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

The case involves the Central States, Southeast and Southwest Areas Pension Fund (the "Fund") seeking to collect withdrawal liability payments from several companies (the "Related Employers") that were commonly controlled with Borden Dairy Company of Ohio, LLC and Borden Transport Company of Ohio, LLC (the "Borden Ohio entities"). The Borden Ohio entities had previously withdrawn from the Fund and entered into a settlement agreement with the Fund during an arbitration process, which revised their withdrawal liability payments. The Borden Ohio entities later went bankrupt and ceased making payments, prompting the Fund to seek payment from the Related Employers.The United States District Court for the District of Delaware dismissed the Fund's suit under Federal Rule of Civil Procedure 12(b)(6), ruling that the Multiemployer Pension Plan Amendments Act (MPPAA) does not provide a statutory cause of action to enforce a private settlement agreement. The District Court also concluded that the Fund failed to meet the procedural requirements for notice and demand outlined in 29 U.S.C. § 1399(b)(2).The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the settlement agreement is properly understood as a revision to the withdrawal liability assessment under the MPPAA. Since no employer began an arbitration with respect to the revised assessment, the Fund has a cause of action under 29 U.S.C. § 1401(b)(1). The Court also determined that the Fund met the procedural requirements for notice and demand under 29 U.S.C. § 1399(b)(1). Consequently, the Third Circuit reversed the District Court's order dismissing the Fund's suit and remanded the case for further proceedings. View "Central States Southeast & Southwest Areas Pension v. Laguna Dairy S.de R.L. de C.V." on Justia Law

Carolyn Jackson and John Jackson were convicted of severe child abuse after a thirty-nine-day jury trial. They were charged with conspiracy and multiple counts of endangering the welfare of a child. The jury found John guilty on several counts and Carolyn guilty on all counts. The charges included both "omission counts" (withholding food, water, and medical care) and "commission counts" (forcing ingestion of harmful substances and physical assault). The Jacksons' sentences were vacated multiple times on appeal due to improper sentencing by the original judge, leading to a reassignment for resentencing.The United States District Court for the District of New Jersey initially sentenced the Jacksons, but the sentences were vacated and remanded by the United States Court of Appeals for the Third Circuit. The case was reassigned to Judge Susan Wigenton, who imposed new sentences of 140 months for Carolyn and 108 months for John. The Jacksons appealed these new sentences, arguing violations of their Fifth and Sixth Amendment rights, procedural and substantive unreasonableness, and that the new sentences contradicted prior rulings (law of the case).The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the District Court did not violate the Jacksons' constitutional rights by finding facts at sentencing by a preponderance of the evidence, since these findings did not increase the statutory maximum sentence. The court also held that the Jacksons had no reasonable expectation of finality in their sentences while under appeal, so no double jeopardy or due process violation occurred. The court found no procedural errors in the District Court's sentencing process and concluded that the sentences were substantively reasonable. The Third Circuit affirmed the sentences imposed by the District Court. View "U.S. v. Jackson" on Justia Law

John Adams was involved in a case where he picked up two runaway girls, aged 15 and 16, and brought them to his home in Philadelphia. He coerced them into having sex with him and engaging in commercial sex acts, threatening to kick them out if they refused. Adams advertised the minors' sexual services on a European website and collected a portion of the money. He instructed the minors to conceal their ages and delete incriminating text messages. Law enforcement discovered the girls during a traffic stop, and they revealed Adams's actions. Adams attempted to cover up his activities by soliciting another minor to help him blackmail one of the victims.The United States District Court for the Eastern District of Pennsylvania indicted Adams on six counts, including sex trafficking of a minor, tampering with evidence, witness tampering, and making false statements. Adams moved to dismiss the sex trafficking charges, arguing that the Trafficking Victims Protection Act did not apply to his conduct and that Congress lacked the power to enact the statute. The District Court denied his motions, holding that the Act criminalized domestic sex trafficking and was valid under the Commerce Clause. Adams pleaded guilty to all charges but reserved the right to challenge the applicability of the Act.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the Trafficking Victims Protection Act applies to both foreign and domestic sex trafficking and that Adams's conduct fell within the statute's scope. The court also found that Congress had the authority to enact the statute under the Commerce Clause. Additionally, the court upheld the District Court's denial of Adams's motion to withdraw his guilty plea, finding no breach of the plea agreement by the government and rejecting Adams's claim of innocence. The Third Circuit affirmed the District Court's judgment of conviction and sentence. View "U.S. v. Adams" on Justia Law

Jeffrey Herrera filed a pro se complaint alleging that he was detained for several months beyond his maximum release date, which he claimed violated the Eighth Amendment. Herrera was arrested in September 2012, sentenced in March 2013 to 36 to 72 months’ imprisonment, and released on parole in December 2014. After violating parole, his sentence was reduced in January 2017 to 30 to 66 months, with credit for time served. Despite this, Herrera claimed he was detained until October 2019, seven months past his maximum release date of March 2019.The United States District Court for the Middle District of Pennsylvania dismissed Herrera’s complaint under 28 U.S.C. § 1915(e), reasoning that his claim must be brought as a habeas corpus petition under 28 U.S.C. § 2254 and that his claim for damages was barred by Heck v. Humphrey, 512 U.S. 477 (1994). The court also found that any amendment to the complaint would be futile. Herrera’s motions for reconsideration and relief from judgment were denied, with the court maintaining that his claim was barred by Heck and the statute of limitations.The United States Court of Appeals for the Third Circuit reviewed the case and determined that Heck does not apply to Herrera’s overdetention claim because it does not imply that his conviction or sentence were invalid. The court found that Herrera plausibly pleaded an Eighth Amendment overdetention claim, as he alleged that prison officials were aware of his overdetention and failed to act, resulting in his prolonged detention. However, the court noted that the claim might be time-barred under Pennsylvania’s two-year statute of limitations but remanded the case to allow Herrera to amend his complaint to address potential tolling of the statute of limitations. The Third Circuit vacated the District Court’s order and remanded for further proceedings. View "Herrera v. Pennsylvania Board of Probation and Parole" on Justia Law

Richard Hightower, a pretrial detainee, was attacked by his cellmate, Anthony Tyler, in a Philadelphia jail, resulting in Hightower's paralysis. Hightower was classified as a low-security risk, while Tyler was classified as a high-security risk with a history of violent behavior. Due to a mistake by a prison health services company, Tyler was placed in Hightower's intake cell instead of being transferred to a permanent cell. Tyler's aggressive behavior escalated, culminating in a violent attack on Hightower.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the City of Philadelphia and the guards. Hightower did not appeal the judgment for the guard but did appeal the judgment for the city.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Hightower failed to prove that the city caused any constitutional violation. To succeed in his Monell claim, Hightower needed to show that the city had an unconstitutional policy or custom or was deliberately indifferent to inmates' rights. The court found that the city had no policy of not separating inmates by security-risk level during intake and that the lack of a policy is not a policy. Additionally, Hightower could not show a custom that violated his rights or that the city acted with deliberate indifference. The court concluded that the risk to Hightower was not so obvious that the city could be held liable without a pattern of similar violations.The Third Circuit affirmed the District Court's summary judgment in favor of the City of Philadelphia. View "Hightower v. City of Philadelphia" on Justia Law

Promise Healthcare Group, LLC and its affiliates operated various hospital and nursing facilities. During their Chapter 11 bankruptcy proceedings, Patrick Wassmann filed a $10 million medical malpractice claim based on treatment he received at one of the facilities between March 15 and June 9, 2017. Robert Michaelson, the liquidating trustee, objected to Wassmann’s claim, arguing it was time-barred because it became untimely by the time the Trustee objected to it and it was evaluated. The Trustee also argued that Wassmann’s claim should be barred because he failed to file a timely state court complaint in addition to his Chapter 11 proof of claim.The United States Bankruptcy Court for the District of Delaware set a bar date of May 31, 2019, for filing proof of claims. Wassmann filed his proof of claim on January 4, 2019. The court confirmed the Debtors’ reorganization plan on September 17, 2020, which went into effect on October 1, 2020. Wassmann had until November 1, 2020, to proceed against the Debtors in state court but chose to seek recovery in the Bankruptcy Court alone. The Bankruptcy Court denied the Trustee’s motion for summary judgment, reasoning that the claims allowance process under 11 U.S.C. § 502 evaluates claims as of the petition date and that a timely proof of claim does not require a separate timely non-bankruptcy complaint.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the Bankruptcy Court’s order. The Third Circuit held that the enforceability of a claim under 11 U.S.C. § 502(b) is determined as of the petition date, not the date of the court’s evaluation. The court also held that a creditor who has filed a timely proof of claim is not required to file a separate, timely non-bankruptcy action to preserve the claim. The court concluded that the Bankruptcy Court correctly allowed Wassmann’s claim as it was timely as of the petition date. View "In re: Promise Healthcare Group LLC" on Justia Law

A New York wine retailer, Jean Paul Weg LLC, and its owner, Lars Neubohn, challenged New Jersey's regulations that require wine retailers to have a physical presence in the state and to purchase their products from New Jersey licensed wholesalers. These regulations prevent the retailer from directly shipping wine to New Jersey customers. The plaintiffs argued that these requirements violate the Commerce Clause by discriminating against out-of-state economic interests.The United States District Court for the District of New Jersey denied the plaintiffs' motion for summary judgment and granted summary judgment in favor of the defendants, including the Director of the New Jersey Division of Alcoholic Beverage Control and the Attorney General of New Jersey. The District Court found that New Jersey's regulations were justified by legitimate local purposes, such as ensuring alcohol sold to New Jersey consumers passes through the state's three-tier system and facilitating inspections to ensure compliance with regulations.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit held that New Jersey's regulations, while discriminatory in effect, were justified on legitimate nonprotectionist grounds. The court found that the physical presence requirement facilitates inspections and investigations, while the wholesaler purchase requirement helps quickly identify sources of contamination and facilitates product recalls. Additionally, the court determined that these regulations are essential features of New Jersey's three-tier system of alcohol regulation, which is "unquestionably legitimate" under the Twenty-first Amendment. Therefore, the challenged regulations were upheld as constitutional. View "Jean-Paul Weg LLC v. Director of the New Jersey Division of Alcoholic Beverage Control" on Justia Law

Rodney Ashe was pulled over by police on October 3, 2022, for failing to maintain his lane. During the stop, officers observed a handgun in his sweatshirt pocket, leading to his arrest and the impoundment of his car. Six months later, while Ashe was incarcerated, a duffle bag containing an AK-style pistol and ammunition was found in the trunk of his car by a towing company employee. Ashe pleaded guilty to being a felon in possession of a firearm related to the handgun found during the traffic stop.The United States District Court for the District of New Jersey held a sentencing hearing on December 21, 2023. Both the Government and the defense argued for a total offense level of 12, but the District Court found a total offense level of 17, applying an enhancement for possession of the AK-style pistol. The court determined that a preponderance of the evidence supported Ashe’s constructive possession of the AK pistol, based on its location in his trunk and his history of firearm-related offenses. Ashe was sentenced to 37 months of imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that the District Court erred in applying the enhancement without sufficient evidence that Ashe possessed the AK pistol. The appellate court noted that the six-month gap between Ashe’s arrest and the discovery of the firearm, combined with the lack of direct evidence linking Ashe to the AK pistol, did not meet the preponderance of the evidence standard required for constructive possession. Consequently, the Third Circuit vacated Ashe’s sentence and remanded the case for resentencing without the enhanced base offense level. View "USA v. Ashe" on Justia Law

In the early morning of December 15, 1987, Richard Laird and Frank Chester brutally murdered Anthony Milano in a wooded area in Bristol, Pennsylvania. Milano, a 26-year-old homosexual man, was beaten and had his neck and throat slashed multiple times, leading to his death. Laird and Chester were arrested and tried for first-degree murder, among other charges. Both were convicted and sentenced to death. Laird's defense included claims of ineffective assistance of counsel, particularly regarding the failure to present expert testimony on the sexual abuse he suffered as a child.Laird's initial conviction and death sentence were affirmed by the Pennsylvania Supreme Court in 1991. He sought post-conviction relief, which was denied by the PCRA Court and affirmed by the Pennsylvania Supreme Court in 1999. Laird then filed a federal habeas petition, which resulted in the vacating of his first-degree murder conviction and death sentence in 2001. The case was remanded for a retrial, and in 2007, Laird was again convicted of first-degree murder and sentenced to death. The Pennsylvania Supreme Court affirmed this conviction and sentence in 2010.Laird filed another PCRA petition, claiming ineffective assistance of counsel for failing to present an expert on childhood sexual abuse. The PCRA Court denied relief, and the Pennsylvania Supreme Court affirmed, finding that the additional expert testimony would have been cumulative and not likely to change the outcome. Laird then filed a federal habeas petition, which was denied by the District Court.The United States Court of Appeals for the Third Circuit reviewed the case, focusing on whether counsel was ineffective for not presenting an additional expert on childhood sexual abuse. The court held that the PCRA Court's decision was reasonable and that counsel's performance did not fall below an objective standard of reasonableness. The court affirmed the District Court's denial of the habeas petition. View "Laird v. Secretary of Dept. of Corrections" on Justia Law

Joseph Cammarata and his associates, Eric Cohen and David Punturieri, created Alpha Plus Recovery, LLC, a claims aggregator that submitted fraudulent claims to securities class action settlement funds. They falsely represented that three entities, Nimello, Quartis, and Invergasa, had traded in securities involved in class action settlements, obtaining over $40 million. The fraudulent claims included falsified trade data and fabricated reports. The scheme unraveled when a claims administrator, KCC, discovered the fraud, leading to the rejection of the claims and subsequent legal action.The United States District Court for the Eastern District of Pennsylvania charged the defendants with conspiracy to commit mail and wire fraud, wire fraud, conspiracy to commit money laundering, and money laundering. Cohen and Punturieri pled guilty, while Cammarata proceeded to trial and was found guilty on all counts. The District Court sentenced Cammarata to 120 months in prison, ordered restitution, and forfeiture of certain property.The United States Court of Appeals for the Third Circuit reviewed the case. The court upheld most of the District Court's rulings but found issues with the restitution order and the forfeiture of Cammarata's vacation home. The court held that the restitution order did not fully compensate the victims, as required by the Mandatory Victims Restitution Act (MVRA), and remanded for reconsideration. The court also found procedural error in the forfeiture process, as Cammarata was deprived of his right to a jury determination on the forfeitability of his property. The court vacated the forfeiture order in part and remanded for the Government to amend the order to reflect that the property is forfeitable as a substitute asset under 21 U.S.C. § 853(p). View "USA v. Cammarata" on Justia Law