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

Patrick Barkers-Woode and Nana Mensah were involved in a conspiracy to defraud Sprint Corporation by exploiting a sales promotion that offered smartphones to new customers at no upfront cost. Conspirators in Ghana obtained personal information of unsuspecting individuals and used it to sign them up as new Sprint customers, arranging for the smartphones to be sent to vacant homes. Barkers-Woode, Mensah, and others tracked, retrieved, and delivered the smartphones to a buyer. The conspiracy was responsible for 274 orders of 833 smartphones, resulting in $357,565.92 in actual loss and $595,399.76 in intended loss. A jury convicted both defendants of mail fraud, aggravated identity theft, and conspiracy to commit these offenses.The United States District Court for the Middle District of Pennsylvania sentenced Barkers-Woode to 111 months’ imprisonment and Mensah to 99 months’ imprisonment. Both defendants appealed, challenging their sentences and, in Barkers-Woode’s case, the admission of certain evidence during the trial.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that the District Court erred in applying a 14-point enhancement based on intended loss rather than actual loss, as required by the court's decision in United States v. Banks. This error affected the defendants' substantial rights, leading the court to reverse and remand for resentencing based on actual loss. The court also upheld the District Court's application of a 2-point enhancement for the number of victims, recognizing that victims of identity theft are included within the definition of "victim" under the Sentencing Guidelines.Additionally, the court affirmed the District Court's decision to admit testimony about a related fraud against Walmart, as it directly proved the conspiratorial agreement. The court also upheld the decision to require Barkers-Woode to proceed pro se after his sixth attorney withdrew, citing his extremely dilatory conduct. Finally, the court rejected Mensah's argument that sentencing enhancements should be based on facts charged in the indictment and proved beyond a reasonable doubt, reaffirming the precedent set in United States v. Grier. View "USA v. Barkers-Woode" on Justia Law

Chenault-Vaughan Family Partnership ("Chenault"), a royalty interest holder in a Texas mineral estate, sued Centennial Resources Operating, LLC ("Centennial"), the site operator, for wrongly withholding royalties. The Bankruptcy Court awarded summary judgment to Centennial. Chenault appealed to the District Court, where the parties consented to proceed before a Magistrate Judge. The Magistrate Judge affirmed the Bankruptcy Court’s judgment, and Chenault appealed to the United States Court of Appeals for the Third Circuit.The Third Circuit first addressed whether the Magistrate Judge had jurisdiction to enter final judgment in the bankruptcy appeal. The court concluded that, with the consent of the parties and a referral by the district court, a magistrate judge may enter final judgment in a bankruptcy appeal. This conclusion was supported by the broad consent authority granted to magistrate judges under 28 U.S.C. § 636(c), the repeal of the statutory provision that previously prohibited such referrals, and the supervisory authority retained by Article III judges.On the merits, the Third Circuit reviewed the Bankruptcy Court’s summary judgment on two claims: trespass to try title and royalties under the Texas Natural Resources Code ("TNRC"). The court affirmed the summary judgment for Centennial on the trespass-to-try-title claim, finding that Centennial did not unlawfully enter the land and dispossess Chenault, as Luxe, a cotenant, had the right to extract minerals and permit Centennial to operate.However, the court vacated the summary judgment on the TNRC claim. The court found that there were genuine disputes of material fact regarding whether Centennial was obligated to pay Unit B royalties to Chenault, particularly concerning the Division Order and Centennial’s knowledge of MDC’s non-signature on the Unit B JOA. The case was remanded to the Magistrate Judge with instructions to remand to the Bankruptcy Court for further proceedings on the TNRC claim. View "In re: MTE Holdings LLC" on Justia Law

Libby Hilsenrath sued the Board of Education of the School District of the Chathams, claiming that the inclusion of instructional videos about Islam in her son's seventh-grade World Cultures and Geography class violated the Establishment Clause of the First Amendment. The class covered various world regions and their predominant religions, including Christianity, Buddhism, Hinduism, and Islam. The specific lessons on Islam included PowerPoint presentations and two YouTube videos, "Intro to Islam" and "The 5 Pillars of Islam," which Hilsenrath argued were proselytizing.The United States District Court for the District of New Jersey granted summary judgment to the Board, finding no Establishment Clause violation. The court applied the Lemon test and later, following a remand due to the Supreme Court's decision in Kennedy v. Bremerton School District, applied a historical analysis. The District Court concluded that the curriculum did not resemble any traditional hallmarks of religious establishment, such as coercion or preferential treatment of one religion over others.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's judgment. The Third Circuit held that the curriculum did not constitute proselytization or coercion, as the videos were part of a secular educational program covering multiple religions. The court also found no evidence of favoritism towards Islam, noting that the curriculum included teachings on various world religions. The court emphasized that the curriculum did not bear any hallmarks of religious establishment and upheld the District Court's decision. View "Hilsenrath v. School District of the Chathams" on Justia Law

Plaintiffs, who are probationers, sued several Pennsylvania judges, probation officers, and the county warden, alleging they were detained without a finding that such detention was necessary to prevent flight or further crimes. They claimed their due process rights were violated as they were held for months without adequate preliminary hearings or credible probable-cause findings.The United States District Court for the Western District of Pennsylvania denied a preliminary injunction and later granted summary judgment for the defendants on both claims. The court held that the plaintiffs' novel claim for a new procedural right conflicted with Supreme Court precedent and found no genuine dispute of material fact regarding the county's adherence to existing constitutional rules in initial hearings.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that probationers do not have a due process right to a finding of necessity before being detained between preliminary and revocation hearings. The Supreme Court's decisions in Morrissey v. Brewer and Gagnon v. Scarpelli established that a finding of probable cause at a preliminary hearing is sufficient to warrant continued detention for a reasonable time until the revocation hearing.However, the Third Circuit found material factual disputes regarding whether the county followed due process rules, particularly concerning the adequacy of notice given to probationers before preliminary hearings. The court reversed and remanded the case in part, allowing plaintiffs to proceed with their claim that the county did not follow established due process procedures. View "Horton v. Rangos" on Justia Law

David Payo pled guilty to two bank robberies in 2017. The District Court applied a career-offender enhancement to his sentence based on three prior robbery convictions: a 2001 federal conviction, a 2008 Pennsylvania conviction, and a 2010 Pennsylvania conviction. Payo argued that the 2008 and 2010 convictions did not involve crimes of violence, but the District Court disagreed, relying on a state-court docket sheet and an argument not advanced by the Government.The United States District Court for the Western District of Pennsylvania held that Payo's 2008 conviction was under § 3701(a)(1)(ii) and his 2010 conviction under § 3701(a)(1)(iv) qualified as a crime of violence under the enumerated-offenses clause. Payo appealed, arguing that the District Court improperly relied on a non-Shepard document (the docket sheet) and advanced an argument the Government had not made.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court erred in relying on the state-court docket sheet, which was not a Shepard document, and in advancing an argument the Government had not made regarding the 2010 conviction. The Third Circuit vacated Payo's sentence and remanded the case for further proceedings, instructing the District Court to determine whether Payo's 2008 conviction was under § 3701(a)(1)(i) or (ii) using only the Shepard documents produced by the Government initially. If the conviction was under subsection (ii), the enhancement stands; otherwise, it does not. View "USA v. Payo" on Justia Law

The Public Interest Legal Foundation (PILF) requested records from the Secretary of the Commonwealth of Pennsylvania under the National Voter Registration Act of 1993 (NVRA). PILF sought documents related to a "glitch" in the Pennsylvania Department of Transportation's system that allowed ineligible persons to register to vote. The Secretary denied the request, leading PILF to file a lawsuit claiming an informational injury due to the denial of access to the records.The United States District Court for the Middle District of Pennsylvania initially dismissed the suit for lack of statutory notice but found that PILF had standing based on an informational injury. After PILF provided the required notice and refiled the suit, the District Court granted and denied parts of both parties' summary judgment motions, ruling that PILF was entitled to some records but not others. The District Court did not reassess PILF's standing in light of the Supreme Court's decision in TransUnion v. Ramirez.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that PILF lacked standing. The court held that PILF did not demonstrate a concrete harm or adverse effects from the denial of information, as required by TransUnion. The court emphasized that PILF's inability to study and analyze the records or produce educational materials did not constitute a concrete injury related to the NVRA's purpose of increasing voter participation. Consequently, the Third Circuit vacated the District Court's orders and remanded the case with instructions to dismiss it. View "The Public Interest Legal Foundation v. Secretary Commonwealth of Pennsylvania" on Justia Law

The appellants, Robin and Louie Joseph Aquilino, filed for Chapter 7 bankruptcy in April 2020 and retained the law firm Spector Gadon Rosen & Vinci P.C. (Spector Gadon) as their counsel. They agreed to pay a flat fee of $3,500 and a $335 filing fee, which Spector Gadon disclosed to the Bankruptcy Court. However, due to the complexity of the case, Spector Gadon billed the Aquilinos for additional post-petition services, resulting in a fee agreement of $113,000, which was not disclosed to the Bankruptcy Court as required by 11 U.S.C. § 329(a) and Bankruptcy Rule 2016(b).The Bankruptcy Court for the District of New Jersey found that Spector Gadon violated the disclosure requirements and sanctioned the firm by ordering the disgorgement of collected fees and cancellation of the remaining fee agreement. Spector Gadon appealed, and the United States District Court for the District of New Jersey reversed the Bankruptcy Court's decision, concluding that Spector Gadon was entitled to a jury trial under the Seventh Amendment.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the Bankruptcy Court had "core" jurisdiction over the fee disclosure issue under 28 U.S.C. § 157(b)(1). The Third Circuit held that the Seventh Amendment did not entitle Spector Gadon to a jury trial in the § 329(a) proceeding because the sanctions imposed were equitable in nature, designed to restore the status quo, and did not involve legal claims. The Third Circuit also found that the Bankruptcy Court did not abuse its discretion in imposing sanctions, as it considered all relevant factors, including the Debtors' misconduct.The Third Circuit reversed the District Court's judgment and reinstated the Bankruptcy Court's sanctions order. View "In re Aquilino" on Justia Law

Randal Wise was convicted of possessing child pornography, attempting to entice a minor, and attempting to transfer obscene matter to a minor. Wise used the Grindr app to contact undercover police officers posing as minors, sending explicit photos and attempting to arrange meetings for sexual activities. He was arrested while holding an iPhone that contained sexual chats and child pornography.The United States District Court for the District of New Jersey denied Wise's motion to sever the charges, and the jury convicted him on all counts. The judge sentenced him to 288 months in prison. Wise appealed, arguing that the charges should not have been joined and that the District Court should have severed them. He also raised several sentencing claims.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the charges were properly joined as they involved the sexual exploitation of minors. The court found no abuse of discretion in the District Court's decision to deny severance, as there was little risk of spillover prejudice, and the jury was instructed to consider each charge separately.The Third Circuit also upheld Wise's sentence. The court found that the District Court properly applied a five-level enhancement for a pattern of sexual abuse or exploitation of a minor and another five-level enhancement for repeated sex crimes against minors. The court also held that an iPhone qualifies as a computer under U.S.S.G. § 2G2.2(b)(6), thus justifying the two-level enhancement for using a computer in the crime.Finally, the court declined to address Wise's ineffective assistance of counsel claim, suggesting it be raised in a collateral review. The Third Circuit affirmed the District Court's judgment. View "USA v. Wise" on Justia Law

Ronald Vines and his two adult sons attempted to rob a bank at gunpoint. They gathered weapons and other equipment, set up a tarp outside the bank, and waited for the tellers to arrive. One of Vines's sons, wearing a mask and armed with a revolver, forced a teller inside at gunpoint. However, another employee saw them and raised the alarm, causing Vines to signal his son to flee. They were apprehended by the police shortly after.Vines pleaded guilty to attempted armed bank robbery under 18 U.S.C. §§ 2113(d) & 2 and brandishing a gun while committing a crime of violence under 18 U.S.C. §§ 924(c)(1)(A)(ii) & 2. He did not initially challenge his § 924(c) charge, so he had to do so collaterally under 28 U.S.C. § 2255. The United States District Court for the Eastern District of Pennsylvania denied his motion but granted a certificate of appealability. On appeal, Vines was allowed to argue that his plea lawyer was ineffective for not asserting that attempted armed bank robbery is not a crime of violence.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that attempted armed bank robbery under 18 U.S.C. § 2113(d) is a crime of violence because it requires the use of force, violence, or intimidation. The court also found that adding a dangerous weapon to the attempted bank robbery does not make the crime less violent. Therefore, Vines's conviction under § 924(c) was upheld. The court also concluded that Vines's counsel was not ineffective, as the argument that attempted armed bank robbery is not a crime of violence would have been meritless. The Third Circuit affirmed the District Court's order denying Vines's collateral attack. View "USA v. Vines" on Justia Law

Mesabi Metallics Company LLC (Mesabi) filed for Chapter 11 bankruptcy in 2016 and emerged successfully in 2017. During the bankruptcy proceedings, Mesabi initiated an adversary proceeding against Cleveland-Cliffs, Inc. (Cliffs), alleging tortious interference, antitrust violations, and civil conspiracy. Mesabi claimed Cliffs engaged in anti-competitive conduct to impede Mesabi's business operations. To facilitate discovery, the parties entered a stipulated protective order allowing documents to be designated as confidential. Mesabi later moved to unseal certain documents filed under seal to support a petition in the Minnesota Court of Appeals.The United States Bankruptcy Court for the District of Delaware, applying the common law right of access, held that Cliffs had not met the burden to keep the documents sealed. The court relied on the Third Circuit's precedent in In re Avandia, which requires a showing that disclosure would cause a clearly defined and serious injury. Recognizing potential ambiguity in the law, the Bankruptcy Court certified the question for direct appeal to the United States Court of Appeals for the Third Circuit.The Third Circuit clarified that the sealing of documents in bankruptcy cases is governed by 11 U.S.C. § 107, not the common law right of access. Section 107 imposes a distinct burden, requiring protection of trade secrets or confidential commercial information without the need for balancing public and private interests. The court vacated the Bankruptcy Court's decision and remanded for application of the correct standard under § 107. Additionally, the Third Circuit held that the Bankruptcy Court lacked jurisdiction to grant a third party's motion to intervene and unseal documents while the appeal was pending, vacating those orders as well. View "ESML Holdings Inc v. Mesabi Metallics Compay LLC," on Justia Law