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

In this case before the United States Court of Appeals for the Third Circuit, a US citizen, Abdoulai Bah, had his life savings of $71,613 seized by the U.S. Customs and Border Protection (CBP) under suspicion of being the proceeds of illegal activities. The CBP returned the money with interest two-and-a-half years later. Bah then sued the United States under the Federal Tort Claims Act (FTCA), seeking damages for personal injury and property damage, arguing that the seizure of his money prevented him from conducting business, caused him to lose his livelihood, and resulted in health problems.The District Court dismissed Bah's case, asserting that the United States was immune from Bah's claims. The court held that the FTCA did not permit Bah's claims as they were seeking prejudgment interest— a type of relief for which the United States has not waived sovereign immunity.Upon appeal, the United States Court of Appeals for the Third Circuit upheld the District Court's decision. The appellate court held that the Detention Exception of the FTCA, under which Bah's claim was filed, only waives sovereign immunity for "injury or loss of goods, merchandise, or other property while in the possession of any officer of customs or excise or any other law enforcement officer," but it does not waive immunity for personal "injury" or "loss" incurred due to the government's seizure of property. As such, the court concluded that Bah's cash was not injured or lost in the sense meant by the FTCA, and his personal injuries were not covered under the Act. Furthermore, the court determined that Bah's claim of "loss" was really a claim for "loss of use" of his cash, which is not covered under the FTCA. Thus, the court affirmed the dismissal of Bah's case. View "Bah v. USA" on Justia Law

This case involves Bradley Barlow, Frances Biddiscombe, and others who were members of either the Service Employees International Union (SEIU) Local 668 or the American Federation of State, County, and Municipal Employees (AFSCME), Council 13. They all signed union membership agreements authorizing the deduction of membership dues from their paychecks. The authorizations were irrevocable, regardless of union membership status, unless they provided written notice of revocation within a specified annual window. After resigning from their respective unions, their membership dues continued to be deducted until the next annual revocation window. They sued, claiming that the continued collection of dues after their resignations constitutes compelled speech, violating their First Amendment rights. They relied on the Supreme Court’s decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, which held that public-sector unions charging fees to nonmembers is a form of coerced speech that violates the First Amendment. However, the United States Court of Appeals for the Third Circuit affirmed the District Court's dismissal of their complaints, holding that Janus was focused on nonmembers who never elected to join a union, not members who voluntarily join a union and later resign. The court also rejected their due process claims for failure to provide procedures for notice and the ability to object to how their dues were spent, as these procedures were based on avoiding subjecting nonconsenting individuals from subsidizing a political agenda, which was not the case for these appellants. The court also rejected the appellants' contract defenses. View "Barlow v. Service Employees International Union" on Justia Law

Larry Trent Roberts spent 13 years in prison for a murder that he did not commit. After being exonerated, he sued several state actors involved in obtaining his wrongful conviction, including Assistant District Attorney John C. Baer. The United States Court of Appeals for the Third Circuit held that Baer is not entitled to absolute immunity from liability under 42 U.S.C. § 1983 because his actions of seeking a new witness to establish a motive for the murder served an investigatory function, not a prosecutorial one. The court noted that prosecutors are not entitled to absolute immunity when they perform investigative functions normally performed by a detective or police officer. Baer argued that he was immune from liability as his conduct occurred post-charge and was designed to produce inculpatory evidence for trial. However, the court clarified that the timing of a prosecutor's actions as pre- or post-indictment and the presence or absence of a connection to a judicial proceeding are only "relevant considerations" in determining whether a prosecutor’s action served a prosecutorial function. They are not enough to establish that a prosecutor's post-charge effort to fabricate evidence for trial served a quasi-judicial function. The court affirmed the District Court's decision denying Baer's motion to dismiss. View "Roberts v. Lau" on Justia Law

A group of petitioners, including several municipalities, private individuals, and organizations, challenged the Federal Aviation Administration's (FAA) approval of a new terminal for the Trenton-Mercer Airport. The petitioners alleged that the FAA’s decision violated the National Environmental Policy Act (NEPA) by failing to fully consider the environmental impact of the new terminal, among other things. The United States Court of Appeals for the Third Circuit found that the FAA had adequately considered the environmental impact of the new terminal and had not violated NEPA. The court found that the FAA reasonably concluded that the new terminal would not induce additional air traffic, and therefore, would not result in increased noise or air pollution. The court also found that the FAA had conducted a reasonable environmental justice analysis and did not need to perform a health risk assessment. The Court of Appeals denied the petitioners' request to review the FAA's decision. View "Trenton Threatened Skies Inc v. FAA" on Justia Law

The case involved a dispute between Winn-Dixie Stores and the Eastern Mushroom Marketing Cooperative, Inc. (EMMC), its individual mushroom farmer members, and certain downstream distributors. Winn-Dixie accused the defendants of violating antitrust laws by engaging in a price-fixing agreement. The U.S. Court of Appeals for the Third Circuit held that the District Court was correct in applying the rule of reason, rather than a "quick-look" review, in assessing the legality of the defendants' pricing policy under the Sherman Act. The court found that the complex and variable nature of the arrangements within the cooperative, involving both horizontal and vertical components, necessitated a careful analysis to determine anticompetitive effects. The court also held that the jury's verdict, which found that the defendants' pricing policy did not harm competition, was not against the weight of the evidence and did not warrant a new trial. The court affirmed the District Court’s judgment in favor of the defendants. View "Winn Dixie Stores v. Eastern Mushroom Marketing Cooperative Inc" on Justia Law

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