAA reasonably concluded that the new terminal would not induce additional air traffic, and therefore, would not result in increased noise or air pollution. The court also found that the FAA had conducted a reasonable environmental justice analysis and did not need to perform a health risk assessment. The Court of Appeals denied the petitioners' request to review the FAA's decision. View "Trenton Threatened Skies Inc v. FAA" on Justia Law

Warren tenders gasoline products to Colonial (a common carrier) for shipment on Colonial’s pipeline from Texas to New Jersey, where Warren has a gasoline-blending operation. The rates and conditions for the transportation services are specified in tariffs approved by the Federal Energy Regulation Commission (FERC). The tariff recognizes that the gasoline batches Colonial transports for Warren are fungible and allows Colonial to comingle gasoline from many shippers during transport. Colonial must deliver gasoline of the same volume and grade as the gasoline that was entrusted to it, with the same characteristics that influence the gasoline’s combustion performance (octane rating and distillation value), and its environmental impact, such as volatility. The tariff does not state whether “on specification” gasoline includes any “blend margin.” In 2016, FERC determined that the regulation of in-pipeline blending was outside its jurisdiction. Colonial continued giving Warren gasoline that complies with the relevant tariff but Warren claims that Colonial’s in-line blending of the gasoline with butane diminishes Warren’s ability to blend cheaper blendstocks into the gasoline. Warren regularly blends cheaper gasoline with more expensive gasoline to increase the amount of on-specification gasoline that it can sell,Warren sued for loss of profits (Carmack Amendment 49 U.S.C. 1590), conversion, unjust enrichment, and tortious interference. The Third Circuit affirmed the summary judgment rejection of the claims. Warren’s request seeks an enlargement of its rights under the FERC-approved tariff and violates the filed-rate doctrine’s nondiscrimination principle. View "George E. Warren LLC v. Colonial Pipeline Co" on Justia Law

The Reefer arrived at the Port of Wilmington, Delaware for what its owner, Nederland, expected to be a short stay. Upon inspection, the Coast Guard suspected that the vessel had discharged dirty bilge water directly overboard and misrepresented in its record book that the ship’s oil water separator had been used to clean the bilge water prior to discharge. Nederland, wanting to get the ship back to sea as rapidly as possible, entered into an agreement with the government for the release of the Reefer in exchange for a surety bond to cover potential fines. Although Nederland delivered the bond and met other requirements, the vessel was detained in Wilmington for at least two additional weeks.Nederland sued. The Delaware district court dismissed the complaint, holding that Nederland’s claims had to be brought in the U.S. Court of Federal Claims because the breach of contract claim did not invoke admiralty jurisdiction a claim under the Act to Prevent Pollution from Ships (APPS) failed because of sovereign immunity. The Third Circuit reversed. The agreement is maritime in nature and invokes the district court’s admiralty jurisdiction. The primary objective of the agreement was to secure the vessel's departure clearance so that it could continue its maritime trade. APPS explicitly waives the government’s sovereign immunity. View "Nederland Shipping Corp. v. United States" on Justia Law

A regulation promulgated under the National Traffic and Motor Vehicle Safety Act, 49 U.S.C. 30101, requires a tire dealer to help customers register their new tires with the manufacturer. The regulation prescribes three methods for tire dealers to help register a buyer’s tires. According to Thorne, Pep Boys failed to pursue any of the three when, or after, it sold her the tires. She sued on behalf of a class of Pep Boys customers who similarly received no tire registration assistance.The district court dismissed her complaint without leave to amend, holding that a dealer’s failure to help register a buyer’s tires in one of the three prescribed ways does not, by itself, create an injury-in-fact for purposes of Article III standing. The Third Circuit vacated and remanded for dismissal without prejudice. A district court has no jurisdiction to rule on the merits when a plaintiff lacks standing. Thorne’s benefit-of-the-bargain allegations do not support a viable theory of economic injury, and her product-defect argument ignores the statute’s defined terms. Unregistered tires are not worth less than Thorne paid and are not defective. Congress did not intend to give private attorneys general standing to redress the “injury” of unregistered tires. View "Thorne v. Pep Boys Manny Moe & Jack" on Justia Law

The Federal Arbitration Act (FAA), 9 U.S.C. 1–16, places certain arbitration agreements on equal footing with all other contracts, requiring courts to enforce such agreements according to their terms. Section 2 provides that the FAA covers “a written provision in any maritime transaction or a contract evidencing a transaction involving commerce,” but section 1 states that “nothing” in the FAA “shall apply to contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” Singh brought this putative class action on behalf of New Jersey Uber drivers, alleging that Uber misclassified them as independent contractors rather than employees, which resulted in their being deprived of overtime compensation and incurring business expenses for Uber's benefit. Singh opposed a motion to compel arbitration, arguing that, to the extent that he had an agreement with Uber, it fell within the “any other class of workers” portion of section 1. The court dismissed, concluding that clause only extends to transportation workers who transport goods. The Third Circuit disagreed, citing its “longstanding precedent,” to hold that the residual clause of section 1 may extend to a class of transportation workers who transport passengers if they are engaged in interstate commerce or in work so closely related thereto as to be in practical effect part of it. The court remanded for resolution of the engaged-in-interstate-commerce inquiry. View "Singh v. Uber Technologies, Inc." on Justia Law

After a confrontational screening at Philadelphia International Airport in 2006, during which police were called, Pellegrino asserted intentional tort claims against TSA screeners. Under the Federal Tort Claims Act, the government generally enjoys sovereign immunity for intentional torts committed by federal employees, subject to the “law enforcement proviso” exception, which waives immunity for a subset of intentional torts committed by employees who qualify as “investigative or law enforcement officers,” 28 U.S.C. 2680(h). The Third Circuit first affirmed the dismissal of Pellegrino’s suit, holding that TSA screeners are not “investigative or law enforcement officers.” On rehearing, en banc, the court reinstated the suit. The words of the proviso dictate the result: TSOs are “officer[s] of the United States” empowered to “execute searches” for “violations of Federal law.” View "Pellegrino v. Transportation Safety Administration" on Justia Law

The Federal Railway Safety Act (FRSA) provides that if railroad carriers retaliate against employees who report safety violations, the aggrieved employee may file a complaint with OSHA within 180 days after the alleged retaliation, 49 U.S.C. 20109(d)(2)(A)(ii). The Secretary of Labor then has 210 days to issue a final decision. If the Secretary takes too long, the employee may file suit. Guerra, a Conrail conductor and brakeman, alleged that Conrail urged him to ignore safety regulations. When he refused, Conrail threatened him and eliminated incidental perks of his job. Guerra reported this to Conrail’s compliance office. He says he was told that if he kept reporting safety issues, there would be “undesirable consequences.” Soon after Guerra filed complaints about allegedly defective braking systems, a train Guerra was operating failed to brake properly and ran through a railroad switch. On April 6, 2016, Conrail notified Guerra that he would be suspended. On May 10, Guerra’s attorney, Katz, allegedly filed a FRSA complaint. Receiving no response, on November 28, Katz followed up with OSHA by email. OSHA notified Guerra that his claim was dismissed as untimely because OSHA first received Guerra’s complaint 237 days after the retaliation. Guerra attempted to invoke the common-law mailbox rule’s presumption of delivery. The district court dismissed for lack of jurisdiction. The Third Circuit affirmed on other grounds. FRSA’s 180-day limitations period is a non-jurisdictional claim-processing rule. Guerra’s claim still fails because he has not produced enough reliable evidence to invoke the common-law mailbox rule. View "Guerra v. Consolidated Rail Corp" on Justia Law