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

StoneMor, Inc. operates cemeteries and funeral homes, with maintenance workers at two cemeteries unionized under the International Brotherhood of Teamsters, Local 469. The Union and StoneMor negotiated a collective bargaining agreement (the "Agreement"), which was ratified on October 5, 2020. The Agreement included a grievance procedure requiring the Union to file grievances within ten days of a dispute. After ratification, StoneMor sent drafts of the Agreement with a clarified wage provision, which the Union contested. The Union did not file a grievance until January 5, 2021, after the Agreement was executed on December 29, 2020.The United States District Court for the District of New Jersey reviewed the case and vacated the arbitrator's award. The District Court held that the Agreement was enforceable upon ratification on October 5, 2020, and that the grievance provision was triggered by October 30, 2020, when paychecks were issued without the salary increase. The court found that the arbitrator's decision, which allowed the Union to wait until January to file a grievance, was contrary to the Agreement's plain meaning.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 arbitrator exceeded her powers by disregarding the Agreement's clear terms, which made the Agreement binding upon ratification. The court emphasized that the grievance procedure was mandatory from the ratification date, and the arbitrator's decision to allow a delay in filing the grievance was not supported by the Agreement. The court concluded that the arbitration award reflected a manifest disregard of the Agreement and was correctly vacated. View "Stonemor Inc v. International Brotherhood of Teamsters Local 469" on Justia Law

The case involves the United States government's appeal against the District Court's dismissal of one of two counts in an indictment against Reginald Hopkins. Hopkins was initially arrested on state firearms charges, and while awaiting his state preliminary hearing, a federal grand jury indicted him on charges of distributing cocaine base and being a felon in possession of firearms and ammunition. The state charges were subsequently withdrawn. Hopkins moved to dismiss the federal indictment, invoking a so-called "ruse exception" to the Speedy Trial Act (STA), arguing that his rights under the Act had been violated because he had been federally indicted over four months after his arrest by state authorities and because he had not been brought to trial within 70 days of that state arrest.The District Court held two evidentiary hearings and eventually dismissed one count of the indictment, the felon-in-possession charge, based on the ruse exception. The government appealed this decision, arguing that the STA contains no such ruse exception.The United States Court of Appeals for the Third Circuit agreed with the government, concluding that a ruse exception premised on a state arrest is inconsistent with the text of the STA and that there are sound policy reasons for declining to adopt a ruse exception. The Court reversed the order of the District Court and reinstated the dismissed count of the indictment. View "United States v. Hopkins" on Justia Law

The case involves Robert Haggerty, a first-time offender who was indicted on three counts of receiving a visual depiction of a minor engaging in sexually explicit conduct, as well as one count of possessing such depictions. Haggerty admitted to communicating with undercover detectives posing as underage girls using online messaging platforms. A search of Haggerty's house and truck yielded two tablets containing a total of 97 still images and 9 videos of child sexual abuse material.The District Court applied multiple Guideline enhancements at sentencing, including a five-level enhancement under U.S.S.G. § 2G2.2(b)(7), which provides for a graduated enhancement scheme based on the number of "images" involved in a child-exploitation offense. Haggerty objected to the application of a five-level, number-of-images enhancement, arguing that the Guideline is unambiguous and does not include videos. The District Court overruled Haggerty’s objection and applied the five-level enhancement, calculating a total offense level of 32, which yielded an advisory Guideline range of 121 to 151 months in prison.The United States Court of Appeals for the Third Circuit held that "image," in the moving picture or video context, unambiguously means "frame." Deference to the Commentary’s 75-images rule is therefore unwarranted. Instead, the number of frames comprising a moving picture or video will determine the specific sentencing enhancement that a District Judge must apply. The court vacated the District Court’s sentencing order and remanded for resentencing in a manner consistent with its holding. View "United States v. Haggerty" on Justia Law

The Securities and Exchange Commission (SEC) brought a civil enforcement action against Dale Chappell and his investment entities for insider trading. The SEC alleged that Chappell traded securities based on material, nonpublic information about the FDA's feedback on a drug developed by Humanigen, a company in which Chappell's entities were the largest shareholders. The FDA had expressed significant concerns about the drug's clinical trial and recommended an additional trial. Despite this, Humanigen submitted an application for Emergency Use Authorization (EUA) without conducting a second trial. Chappell sold a significant portion of his Humanigen stock before the FDA's denial of the EUA application was publicly announced, avoiding substantial losses.In the District Court, the SEC sought and obtained a preliminary injunction to freeze Chappell’s assets. Chappell appealed this decision to the United States Court of Appeals for the Third Circuit.The Third Circuit affirmed the District Court's decision. It found that the SEC had shown a likelihood of success on its claim that Chappell violated insider trading laws. The court concluded that the FDA's feedback was material and that Chappell had the necessary mindset to commit fraud. The court also found that the preliminary injunction factors, including irreparable harm, balance of equities, and public interest, supported the injunction. The court noted that without the injunction, there was a substantial potential injury to Humanigen shareholders if Chappell was able to move assets out of reach of future judgment creditors. View "Securities and Exchange Commission v. Chappell" on Justia Law

The case involves Transcontinental Gas Pipe Line Company, LLC (Transco), a natural gas company that sought to abandon and expand its pipeline facilities in Pennsylvania and New Jersey. To do so, Transco needed a Certificate of Public Convenience and Necessity from the Federal Energy Regulatory Commission (FERC), which it obtained. However, the certificate was subject to conditions, including that Transco receive three additional permits from the Pennsylvania Department of Environmental Protection (PADEP). After receiving these permits, Transco began its pipeline project. However, three environmental advocates filed an administrative appeal with the Environmental Hearing Board (EHB) challenging PADEP's issuance of the permits. In response, Transco initiated a lawsuit in the District Court seeking to enjoin the administrative appeal, arguing that the Natural Gas Act preempts the state law allowing the appeal.The District Court rejected Transco's preemption arguments and denied its motion for a preliminary injunction. Transco appealed this decision to the United States Court of Appeals for the Third Circuit. The Court of Appeals affirmed the District Court's decision, finding that none of the theories of preemption advanced by Transco or the state agency applied in this case. The Court held that the Natural Gas Act does not expressly preempt administrative appeals to the EHB, nor does it field preempt such appeals. The Court also found that the possibility of multiple challenges in different fora to PADEP permitting decisions under the Clean Water Act for interstate natural gas pipelines does not impose an obstacle to the purposes of the Natural Gas Act. Therefore, the Court concluded that Transco's motion for a preliminary injunction was correctly denied. View "Transcontinental Gas Pipe Line Co LLC v. Pennsylvania Environmental Hearing Board" on Justia Law

Samantha Peifer, an employee of the Pennsylvania Board of Probation and Parole, filed a lawsuit against her employer alleging pregnancy discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Pregnancy Discrimination Act. Peifer, who was diagnosed with multiple sclerosis and later became pregnant, requested accommodations from her employer due to her inability to perform certain tasks. Her requests were initially denied, but later granted after she filed a charge with the Equal Employment Opportunity Commission (EEOC). However, she was not allowed to work from home as requested due to her high-risk pregnancy and exposure to COVID-19. Peifer eventually resigned, citing discriminatory treatment, and filed additional charges with the EEOC.The United States District Court for the Eastern District of Pennsylvania granted the Board's motion for summary judgment, concluding that Peifer could not establish a prima facie case for any of her claims. Peifer appealed this decision.The United States Court of Appeals for the Third Circuit affirmed in part and vacated in part the District Court's decision. The Court of Appeals agreed with the lower court that Peifer's claims partly failed but concluded that the District Court was best situated to analyze the impact of the Supreme Court’s recent holding in Muldrow v. City of St. Louis on whether Peifer makes out a prima facie case under an adverse employment action theory. The Court of Appeals also concluded that Peifer makes out a prima facie case of pregnancy discrimination based on the Board’s denials of her light-duty requests under a failure to accommodate theory. The case was remanded for further analysis on Peifer’s adverse employment theory and failure to accommodate theory, while the District Court’s decisions on Peifer’s constructive discharge allegation and retaliation claim were affirmed. View "Peifer v. Pennsylvania Board of Probation and Parole" on Justia Law

In September 2017, Luis Davis, Joel Rivera, and Chriss Cepeda broke into the home of Stephen O’Dea and Kathryn Duncan on the island of Saint Croix. The intruders physically assaulted the couple, threatened them with a gun, and stole their money and vehicle. Davis was later indicted on twelve counts, including brandishing a firearm during a violent crime, carjacking, and being a felon in possession of a firearm. Davis pleaded guilty to these three counts in exchange for the Government dismissing the remaining counts and recommending a sentence at the low end of the Sentencing Guidelines range (87 to 108 months).The District Court determined the applicable Guidelines sentence for brandishing a firearm was the statutory minimum of 84 months’ imprisonment and the Guidelines range for the carjacking and felon-in-possession counts was 87 to 108 months’ imprisonment. At sentencing, Davis’s counsel presented mitigating evidence regarding his client’s abusive childhood, intellectual disabilities, drug addiction, and the negative influence of his adopted brother. The Government, however, emphasized the heinous nature of Davis’s crimes and the harm suffered by the victims. Davis’s counsel objected, claiming that the Government’s position sounded like a breach of the plea agreement. The District Court sentenced Davis to 102 months’ imprisonment on the carjacking and felon-in-possession counts, in addition to the statutory minimum of 84 months’ imprisonment for brandishing a firearm. Davis appealed.The United States Court of Appeals for the Third Circuit agreed with Davis that the Government breached the plea agreement. The court found that the Government's emphasis on the heinous nature of Davis's crimes and the harm suffered by the victims effectively advocated for a sentence higher than the one it promised to recommend. The court vacated the sentence and remanded the case for resentencing. View "USA v. Davis" on Justia Law

Between 2012 and 2015, Anthony D’Ambrosio and Armando Delgado were involved in a sex trafficking ring that operated across several states. They were responsible for transporting victims, collecting money, providing security, and supplying drugs to the victims. In 2015, a federal grand jury indicted them, and in 2017, a jury convicted them of several crimes, including sex trafficking of children and transportation of an individual to engage in prostitution. As part of their sentences, the District Court required them to comply with the Sex Offender Registration and Notification Act (SORNA) as a condition of their supervised release.Delgado objected to the SORNA registration requirement at his sentencing, arguing that his offenses did not require SORNA registration. The District Court acknowledged that it was unclear whether the SORNA requirement applied to Delgado’s offenses and delegated the determination to the Probation office. Delgado appealed this decision, but the Court of Appeals affirmed the District Court's decision, stating that the District Court did not impose any SORNA requirement. However, following his direct appeal, Probation required Delgado to register under SORNA. Delgado challenged this condition, but the District Court denied his motion, stating that it lacked jurisdiction to consider his legal challenge.D’Ambrosio, on the other hand, did not object to the SORNA registration requirement at his sentencing. The District Court required D’Ambrosio to comply with SORNA as a condition of his supervised release. D’Ambrosio first challenged the SORNA requirement in a motion to modify, which the District Court also denied on the grounds of lacking jurisdiction.The United States Court of Appeals for the Third Circuit reversed the District Court's decisions. The Court of Appeals held that the District Court erred in delegating its responsibility to determine the applicability of SORNA to the Probation office and in concluding that it lacked jurisdiction to consider the defendants' motions to modify the conditions of their supervised release. The case was remanded for further proceedings. View "United States v. D’Ambrosio" on Justia Law

The case revolves around a disabled child, Abigail P., who filed a due process complaint against the Old Forge School District under the Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act, and Pennsylvania state law. Abigail, who suffers from severe disabilities, claimed that the school district denied her a free appropriate public education (FAPE) when it moved to remote instruction during the COVID-19 pandemic.The case was first heard by a hearing officer appointed by the Pennsylvania Department of Education, who disagreed with Abigail's claim. The United States District Court for the Middle District of Pennsylvania also disagreed and affirmed the hearing officer's decision.The case was then brought before the United States Court of Appeals for the Third Circuit. The court was tasked with deciding whether Abigail received a FAPE during the COVID-19 pandemic. The court affirmed the lower courts' decisions, stating that the school district did not deny Abigail a FAPE. The court concluded that the school district provided an educational program reasonably calculated to confer meaningful educational benefits in light of Abigail's individual circumstances, even during the period of remote instruction. The court also clarified that its opinion does not give school districts carte blanche to reduce a disabled student’s school day for any reason or no reason at all. View "Abigail P. v. Old Forge School District" on Justia Law

The case involves Smith & Wesson Brands, Inc., Smith & Wesson Sales Company, and Smith & Wesson Inc. (collectively, “Smith & Wesson”) and the Attorney General of the State of New Jersey and the New Jersey Division of Consumer Affairs. The New Jersey Attorney General issued a subpoena to Smith & Wesson under the New Jersey Consumer Fraud Act, seeking documents related to the company's advertising practices. Smith & Wesson filed a federal lawsuit to enjoin enforcement of the subpoena, alleging it violated various constitutional provisions. The New Jersey Attorney General then filed a subpoena enforcement action in state court. The state court rejected Smith & Wesson’s objections and ordered the company to comply with the subpoena.The state court proceedings concluded before the federal case, with the state court ordering Smith & Wesson to comply with the subpoena. The federal court then dismissed Smith & Wesson’s civil rights action on claim preclusion grounds, giving preclusive effect to the state court’s order. The state appellate court later affirmed the state court judgment. Smith & Wesson appealed to the United States Court of Appeals for the Third Circuit, arguing that the District Court should not have given preclusive effect to the state court order.The United States Court of Appeals for the Third Circuit affirmed the District Court’s order. The court found that all elements of New Jersey’s claim preclusion test were satisfied. The court also rejected Smith & Wesson’s argument that it had reserved its right to litigate in federal court, finding that such reservation was unavailable in this case. The court emphasized that litigants get one opportunity to make their arguments, not two, and they cannot file a federal lawsuit to hedge against a potentially unfavorable state ruling. View "Smith & Wesson Brands Inc. v. Attorney General of the State of New Jersey" on Justia Law