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

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

Sahbree Hurtt was convicted of possession of heroin, fentanyl, and cocaine with intent to distribute. The District Court determined that his prior convictions for aggravated assault and drug trafficking qualified him as a "career offender" under the U.S. Sentencing Guidelines (USSG), leading to sentencing enhancements. Hurtt objected to his status as a career offender, arguing that neither conviction constituted a career-offender predicate.The District Court reviewed judicial records from Hurtt's prior convictions and determined that he had prior convictions under specific sections of Pennsylvania's aggravated-assault and drug-trafficking statutes. The court concluded that these convictions qualified as a "crime of violence" and "controlled substance offense," respectively, under the USSG. Consequently, the court imposed corresponding enhancements and sentenced Hurtt to 120 months' imprisonment. Hurtt appealed this decision, challenging his status as a career offender.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The court found that Hurtt's conviction for aggravated assault under a specific subsection of Pennsylvania's aggravated-assault statute constituted a "crime of violence" under the USSG. The court also determined that Hurtt's conviction for drug trafficking under a specific section of Pennsylvania's drug-trafficking statute constituted a "controlled substance offense" under the USSG. Therefore, the court concluded that Hurtt qualifies as a career offender under the USSG, affirming the District Court's judgment. View "USA v. Sahbree Hurtt" on Justia Law

The case involves Tahjair Dorsey, who was convicted for possession of a firearm by a convicted felon under 18 U.S.C. § 922(g)(1). Dorsey had previously pleaded guilty to carrying a firearm without a license, a felony under Pennsylvania law. He was paroled in June 2021. In August 2021, during an investigation into suspected gang activity, Dorsey was observed leaving a residence under surveillance and was apprehended after fleeing a vehicle stop. A stolen handgun was recovered nearby, and Dorsey's DNA was found on it. He was subsequently indicted for being a felon in possession of a firearm.Dorsey pleaded guilty but later appealed his conviction, arguing that § 922(g)(1) was unconstitutional as applied to him under the Second Amendment. However, he had not raised this objection at any stage of the District Court proceedings. The District Court sentenced Dorsey to time served and three years of supervised release.The United States Court of Appeals for the Third Circuit reviewed the case for plain error. The court referred to its en banc decision in Range v. Attorney General, which held that disarming an individual with a single, almost-thirty-year-old criminal conviction for food stamp fraud was not consistent with the Second Amendment. The court found that Dorsey could not show that he was similarly situated to the appellant in Range for Second Amendment purposes. The court noted that Dorsey's prior conviction was for a state firearm law violation, was more recent, and he was on state parole at the time of the offense. The court concluded that any Second Amendment error inherent in Dorsey’s conviction was not plain and affirmed the lower court's decision. View "USA v. Dorsey" on Justia Law

The case involves Carlos Inestroza-Tosta, a native and citizen of Honduras, who illegally entered the United States multiple times and was removed on each occasion. After his third illegal entry, he was apprehended following an arrest for aggravated assault. His prior order of removal was reinstated, but he claimed a fear of returning to Honduras and sought withholding of removal and relief under the Convention Against Torture. His requests were denied by the Immigration Judge (IJ) and the Board of Immigration Appeals (BIA), leading to his appeal to the United States Court of Appeals for the Third Circuit.The BIA dismissed Inestroza-Tosta's appeal, affirming the IJ's denial of his motion for administrative closure and his applications for statutory withholding of removal and relief under the Convention Against Torture. The BIA held that Inestroza-Tosta had not established that any harm he experienced or feared was connected to a protected ground, and his proposed particular social group, "gang violence recipients," was not recognized by law.The United States Court of Appeals for the Third Circuit held that the 30-day deadline for a would-be immigrant to seek judicial review of a "final order of removal" is nonjurisdictional. The court also held that an order of removal is not final until a decision has been made on the alien’s request for withholding of removal. Applying these conclusions to this case, the court ruled that Inestroza-Tosta timely sought review of the BIA’s denial of his requests for statutory withholding of removal and relief under the Convention Against Torture. However, his petition failed on the merits. Although he suffered persecution in the past, he could not demonstrate a clear probability of future harm based on a protected status or trait. Therefore, while his petition for review was timely, it was denied. View "Inestroza-Tosta v. Attorney General United States of America" on Justia Law

James Chandler was convicted for twice robbing on-duty United States Postal Service employees using a fake gun, and in one instance, kidnapping his victim. The District Court enhanced Chandler's sentence for using the replica gun in the robberies and the kidnapping, and for the kidnapping being motivated, at least in part, by the mail carrier being a government employee.Chandler appealed the application of these two enhancements, arguing that the judge erred in holding that a replica of a gun constitutes a dangerous weapon, and further erred in holding that his kidnapping of the second mail carrier was motivated by her status as a government employee. He also appealed his conviction for armed robbery, rather than unarmed robbery, again arguing that a replica firearm is not a dangerous weapon.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals found that the term "dangerous weapon" is genuinely ambiguous and can include a replica firearm. The Court also found that the District Court did not err in accepting Chandler's guilty plea to armed robbery. Finally, the Court of Appeals agreed with the District Court that Chandler was motivated to kidnap the mail carrier because she was a government employee. View "USA v. Chandler" on Justia Law

The case involves a non-verbal student, Alexandre Le Pape, and his family who repeatedly requested that the Lower Merion School District change his educational program to include a new communication protocol known as "Spelling to Communicate" (S2C). The school district denied these requests, leading to Alexandre's withdrawal from public education. The family filed an administrative special education due process complaint against the school district, alleging that the district failed to protect Alexandre's rights and denied him a Free Accessible Public Education (FAPE) under various laws. An administrative hearing officer ruled against the family on all claims, leading them to file a suit in the United States District Court for the Eastern District of Pennsylvania.The District Court granted the school district's motions for summary judgment on the Americans with Disabilities Act (ADA) claim and judgment on the administrative record for the denial-of-FAPE claims. The Le Papes appealed the court's decision, arguing that the court granted judgment without applying the summary judgment standard to which they were entitled under Federal Rule of Civil Procedure 56.The United States Court of Appeals for the Third Circuit reversed and remanded the case. The court held that the District Court erred in granting summary judgment for the school district on the Le Papes' ADA discrimination claim and judgment on the administrative record for their discrimination claims under both the ADA and Section 504. The court clarified that a denial-of-FAPE claim under the Individuals with Disabilities Education Act (IDEA) can be resolved through an administrative appeal, but ADA and Section 504 discrimination claims seeking compensatory damages, even if on the same facts, should be resolved through summary judgment and, possibly, trial. View "Le Pape v. Lower Merion School District" on Justia Law

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