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

A student, Brooklyn, and her parent, Gabrielle M., filed a complaint against the Upper Darby School District, alleging that the district failed to provide Brooklyn with a Free Appropriate Public Education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA) and Section 504 of the Rehabilitation Act of 1973. The family claimed that the district had not fulfilled its "Child Find" obligation to identify Brooklyn as eligible for services under Section 504 until fourth grade, despite requests for a comprehensive evaluation as early as kindergarten. The family also argued that the district's 504 plan for Brooklyn was inadequate.The case was first heard by a special education hearing officer, who ruled that the district had denied Brooklyn a FAPE by providing an inadequate 504 plan, but had not violated its Child Find obligation. The family then filed a complaint in the United States District Court for the Eastern District of Pennsylvania, which affirmed the hearing officer's decision and granted judgment on the administrative record to the School District.The United States Court of Appeals for the Third Circuit disagreed with the District Court's decision, stating that the court had erred in not separately analyzing the Child Find claim under Section 504, despite the broader definition of disability under Section 504 compared to the IDEA. The Court of Appeals vacated the District Court's decision and remanded the case for further analysis of the Child Find claim under Section 504. View "B. M. v. Upper Darby School District" on Justia Law

The case revolves around the tragic death of Tyler Gergler, a recruit in the Marine Corps' Delayed Entry Program. Gergler died in a car accident while driving to a Marine Corps event, despite being ill. His parents, Raynu Clark and Jason R. Gergler, alleged that Sergeant Mitchell Castner, Gergler's recruiter, negligently pressured their son to drive to the event despite his illness, which led to the fatal accident. They argued that since Castner's actions were within the scope of his Marine Corps employment, the Government was liable for their son's death.The case was initially heard in the United States District Court for the District of New Jersey. The Government moved to dismiss the case, arguing that the United States has sovereign immunity for discretionary acts of government agents. They contended that when Castner pressured Gergler to drive, he was acting as Gergler's recruiter, a discretionary function, and thus, sovereign immunity barred the lawsuit. The District Court agreed with the Government's argument and dismissed the case on the grounds that Castner had discretion and was exercising that discretion.The case was then appealed to the United States Court of Appeals for the Third Circuit. The court affirmed the District Court's decision, ruling that the United States and its agents enjoy sovereign immunity from suit. The court found that Castner had discretion to urge Gergler to attend the event and that his function of preparing Marine recruits for training was discretionary. The court also rejected the parents' arguments that Castner's conduct was so egregious that it goes beyond policy consideration and that a narrow carve-out for easy precautions should apply. The court concluded that the United States is immune from suit when its agents commit alleged torts within the discretion accorded by their job function, and Sergeant Castner's actions were within his discretionary function of preparing Marine recruits for training. View "Clark v. Secretary United States Navy" on Justia Law

The case revolves around Tiffany Smith, who filed a voluntary petition for a Chapter 13 bankruptcy proceeding in May 2019. Smith owned a two-unit rental property in Newark, New Jersey, secured by a mortgage held by Freedom Mortgage Corporation. Smith filed a Chapter 13 payment plan in the Bankruptcy Court, which included a motion to partially void Freedom’s mortgage lien on the property and to reclassify Freedom’s underlying claim as partially secured and partially unsecured. Freedom objected to the plan, particularly the cramdown of its secured claim, the property's listed valuation, the property's rents being applied to reduce its secured claim, and the feasibility of the overall plan.The Bankruptcy Court held a hearing to address Freedom’s objections. During the hearing, Freedom clarified that it was not disputing the listed value of the property. The parties resolved their differences and filed a consent order, in which they agreed to the terms. The Bankruptcy Court confirmed the First Modified Plan, which reflected the terms of the Consent Order.Smith later filed a third modified plan, seeking to extend the payment term due to delinquent tenants and pandemic-related eviction moratoriums. Freedom objected to the Third Modified Plan, arguing among other things, that the plan was not feasible. The Bankruptcy Court held a hearing and concluded that the objections raised by Freedom were precluded by res judicata. The Bankruptcy Court then confirmed the Third Modified Plan in a written order. Freedom appealed the Bankruptcy Court’s order to the District Court, which affirmed it. Freedom then appealed to the United States Court of Appeals for the Third Circuit.The Court of Appeals affirmed the District Court’s decision, holding that res judicata precluded Freedom’s objections to Smith’s use of rental income to pay its secured claim, to the valuation of the property, and to the plan’s stepped-up payment schedule. The Court also concluded that the Bankruptcy Court did not clearly err when it determined the Third Modified Plan to be feasible. View "In re: Smith" on Justia Law

The case involves two American Airlines pilots, James P. Scanlan and Carla Riner, who sued their employer for failing to pay them and provide certain benefits while they were on short-term military leave. They claimed that the airline violated the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA), which provides employees on military leave the right to receive the same employment benefits as other similarly situated employees. They also claimed that the airline breached their profit-sharing plan by failing to account for imputed earnings during periods of military leave.The District Court granted summary judgment for the airline on all claims. It held that the pilots could not prevail on their USERRA claims because short-term military leave is not comparable to jury-duty or bereavement leave when comparing duration, frequency, control, and purpose. It also concluded that, under Texas law, the profit-sharing plan unambiguously excludes imputed income from periods of military leave.The United States Court of Appeals for the Third Circuit affirmed the judgment for the airline on the breach of contract claim. However, it reversed the judgment for the airline on the USERRA claims, stating that a reasonable jury could find that short-term military leave is comparable to jury-duty leave or bereavement leave based on the three factors mentioned in the implementing regulation, and any other factors it may consider. The case was remanded for further proceedings on the USERRA claims. View "Scanlan v. American Airlines Group Inc." on Justia Law

The case revolves around Jonathan Goerig, who was found parked in a high-school parking lot. A police officer, acting on a tip, approached Goerig and began questioning him. The officer noticed Goerig's shorts were pulled down and his suspicious responses led the officer to order him out of his truck. Evidence found in the truck revealed that Goerig planned to meet a minor for sex.Prior to the current review, the District Court had denied Goerig's motion to suppress the evidence found in his truck, his statements to the arresting officers, and all evidence recovered from his phone and iCloud account. The court held that the officer had not seized Goerig until he told him to get out of the truck and by then, he had reasonable suspicion. It also ruled that police had validly seized all the evidence.The United States Court of Appeals for the Third Circuit affirmed the District Court's judgment. The court held that the police officer did not seize Goerig until he ordered him to step out of the truck. Until then, the officer was just asking him questions. The court also held that by the time the officer ordered Goerig out of the truck, he had reasonable suspicion for a Terry stop. The court further held that the arrest was proper and that the police validly searched and seized all the evidence. The court concluded that the Terry stop, arrest, and searches and seizures were proper, and thus affirmed the District Court's judgment. View "USA v. Goerig" on Justia Law

The case involves plaintiffs Nancy Mator and Robert Mator, who are participants in the Wesco Distribution, Inc. Retirement Savings Plan. They sued Wesco Distribution, Inc., its fiduciaries, and the Plan, alleging that they violated fiduciary duties imposed by the Employee Retirement Income Security Act of 1974 (ERISA) by paying excessive recordkeeping fees and failing to monitor the Plan. The District Court dismissed the complaint with prejudice.The plaintiffs appealed to the United States Court of Appeals for the Third Circuit. They argued that the District Court erred in dismissing their complaint, which alleged that Wesco breached its fiduciary duties under ERISA by causing the Plan to pay excessive recordkeeping fees, offering retail-class shares of mutual funds, and failing to monitor those responsible for the Plan.The Court of Appeals agreed with the plaintiffs. It found that the plaintiffs' allegations were sufficient to state a claim for breach of fiduciary duty. The Court noted that the plaintiffs provided specific plan comparators and plausibly alleged that the services purchased were sufficiently similar to render the comparisons valid. The Court also found that the plaintiffs adequately alleged a fiduciary breach based on the Plan’s offerings of retail-class mutual fund shares.The Court of Appeals vacated the District Court's dismissal of the complaint and remanded the case for further proceedings. View "Mator v. Wesco Distribution Inc" on Justia Law

The case involves defendants Abdur Rahim Islam and Shahied Dawan, who were charged with multiple counts of fraud and bribery related to their roles in Universal Community Homes and Universal Education Companies. During their nearly six-week-long trial, five original jurors were discharged and replaced by alternates. When one of the remaining jurors contracted COVID-19, the defendants refused to proceed with eleven jurors, leading the District Court to declare a mistrial based on manifest necessity. The defendants moved to dismiss the indictment, arguing that the Fifth Amendment’s Double Jeopardy Clause barred their reprosecution. The District Court denied the motion.The case was previously tried in March 2022, but the jury was unable to reach a verdict, leading to a retrial in September 2022. During the retrial, three jurors were discharged during the first phase of the trial due to various personal reasons. After the jury acquitted all four defendants of the honest services wire fraud charges, the trial continued with the remaining charges against Islam and Dawan. However, two more jurors were discharged due to personal reasons, and another juror contracted COVID-19, leading to the declaration of a mistrial.The United States Court of Appeals for the Third Circuit held that the District Court’s declaration of a mistrial was manifestly necessary, affirming the decision as to Islam. However, the court dismissed Dawan’s appeal as moot because he was acquitted on all other counts, and any remaining double jeopardy issues with respect to him were no longer live. The court found that the District Court had considered and exhausted all reasonably available alternatives before declaring a mistrial, and therefore did not abuse its discretion when it discharged the jury. View "USA v. Islam" on Justia Law

The case involves Gerald Forsythe, who filed a class action lawsuit against Teva Pharmaceuticals Industries Ltd. and several of its officers. Forsythe claimed that he and others who purchased or acquired Teva securities between October 29, 2015, and August 18, 2020, suffered damages due to misstatements and omissions by Teva and its officers related to Copaxone, a drug used to treat multiple sclerosis. Teva's shares are dual listed on the New York Stock Exchange and the Tel Aviv Stock Exchange.The District Court granted Forsythe's motion for class certification, rejecting Teva's assertion that the class definition should exclude purchasers of ordinary shares. The Court also rejected Teva's argument that Forsythe could not satisfy Rule 23(b)(3)’s predominance requirement.Teva sought permission to appeal the District Court’s Order granting class certification, arguing that interlocutory review is proper under Federal Rule of Civil Procedure 23(f). Teva contended that the Petition presents a novel legal issue and that the District Court erred in its predominance analysis with respect to Forsythe’s proposed class-wide damages methodology.The United States Court of Appeals for the Third Circuit denied Teva's petition for permission to appeal. The court found that the securities issue did not directly relate to the requirements for class certification, and agreed with the District Court’s predominance analysis. The court also clarified that permission to appeal should be granted where the certification decision itself under Rule 23(a) and (b) turns on a novel or unsettled question of law, not simply where the merits of a particular case may turn on such a question. View "Forsythe v. Teva Pharmaceutical Industries Ltd" on Justia Law

The case revolves around a local ordinance in the Borough of Camp Hill that regulates the display of signs on private property. The ordinance categorizes signs into about twenty different types, each with its own set of restrictions. Two residents, Katherine Pearson and Caroline Machiraju, displayed political signs on their lawns in the lead-up to the 2022 midterm elections. However, they were told to remove their signs as they violated the local sign ordinance. The ordinance categorized their signs as "Temporary Signs" and further classified them as "Personal Expression Signs," which express a non-commercial message. The ordinance limited the number of such signs a resident could display and the time frame within which they could be displayed.The residents complied with the directive but subsequently sued Camp Hill, challenging the provisions of the ordinance under the First Amendment. The United States District Court for the Middle District of Pennsylvania granted them summary judgment on their facial challenge, ruling that the provisions were content-based and failed strict scrutiny.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals found that the ordinance was content-based as it classified signs based on their content, favoring commercial expression over noncommercial and holiday messages over non-holiday messages. The court held that such content-based restrictions could only stand if they furthered a compelling government interest and were narrowly tailored to achieve that interest. The court found that Camp Hill's interests in traffic safety and aesthetics, while legitimate, were not compelling and that the ordinance was not narrowly tailored to serve those interests. The court concluded that the ordinance was unconstitutional on its face. View "Camp Hill Borough Republican Association v. Borough of Camp HIll" on Justia Law

The case involves the Government Employees Insurance Company (GEICO) and its affiliates, who sued several medical practices in separate actions in the District of New Jersey. GEICO alleged that the practices defrauded them of more than $10 million by abusing the personal injury protection (PIP) benefits offered by its auto policies. The practices allegedly filed exaggerated claims for medical services, billed medically unnecessary care, and engaged in illegal kickback schemes. GEICO's suits against the practices each included a claim under the New Jersey’s Insurance Fraud Prevention Act (IFPA).The practices sought arbitration of GEICO’s IFPA claim, arguing that a valid arbitration agreement covered the claim and that a different New Jersey insurance law allowed them to compel arbitration. However, each District Court disagreed, ruling instead that IFPA claims cannot be arbitrated. The practices appealed to the United States Court of Appeals for the Third Circuit.The Third Circuit Court of Appeals reversed the lower courts' decisions, holding that claims under the IFPA are arbitrable. The court found that GEICO's argument that the IFPA implicitly prohibits arbitration was not persuasive. The court also concluded that GEICO’s IFPA claims must be compelled to arbitration under the Federal Arbitration Act (FAA), as the claims fell under the scope of the arbitration agreement in GEICO's Precertification and Decision Point Review Plan. The court remanded the case with instructions to compel arbitration of GEICO’s IFPA claims against the practices. View "GEICO v. Caring Pain Management PC" on Justia Law