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

Shiheem Amos appealed the denial of his motion to suppress a firearm, which was found after he was stopped by police officers who suspected him of being involved in a disturbance reported at a nearby location. Amos argued that he was seized without reasonable suspicion, and therefore the firearm should not have been admissible in court. The United States Court of Appeals for the Third Circuit held that Amos was not seized until after he attempted to flee from the police officers, and at that point, the officers had reasonable suspicion to seize him based on his attempt to flee. Thus, the firearm was admissible, and the motion to suppress was correctly denied.Amos also challenged his 62-month sentence, which included an enhancement for a previous state court conviction that was classified as a crime of violence under the United States Sentencing Guidelines. The court records did not specify which subsection of the Pennsylvania aggravated assault statute Amos had been convicted under, but the government argued that all possible subsections qualified as a crime of violence. However, the Third Circuit held that one of the subsections, which can be violated by a failure to act, does not meet the definition of a crime of violence because it does not require the use of violent force. Therefore, the court vacated Amos's sentence and remanded for resentencing without the crime of violence enhancement. View "USA v. Amos" on Justia Law

In this case, Daniel Coach and Clifton Junius, who were both involved in a drug distribution operation, appealed the denials of their motions for sentence reduction under the First Step Act. They argued that their convictions for intentional killing in furtherance of a continuing criminal conspiracy were "covered offenses" under the Act, and hence, they were eligible for sentencing relief for their convictions under that statute. The United States Court of Appeals for the Third Circuit disagreed with the appellants' arguments, holding that drug-related murder under 28 U.S.C. § 848(e)(1)(A) is not a covered offense under the First Step Act.The appellants also argued that their murder and drug charges on which they were sentenced were interdependent, so they were eligible for sentence reduction under the sentencing package doctrine. The court disagreed, stating that the sentencing package doctrine does not apply to this case because the sentences imposed on Coach and Junius for murder in furtherance of a continuing criminal enterprise were imposed independently from their cocaine base distribution charges and were not part of a sentencing package. The court affirmed the lower court's decision denying the motions for sentence reduction. View "USA v. Coach" on Justia Law

The United States Court of Appeals for the Third Circuit heard an appeal by Mark Jordan regarding his conviction for armed bank robbery and associated gun charges. The main issue was whether armed bank robbery can be considered a "crime of violence" under a federal gun statute. Jordan argued that armed bank robbery could be committed recklessly, and therefore should not count as a crime of violence.The court, however, found that the federal armed bank robbery statute is divisible into different crimes, and the specific crime that Jordan pleaded guilty to required purpose or knowledge, not recklessness. Therefore, using the modified categorical approach, the court held that armed bank robbery is a crime of violence. The court also held that whenever a federal crime is predicated on committing another crime, the elements of the predicate crime are considered elements of the first crime as well.In regards to the facts of the case, Jordan committed three bank robberies, during two of which he fired a gun. He was charged with three counts of armed bank robbery under 18 U.S.C. § 2113(d) and two gun charges under 18 U.S.C. § 924(c). He pleaded guilty to all five counts and was sentenced to 318 months in prison. He later challenged his sentence, arguing that § 2113(d) is not a "crime of violence" under § 924(c), which is what the court ultimately disagreed with. View "USA v. Jordan" on Justia Law

The case involves an appeal by Michael Caraballo who was sentenced for an aggravated assault. He challenges the District Court's finding that the injuries sustained by his victim amounted to serious bodily injury rather than bodily injury under the United States Sentencing Guidelines, which resulted in a higher guideline range for Caraballo. The case arose from an incident where Caraballo, an inmate, assaulted another inmate with a five-inch metal shank, causing the victim to sustain a number of puncture wounds, a fractured mandible, and abrasions. Caraballo pleaded guilty to assault with a dangerous weapon, aiding and abetting, and possessing contraband in prison. During the sentencing hearing, Caraballo's counsel objected to the five-level sentencing enhancement for causing serious bodily injury. The District Court overruled the objection and sentenced Caraballo on the low end of the range, which was 63 months. Caraballo appealed, arguing that the injuries caused to the victim constituted bodily injury, not serious bodily injury.The U.S. Court of Appeals for the Third Circuit held that the phrase "serious bodily injury" as used in the relevant guideline is ambiguous. Therefore, it turned to the Sentencing Commission's interpretation of the phrase in the commentary to the Guidelines. The court held that the reasonableness, character, and context of the Sentencing Commission's interpretation entitles it to controlling weight. Applying the commentary definition, the court held that the District Court did not commit clear error by concluding that the victim's injuries constituted serious bodily injury rather than bodily injury. Therefore, the court affirmed the judgment of the District Court. View "USA v. Caraballo" on Justia Law

In this case, the appellant, Steven Voneida, a former convict, appealed to the United States Court of Appeals for the Third Circuit, arguing that his conviction for transmitting threatening communications was no longer criminal due to a change in law. His conviction came after a series of threatening MySpace posts he made in 2007, expressing admiration for the Virginia Tech shooter. He was convicted based on the jury's decision that "a reasonable person would interpret his statement as a true threat."Voneida filed several unsuccessful motions for relief under 28 U.S.C. § 2255. He then filed a petition under 28 U.S.C. § 2241, arguing that the Supreme Court’s decision in Elonis v. United States, 575 U.S. 723 (2015), resulted in a change in law that rendered his conduct no longer criminal.The Third Circuit initially determined that Voneida’s claim could not proceed under § 2241, but this was reversed. On remand, the District Court rejected Voneida’s claim on the merits. During the pendency of Voneida’s appeal, the Supreme Court decided Jones v. Hendrix, 143 S. Ct. 1857 (2023), which established that the limitations on second or successive motions set forth in 28 U.S.C. § 2255(h) do not make § 2255 “inadequate or ineffective” such that a prisoner must pursue a remedy under § 2241.As a result of the holding in Jones, the Third Circuit held that Voneida has no recourse under § 2241. The Court vacated the District Court’s Order and remanded with instructions to dismiss for lack of subject-matter jurisdiction. View "Voneida v. Johnson" on Justia Law

Sherelle Thomas, on behalf of the estate of Terelle Thomas, sued the City of Harrisburg, PrimeCare Medical, Inc., and several individual law enforcement officers (the Officers) alleging that they failed to provide medical care and to intervene in the prevention of a violation of Thomas's right to medical care. The Officers moved to dismiss the case on grounds of qualified immunity, but the United States District Court for the Middle District of Pennsylvania denied the motion. The Officers then appealed the decision.The United States Court of Appeals for the Third Circuit, reviewing the case de novo, affirmed the District Court's denial of qualified immunity regarding the failure to render medical care. The court found that the Officers, based on their observations and knowledge, should have recognized that Thomas had ingested a significant amount of cocaine, presenting a serious medical need. The Officers' decision not to take Thomas to the hospital amounted to deliberate indifference to that need, constituting a violation of Thomas' constitutional right to medical care.However, the Court of Appeals reversed the District Court's recognition of a claim of failure to intervene. The court explained that neither the Supreme Court nor the Third Circuit have recognized a right to intervene in the context of rendering medical care. As such, the Officers were entitled to qualified immunity on this claim.The case was remanded to the District Court with instructions to dismiss the claim regarding the Officers' failure to intervene. View "Thomas v. City of Harrisburg" on Justia Law

The United States Court of Appeals for the Third Circuit reviewed a case involving the estate of Terelle Thomas who died after ingesting a large amount of cocaine while in police custody. The plaintiffs, acting on behalf of the estate, brought a suit against the City of Harrisburg, PrimeCare Medical, and several individual law enforcement officers, alleging that they failed to render medical care and intervene to prevent a violation of the right to medical care. The officers moved to dismiss the case on the grounds of qualified immunity, but the District Court denied the motion.On appeal, the Third Circuit affirmed in part and reversed in part. The court held that the officers were not entitled to qualified immunity for the failure to render medical care claim as the plaintiffs successfully alleged a violation of the constitutional right to medical care. The court found that the officers had a clear indication that Thomas had ingested a significant amount of drugs and thus had a serious medical need, and their decision to book Thomas instead of taking him to a hospital demonstrated deliberate indifference to that need.However, the court reversed on the failure to intervene claim. The court noted that neither the Third Circuit nor the Supreme Court had recognized a right to intervene in the context of rendering medical care. Therefore, the officers were entitled to qualified immunity on the failure to intervene claim. The case was remanded to the District Court with instructions to dismiss the failure to intervene claim. View "Thomas v. City of Harrisburg" on Justia Law

A traffic stop conducted by Pennsylvania State Trooper Galen Clemons resulted in the arrest of Jamar Hunter after a loaded Glock-45 semi-automatic handgun was discovered in Hunter's waistband. This discovery followed a routine license and warrant check and an additional computerized criminal history check on Hunter and his passenger, Deshaun Davis. Hunter was later indicted for possession of a firearm as a convicted felon. Hunter moved to suppress the firearm evidence claiming that the computerized criminal history check extended the traffic stop beyond its constitutional authority.The United States District Court for the Eastern District of Pennsylvania granted Hunter's motion to suppress. The court reasoned that the computerized criminal history check was unrelated to the traffic stop's mission and, without reasonable suspicion, prolonged the stop, therefore violating the Fourth Amendment.The United States Court of Appeals for the Third Circuit reversed the District Court’s decision, finding that the lower court had applied a subjective standard of review, thereby erring as a matter of law. The appellate court held that the criminal history check, which lasted approximately two minutes, was an objectively reasonable safety precaution related to the mission of the traffic stop under Rodriguez v. United States, 575 U.S. 348 (2015) and the Fourth Amendment. The Court of Appeals found the check to be a negligibly burdensome officer safety precaution that fell within the stop's mission. The case was remanded for further proceedings consistent with this opinion. View "USA v. Hunter" on Justia Law

In this case, the plaintiff, Maria Del Rosario Hernandez, filed a lawsuit against MicroBilt Corporation alleging the company violated the Fair Credit Reporting Act after the lender denied her loan application based on inaccurate information provided by a MicroBilt product. MicroBilt moved to compel arbitration based on the terms and conditions that Hernandez agreed to while applying for the loan, which included an arbitration provision. However, Hernandez had already submitted her claims to the American Arbitration Association (AAA) for arbitration.The AAA notified MicroBilt that its agreement with Hernandez was a consumer agreement, which meant the AAA's Consumer Arbitration Rules applied. Applying these rules, the AAA notified MicroBilt that its arbitration provision included a material or substantial deviation from the Consumer Rules and/or Protocol. Specifically, the provision’s limitation on damages conflicted with the Consumer Due Process Protocol, which requires that an arbitrator should be empowered to grant whatever relief would be available in court under law or in equity. After MicroBilt did not waive the damages limitation, the AAA declined to administer the arbitration under Rule 1(d).MicroBilt asked Hernandez to submit her claims to a different arbitrator, but she refused, requesting a hearing before the District Court. She argued that she must now pursue her claims in court because the AAA dismissed the case under Rule 1(d). The District Court reinstated Hernandez’s complaint and granted MicroBilt leave to move to compel arbitration under 9 U.S.C. § 4. However, the District Court denied MicroBilt’s motion to compel, leading to this appeal.The United States Court of Appeals for the Third Circuit affirmed the lower court's decision, stating that Hernandez had fully complied with MicroBilt’s arbitration provision, which allowed her to pursue her claims in court. The court held that it lacked the authority to compel arbitration. The court rejected MicroBilt's arguments that the AAA administrator improperly resolved an arbitrability issue that should have been resolved by an arbitrator, that the provision’s Exclusive Resolution clause conflicted with Hernandez’s return to court, and that the AAA’s application of the Consumer Due Process Protocol was unreasonable. The court concluded that it lacked the authority to review the AAA’s decision or to sever the damages limitation from the arbitration provision. View "Hernandez v. MicroBilt Corp" on Justia Law

The United States Court of Appeals for the Third Circuit reviewed a consolidated action related to the Federal Energy Regulatory Commission's (FERC) acceptance of a tariff filed by PJM Interconnection, L.L.C. (PJM), a Regional Transmission Organization managing a system that serves around fifty million consumers in thirteen mid-Atlantic and Midwestern states and the District of Columbia. The tariff was challenged by PJM Power Providers Group and Electric Power Supply Association, two nonprofit associations representing energy generators, and Pennsylvania Public Utility Commission and Public Utilities Commission of Ohio. The challengers argued that the tariff, which was approved by inaction due to a deadlock among FERC commissioners, was arbitrary and capricious. The court disagreed, ruling that FERC's acceptance of the tariff was not arbitrary or capricious and was supported by substantial evidence. The court also confirmed that it could review FERC's inaction under the Federal Power Act. View "PJM Power Providers Group v. FERC" on Justia Law