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

Davis, a non-citizen, and Beckford, a U.S. citizen, met when they were children. In 1993, Davis was sentenced to life in prison for nonviolent drug convictions. When his sentence was reduced to 30 years in 2008, the two decided to marry. viewing marriage as an expression of their Christian faith. In 2012, Davis was moved to Moshannon Valley, a private prison that houses low-security alien inmates. The prison’s written policy for allowing marriage had certain behavioral requirements; the prison psychologist and other officials had to approve the request. Davis unsuccessfully challenged the denial of his marriage request through the prison’s administrative process. The Administrator of the Bureau of Prisons Privatization Management Branch informed Davis that marriage requests remained exclusively within the province of Moshannon officials. Davis learned that Moshannon had not approved a single request to marry during its contractual relationship. Davis’s sentence was later reduced to 27 years. He was deported after his release. Although their marriage would not have allowed Davis to challenge his deportation, Davis alleges that marriage to a U.S. citizen could provide a basis for other inmates to challenge their removals. Davis alleged that federal officials directed Moshannon officials to deny all inmate marriage requests to ensure that marriage to a citizen would not interfere with deportations. The district court dismissed claims under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-1, under 42 U.S.C. 1985; and for intentional infliction of emotional distress. The Third Circuit vacated in part. Davis stated a RFRA claim. View "Davis v. Wigen" on Justia Law

Local 537 scheduled a vote to disaffiliate from UWUA and formed a new union, Independent 537. UWUA learned of the impending vote and declared an emergency trusteeship over Local 537. Ninety percent of Local 537 members who cast ballots voted to disaffiliate and to make Independent their new bargaining representative. UWUA President Langford sent notices of the trusteeship to Local 537’s officers and members, stating that all money, books, and property of the Local must be handed over and that all Local Officers were removed. They did not comply. UWUA sought an injunction. The removed officers entered into a consent order and delivered Local 537’s assets.The NLRB conducted elections and certified Independent 537 as the new bargaining representative. UWUA withdrew its lawsuit, formally lifted the trusteeship, revoked Local 537’s charter, then invoked a section in its constitution permitting forfeiture of assets upon revocation of a local union’s charter and took possession of Local 537’s books, money, and property.Independent 537 sued under the Labor Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 401, and the Labor Management Relations Act (LMRA), 29 U.S.C. 141. The Third Circuit affirmed orders granting Independent 537 equitable distribution of Local 537’s assets but denying attorneys’ fees. UWUA breached the fiduciary duty it owed to former Local 537 members under LMRDA section 501, rendering the forfeiture provision unenforceable. Neither the UWUA constitution nor any statute authorizes an award of attorneys’ fees for its breach. View "Utility Workers United Association Local 537 v. Utility Workers Union of America AFL-CIO" on Justia Law

This consolidated case concerns three appeals from orders entered by magistrate judges in the Western District of Pennsylvania in cases filed under 42 U.S.C. 1983. One case was involuntarily dismissed without prejudice for failure to prosecute; in the others, magistrates entered summary judgment for all defendants.Under 28 U.S.C. 636, precise limits govern a magistrate judge’s jurisdiction absent parties’ consent. A magistrate judge can oversee pretrial discovery even without the consent of the parties, but he cannot grant summary judgment or involuntarily dismiss a case; those limits dissolve if the parties voluntarily consent to a magistrate judge’s final judgment jurisdiction.The Third Circuit dismissed one appeal for lack of jurisdiction because all parties did not consent and, therefore, the magistrate judge lacked the power to involuntarily dismiss the case. However, the magistrate judges were empowered to enter summary judgment in the other cases because all parties either expressly or impliedly consented. The court then affirmed summary judgment based on the plaintiffs’ failure to exhaust administrative remedies. View "Prater v. Pennsylvania Department of Corrections" on Justia Law

Shaknitz pleaded guilty to three counts of distribution and attempted distribution of child pornography, 18 U.S.C. 2252(a), and one count of possession of child pornography. Shaknitz was sentenced to a 170-month term of imprisonment and a five-year term of supervised release. During sentencing, the district court orally imposed a condition on Shaknitz’s incarceration, limiting his contact with his five-year-old son to telephone only. In its written judgment, the court did not include its previously-announced condition but recommended that the Bureau of Prisons (BOP) impose the telephone-only condition. The judgment did not state that the recommendation superseded the oral pronouncement.The Third Circuit vacated, noting its prior holding that a sentencing court lacks “inherent authority to impose a no-contact order during [a defendant’s] incarceration term.” It is unclear whether the written judgment was intended to replace the mandate with a recommendation; sentencing courts have the authority to recommend to the BOP that defendants’ contact with others be limited where necessary and appropriate. View "United States v. Shaknitz" on Justia Law

Kramer’s then-wife, Terry, found a document on her husband’s computer that led her to believe that Kramer had engaged in sexual conduct with a minor. Later, Terry found photographs on Kramer’s cellphone depicting the victim engaged in sexual acts. Terry met with police, described the sexually explicit photographs, and showed them the document; she emailed the photographs to the police. The victim reported that Kramer had sexually abused her for years and had used his cellphone to take pictures of her engaged in sexual conduct. Kramer admitted to having a sexual relationship with the victim and to taking the photographs. With a warrant, law enforcement searched Kramer’s cellphone and eventually found videos and photographs depicting sexual acts involving the victim.Kramer was charged with sexual exploitation of children, 18 U.S.C. 2251(a). While in custody, he sent Terry a letter: “You crossed [the] line and it IS going to cost you,” repeatedly stating that he would have Terry arrested for her purported crimes. Kramer was then charged with attempted witness tampering, 18 U.S.C. 1512(b)(1). The Third Circuit affirmed Kramer’s convictions and 350-month sentence, upholding the denial of Kramer’s motion to suppress evidence. Terry conducted a private search of his cellphone and voluntarily provided the evidence to the government; the evidence was admissible without implicating the Fourth Amendment. The court properly denied Kramer’s motion to dismiss the attempted witness tampering charge. View "United States v. Kramer" on Justia Law

Following the armed robbery of a Winston-Salem, North Carolina convenience store, officers obtained a warrant for Stanford’s arrest and contacted Wilmington Detective Cannon for help apprehending Stanford, whom they believed had fled to Delaware. Cannon obtained a search warrant authorizing the use of a cell-site simulator to locate Stanford’s cell phone. Cannon alleged that Stanford was originally from Wilmington and had family members and associates who could assist him. Officers learned that Stanford was at a Wilmington Residence. While conducting surveillance, police approached a woman who exited the Residence and asked whether Stanford was there. She said Stanford and Gibson—Stanford’s brother, wanted on other charges—were inside. Officers knocked, announced, and entered the unlocked door. Stanford and Gibson were arrested. Cannon obtained a warrant to search the Residence for evidence of the North Carolina robbery. The Affidavit contained possible inaccuracies about the other suspects and Stanford's stay at the Residence. The subsequent search of the Residence yielded a loaded handgun beneath a cushion on the couch where Stanford was laying when he was arrested.Stanford was charged with illegal firearm possession 18 U.S.C. 922(g)(1), 924(a)(2). The Third Circuit affirmed the denial of his motion to suppress, based on the good faith exception to the exclusionary rule, and his sentence. Delaware first- and second-degree robbery are U.S.S.G crimes of violence. View "United States v. Stanford" on Justia Law

For many years, Zurn, a manufacturer of plumbing products and accessories, has faced multiple lawsuits in which claimants allege bodily injury or wrongful death caused by asbestos in its products. To cover litigation costs, Zurn used various insurance policies issued by various insurance companies. Eventually, Zurn was told by its primary and umbrella insurers that Zurn had exhausted the limits of liability under those policies. When Zurn’s excess policy insurers refused to pay, Zurn sought a declaratory judgment that it had exhausted the limits of liability under its primary and umbrella policies and that Zurn’s excess policy insurers had a duty to defend and pay defense costs in the underlying asbestos suits. After discovery, the district court interpreted the meaning of various primary, umbrella, and excess policies, and determined the scope of some duties insurers have under them.One excess policy insurer—American Home—appealed several partial summary judgment orders. The Third Circuit dismissed the appeal for lack of jurisdiction. American Home does not challenge orders that are functionally equivalent to an injunction, No part of the declaration-granting orders compels American Home “to undertake the defense” of Zurn. View "Zurn Industries Inc v. Allstate Insurance Co" on Justia Law

Mylan regularly submitted abbreviated new drug applications (ANDAs) to the FDA, often including Paragraph IV certifications stating that the proposed generic drug at issue would not infringe valid patents. Mylan incurred tens of millions of dollars in legal fees defending itself in about 120 patent infringement suits, 35 U.S.C. 271(e)(2). Mylan incurred additional, much lower legal fees in preparing the notice letters associated with the Paragraph IV certifications. Mylan's fees were $46,158,403, $38,211,911, and $38,618,993 during 2012, 2013, and 2014, respectively, for preparing notice letters and litigating the ANDA suits. In tax filings, Mylan deducted those amounts in the years incurred. The IRS responded that Mylan could not deduct the nearly $130 million of legal expenses incurred from 2012-2014 and that its additional tax liability was about $50 million.The Tax Court considered expert testimony regarding internal FDA processes and the typical course of dealing between an ANDA applicant and the FDA during the submission process for an ANDA with a paragraph IV certification and held that the legal expenses Mylan incurred to prepare notice letters were required to be capitalized because they were necessary to obtain FDA approval of its generic drugs. The Third Circuit affirmed its holding that the legal expenses incurred to defend patent infringement suits were deductible as ordinary and necessary business expenses because the patent litigation was distinct from the FDA approval process. View "Mylan Inc v. Commissioner of Internal Revenue" on Justia Law

The Center for Biological Diversity challenged the Environmental Protection Agency’s approval of certain air pollution control technology for use at various Pennsylvania industrial facilities. The Center argues that the EPA violated the Clean Air Act, 42 U.S.C. 7401, by focusing exclusively on emissions from those facilities instead of examining their impact on air quality more generally and that, even if the EPA is permitted to base its approvals on an emissions-only analysis, it incorrectly concluded that emissions would not be increased by Pennsylvania’s pollution control technologies at issue.The Third Circuit denied petitions for review, interpreting the relevant statutory provisions to permit the EPA’s chosen emissions-based approach. The court reasoned that emissions were the sole air quality variable implicated by Pennsylvania’s revisions of its state implementation plan under the Act; it was therefore not arbitrary for the EPA to use an emissions-based analysis. It was not arbitrary for the EPA to use prior permitting standards, instead of presumptive Reasonably Available Control Technology (RACT), as the emissions baseline for its comparative emissions analysis. The Center’s alternative challenges were procedurally and substantively deficient. View "Center for Biological Diversity v. United States Environmental Protection Agency" on Justia Law

The owner and CEO of Southern Pines (Pat) recruited Kairys as Vice President of Sales to grow the company’s cryogenic trucking services. Soon after he started the job, Kairys required hip replacement surgery. Kairys had surgery and missed seven days of work. Southern was self-insured. Kairys’s surgery caused its health insurance costs to rise markedly. According to Kairys, after he returned to work, Pat’s brother (the VP) told him to “lay low” because Pat was upset. Four months later, Pat fired Kairys, claiming that Southern had “maxed out” its sales potential in cryogenic trucking. Weeks later, Souther hired a part-time worker in a hybrid role that included work that had been done by Kairys.Kairys sued, alleging discrimination and retaliation, citing the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, and state laws. A jury rejected Kairys’s ADA and ADEA claims and returned an advisory verdict for Southern on the ERISA claim.The district court independently considered the ERISA claim and found that Kairys had proved retaliation for using ERISA-protected benefits and interfered with his right to future benefits. The court awarded Kairys $67,500 in front pay and $111, 981.79 in attorney fees. The Third Circuit affirmed. The judgment for Kairys on the ERISA claim was not inconsistent with the jury’s verdict on the other claims and was supported by sufficient evidence. View "Kairys v. Southern Pines Trucking, Inc" on Justia Law