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

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

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

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

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

In a case involving the Federal Energy Regulatory Commission (FERC) and a group of petitioners, the petitioners challenged FERC's decision to allow a new auction rule to be applied retroactively. The auction in question, run by PJM Interconnection LLC, determines the selling price for electricity. The petitioners argued that the retroactive application of the new rule violated the filed rate doctrine, which prohibits retroactive rates.The court agreed with the petitioners, granting their petitions and vacating the orders in question. The court found that the new rule was retroactive because it changed the legal consequence of a past action, specifically the calculation and posting of the Locational Deliverability Area (LDA) Reliability Requirement. The LDA Reliability Requirement is a parameter used in the auction to determine the amount of electricity that must be produced to meet peak demand.The court noted that while the new rule allowed PJM to adjust the LDA Reliability Requirement downward to account for certain resources' lack of participation in the auction, the original tariff did not provide for this adjustment. Therefore, the new rule altered the legal consequence of the past action of calculating and posting the LDA Reliability Requirement.The court concluded that the retroactive application of the new rule violated the filed rate doctrine, and therefore FERC's approval of the rule was not in accordance with the law. The court emphasized that the doctrine's goal of predictability is of utmost importance and that FERC and the courts must respect the doctrine to ensure stability in the markets. As a result, only the portion of FERC's orders that allowed the new rule to be applied to the specific 2024/25 capacity auction was vacated. View "PJM Power Providers Group v. FERC" on Justia Law

A dispute arose over Pennsylvania's rule requiring mail-in and absentee voters to date the return envelope carrying their ballot. The Supreme Court of Pennsylvania had ruled this requirement mandatory and declared that undated or incorrectly dated ballots were invalid under state law. The case centered on whether federal law, specifically Section 10101(a)(2)(B) of the Civil Rights Act of 1964, mandated that these non-compliant ballots be counted. This provision prohibits the denial of the right to vote due to an immaterial error or omission on paperwork related to voting.The District Court granted summary judgment for the plaintiffs, declaring that rejecting timely received mail ballots due to missing or incorrect dates violated the federal provision. They reasoned that the date requirement was immaterial, as it played no role in determining a vote's timeliness.However, the appellate court reversed this decision. The court held that the federal provision only applies when the state is determining who may vote, not how a qualified voter must cast their ballot. They found that the provision does not apply to rules, like the date requirement, that govern how a qualified voter must cast their ballot for it to be counted. The court concluded that a contrary approach could not be reconciled with the text and historic backdrop of the statute. Therefore, the court ruled that the federal provision does not override Pennsylvania's date requirement for casting a mail-in ballot. The case was remanded for further consideration of the plaintiffs' pending equal protection claim. View "Pennsylvania State Conference of NAACP Branches v. Northampton County Board of Elections" on Justia Law

The case arose from appellant Khamal Fooks' claim that his attorney misled him about the parole eligibility related to his plea agreement. Fooks had pleaded guilty to third-degree murder, conspiracy, and carrying an unlicensed gun in a Pennsylvania state court. He later alleged that his lawyer incorrectly assured him he would be eligible for parole after ten years, when in reality, he had to serve at least twenty. His allegations, if true, would demonstrate that his lawyer’s advice was ineffective.Both the state and the federal district courts dismissed his claims without providing an opportunity for an evidentiary hearing. Fooks then appealed this decision to the United States Court of Appeals for the Third Circuit. The Circuit Court found that Fooks' allegations, if proven, would indeed establish ineffective assistance of counsel, thereby warranting habeas relief.The Circuit Court held that the district court erred in not affording Fooks an evidentiary hearing to substantiate his allegations. The court emphasized the importance of giving petitioners a fair chance to prove their allegations and remanded the case for an evidentiary hearing. The court did not rule on Fooks' entitlement to relief, instead emphasizing the need for a fair opportunity to present evidence supporting his claims. View "Khamal Fooks v. Superintendent Smithfield SCI" on Justia Law

This case involves a dispute between Jennifer Zuch and the Internal Revenue Service (IRS) over the allocation of estimated tax payments and the subsequent application of those payments to pay off her tax liability. Zuch argued that the IRS erroneously applied $50,000 in estimated tax payments, which she and her then-husband had made, to her ex-husband's tax liability instead of hers. As the dispute was litigated over several years, the IRS withheld tax refunds owed to Zuch and applied them to her alleged unpaid balance, thereby satisfying it in full. The IRS then moved to dismiss the Tax Court proceeding, arguing the case was moot since there was no more tax to be paid. The Tax Court granted the motion.In appeal, the U.S. Court of Appeals for the Third Circuit vacated the Tax Court's dismissal and remanded the matter back to the Tax Court. The appellate court found that Zuch's claim was not moot, even though the IRS had satisfied her tax liability by applying her tax refunds to it. The court held that the IRS cannot unilaterally moot a case by withdrawing its proposed collection action, especially when the Tax Court has already obtained jurisdiction of a liability challenge. The court also found that a taxpayer's challenge to the tax liability at issue in an action under § 6330(c)(2)(B) of the Internal Revenue Code cannot be rendered moot by the unilateral action of the IRS. The court concluded that the Tax Court retained jurisdiction to review Zuch's liability and to determine whether she is entitled to receive credit for any amount of the estimated tax payments at issue. View "Zuch v. Commissioner of Internal Revenue" on Justia Law

In a case before the United States Court of Appeals for the Third Circuit, the plaintiff, Troy Moore, Sr., a prisoner, sued Correctional Officer Saajida Walton under 42 U.S.C. § 1983, alleging that she violated his Eighth Amendment rights. The claim was based on an incident where a toilet in Moore’s prison cell exploded and Walton refused to let him out of his cell to clean up for over eight hours. Moore originally filed the complaint under a misspelled version of Walton’s name. The correct spelling was not provided until after the statute of limitations for his claim had expired. The District Court granted summary judgment to Walton based on the statute of limitations.The Circuit Court held that the District Court misapplied the relation back analysis under Federal Rule of Civil Procedure 15(c)(1)(C) by failing to consider the period for service provided by Federal Rule of Civil Procedure 4(m). It held that Rule 15(c)(1)(C)’s reference to “the period provided by Rule 4(m)” includes any extensions for service granted under Rule 4(m) for good cause. The case was remanded to the District Court to determine whether Walton received notice of the action by a certain date and, if so, whether Moore could demonstrate the absence of prejudice—the final element necessary to satisfy the relation back inquiry. If all these conditions were met, the District Court would then need to consider the merits of Moore’s Eighth Amendment claim. View "Moore v. Walton" on Justia Law

The U.S. Court of Appeals for the Third Circuit ruled on a case involving the Consumer Financial Protection Bureau (CFPB) and a group of trusts associated with the National Collegiate Student Loan Trust. The central questions in the case were whether the trusts were "covered persons" under the Consumer Financial Protection Act (CFPA), and whether the CFPB was required to ratify the underlying action.The CFPB had initiated enforcement proceedings against the trusts for alleged violations related to servicing and collecting student loans, which the trusts had contracted out to third parties. The trusts argued that they were not "covered persons" under the CFPA and that the CFPB's action was untimely because it was initiated when the CFPB director was unconstitutionally insulated from presidential removal and ratified after the statute of limitations had expired.The Third Circuit held that the trusts were indeed "covered persons" under the CFPA because they were engaged in offering or providing a consumer financial product or service. The court also held that the CFPB was not required to ratify the action before the statute of limitations had run, following the Supreme Court's decision in Collins v. Yellen. The court concluded that there was no indication that the unconstitutional limitation on the President's authority to remove the CFPB Director harmed the Trusts, and thus no need for ratification. Therefore, the case was affirmed and remanded to the lower court for further proceedings with these determinations in mind. View "Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trust" on Justia Law