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

Jose Montanez, an inmate in Pennsylvania state prisons, experienced sudden paralysis and incontinence while incarcerated at SCI-Huntingdon. After collapsing in his cell, he was taken to the medical unit but received minimal assistance and was denied hospital care. He was left in his cell, unable to walk or reach the toilet, for three days before receiving an MRI that revealed spinal cord stenosis and edema, necessitating surgery. Following surgery and a brief rehabilitation, Montanez was returned to prison, where he suffered a fall and herniated a disc. He alleged that prison medical staff denied him adequate pain medication and accommodations for his disabilities, such as a double mattress, mobility aids, and access to physical therapy.Montanez filed a pro se complaint in the United States District Court for the Middle District of Pennsylvania, asserting claims under the Eighth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act (RA) against the Commonwealth of Pennsylvania, its employees, Wellpath Care LLC (a private medical contractor), and Wellpath employees. The District Court dismissed all claims with prejudice, finding the complaint insufficient to state a claim and denying leave to amend, citing futility.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that Montanez’s complaint, liberally construed, stated viable Eighth Amendment claims against certain individual defendants (Dr. Mahli, Nurse Wagman, and Administrator Ellers), a Section 504 RA claim against Wellpath, and ADA and RA claims against the Commonwealth. The court found that the District Court erred in dismissing these claims and in denying leave to amend for other claims, as amendment would not be futile. The Third Circuit affirmed in part, reversed in part, and remanded with instructions to allow Montanez to amend his complaint. View "Montanez v. Price" on Justia Law

A member of the Pennsylvania House of Representatives used public funds and the resources of the House Democratic Caucus to send five pre-recorded, automated phone calls to constituents. These calls provided information about public health resources, employment opportunities, and community events. The calls were approved and administered by House staff, who determined that each served a clear legislative purpose and public benefit. The recipient of these calls, Andrew Perrong, filed suit, alleging that the calls violated the Telephone Consumer Protection Act (TCPA), which generally prohibits automated or pre-recorded calls made by “any person.”The United States District Court for the Eastern District of Pennsylvania denied the legislator’s motion for summary judgment. The court held that the legislator was a “person” under the TCPA and could be sued in his individual capacity, even though the calls were made as part of his official duties. The District Court also found that the suit was not barred by Eleventh Amendment sovereign immunity, reasoning that the Commonwealth of Pennsylvania was not the real party in interest, and that qualified immunity did not apply because the statutory prohibition was clear.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory question and the immunity defenses. The Third Circuit held that the TCPA’s use of the term “person” does not clearly and unmistakably include state legislators acting in their official capacity when performing legitimate government functions. The court reasoned that longstanding interpretive presumptions, constitutional federalism principles, and statutory context all support excluding such official acts from the statute’s reach. As a result, the court reversed the District Court’s denial of summary judgment, holding that the TCPA’s robocall restriction does not apply to calls made by state legislators in connection with their legitimate government functions. View "Perrong v. Bradford" on Justia Law

Novo Nordisk, a pharmaceutical manufacturer, challenged the implementation of the Drug Price Negotiation Program established by the Inflation Reduction Act of 2022. The Program requires the Department of Health and Human Services, through the Centers for Medicare and Medicaid Services (CMS), to negotiate prices for certain high-expenditure drugs covered by Medicare. In the first round of selections, CMS grouped six of Novo Nordisk’s insulin aspart products as a single “negotiation-eligible drug” and selected them for price negotiation. Novo Nordisk signed the required agreements to participate but subsequently filed suit, arguing that CMS’s grouping of its products and the procedures used to implement the Program violated statutory and constitutional provisions.The United States District Court for the District of New Jersey granted summary judgment in favor of the government. The court found it lacked subject matter jurisdiction to review CMS’s decision to treat the six products as one drug due to a statutory bar on judicial review. It also held that Novo Nordisk lacked standing to challenge the identification of more than ten drugs for the initial pricing period. The court rejected Novo Nordisk’s claims under the unconstitutional conditions doctrine, the Due Process Clause, the nondelegation doctrine, and the First Amendment, concluding that the Program did not deprive the company of a protected property interest, that Congress provided an intelligible principle to guide CMS, and that the Program primarily regulated conduct rather than speech.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that the statutory bar on judicial review precluded consideration of Novo Nordisk’s challenge to the grouping of its products. The court also held that CMS was authorized to implement the Program through guidance for the initial years without notice and comment rulemaking, that the Act did not violate the nondelegation doctrine or the Due Process Clause, and that Novo Nordisk’s First Amendment claim was foreclosed by precedent. View "Novo Nordisk Inc. v. Secretary US Dept & Health and Human Services" on Justia Law

A Nigerian citizen who became a lawful permanent resident of the United States in 2005 was placed in removal proceedings after being convicted of conspiracy to commit passport fraud. He had lived in the U.S. for many years, had a long-term partner, and was the father of four U.S. citizen children. His conviction stemmed from a scheme to obtain fraudulent U.S. passports for noncitizens, for which he was sentenced to 27 months in prison. After serving his sentence and briefly fleeing to Canada, he was returned to the U.S. and charged as inadmissible for committing a crime involving moral turpitude. In removal proceedings, he applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), claiming past persecution and fear of future harm in Nigeria due to his former union activities and threats from a militia group.An Immigration Judge (IJ) found him inadmissible, denied all forms of relief, and determined that his conviction constituted a particularly serious crime, barring asylum and withholding. The IJ also found his and his partner’s testimony not credible and denied CAT relief, concluding he had not shown a likelihood of torture with government acquiescence. The Board of Immigration Appeals (BIA) affirmed, agreeing with the IJ’s findings and further holding that the absence of an interpreter did not violate due process, that the conviction was a particularly serious crime, and that he was not eligible for a waiver of inadmissibility.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the BIA misapplied the legal standard for determining a particularly serious crime by failing to consider the elements of the underlying substantive offense in the conspiracy conviction. The court also found that the BIA did not properly analyze the CAT claim under the required legal framework and failed to consider eligibility for a waiver of inadmissibility. The court denied the due process claim but vacated the BIA’s decision and remanded for further proceedings, ordering a stay of removal pending the outcome. View "Amos v. Attorney General United States of America" on Justia Law

Natalya Shvets was convicted by a jury in 2014 for healthcare fraud and conspiracy to commit healthcare fraud, stemming from her role as a nurse at Home Care Hospice, Inc. (HCH). Evidence showed she and other employees created false records for high-priced “continuous care” services, resulting in fraudulent bills submitted to Medicare. Shvets was ordered to pay $253,196 in restitution, jointly and severally with eight other defendants, for her involvement in 52 false bills. The broader scheme allegedly caused $16.2 million in losses to Medicare, with seventeen individuals ordered to pay varying restitution amounts.After sentencing in the United States District Court for the Eastern District of Pennsylvania, Shvets moved for an accounting and to declare her restitution judgment satisfied, arguing that payments by herself and her jointly liable co-defendants had collectively exceeded $253,196. The District Court, relying on United States v. Sheets, held that Shvets’s judgment would not be satisfied until she personally paid the full amount or until all defendants collectively paid $16.2 million. The Clerk of Court, using a complex allocation method, also reported Shvets’s balance as outstanding, but the District Court did not resolve whether the Clerk’s method was correct.On appeal, the United States Court of Appeals for the Third Circuit affirmed in part, vacated in part, and remanded. The Court held that sentencing judges may issue “hybrid” restitution orders under the Mandatory Victim Restitution Act, combining joint and several liability with apportioned liability. The Court found the District Court erred by applying the Sheets rule, which conflicted with the language of Shvets’s judgment. The Third Circuit directed the District Court to determine whether the Clerk’s accounting method is fair and appropriate, and to decide if Shvets’s restitution judgment has been satisfied. View "United States v. Shvets" on Justia Law

Scranton Products sued Bobrick Washroom Equipment in 2014, alleging false advertising regarding the fire compliance of Scranton’s toilet partitions. Bobrick counterclaimed, asserting Scranton’s advertising was itself false. Scranton voluntarily dismissed its claims, and the parties entered into a settlement agreement that included a provision waiving their rights to appeal any court orders arising from the agreement or enforcement motions. The District Court approved the agreement, dismissed the case, and retained jurisdiction to enforce the settlement. Subsequently, both parties filed enforcement motions related to compliance with the agreement, leading to a public evidentiary hearing. During post-hearing proceedings, Scranton moved to seal certain documents, and the District Court issued two sealing orders: one temporarily sealing documents during the pendency of enforcement motions, and another indefinitely sealing them after the motions were resolved.The United States District Court for the Middle District of Pennsylvania denied all enforcement motions and issued the second sealing order, directing the parties to confer about sealing and stating that, absent agreement, the status quo of sealing would remain. Bobrick appealed both sealing orders, arguing that the indefinite sealing was overbroad and contrary to the public’s right of access to judicial records.The United States Court of Appeals for the Third Circuit reviewed the case. It held that it lacked jurisdiction to review the first, temporary sealing order because it was no longer in effect, rendering the appeal moot. The court found it had jurisdiction to review the second, indefinite sealing order under the collateral order doctrine, as it was final and appealable. However, the Third Circuit enforced the appellate waiver in the settlement agreement, declining to exercise jurisdiction over the appeal and affirming the District Court’s indefinite sealing order. The court also denied Bobrick’s alternative request for a writ of mandamus. View "Bobrick Washroom Equipment Inc v. Scranton Products Inc" on Justia Law

The defendant was previously convicted in North Carolina of indecent liberties with a child, which required him to register as a sex offender under federal law. He complied with federal registration requirements after moving to New York in 2017 and again after moving within New York in 2018. However, he failed to comply with New York’s separate annual address verification requirement after 2018. In 2023, after moving to Pennsylvania, he also failed to update his federal sex offender registration as required by the Sex Offender Registration and Notification Act (SORNA). He was indicted and pleaded guilty to knowingly failing to update his federal registration after interstate travel, in violation of 18 U.S.C. § 2250(a).The United States District Court for the Middle District of Pennsylvania, relying on the Presentence Investigation Report, calculated the defendant’s criminal history score by including three prior sentences from 2010 and 2011. The Probation Office and the District Court reasoned that the “commencement of the instant offense” for purposes of the Sentencing Guidelines’ criminal history look-back period included not only the conduct underlying the federal conviction but also “relevant conduct,” specifically the earlier New York state registration violations. This interpretation resulted in a higher criminal history category and a longer advisory sentencing range.The United States Court of Appeals for the Third Circuit reviewed the District Court’s interpretation of the Sentencing Guidelines de novo. The Third Circuit held that the phrase “commencement of the instant offense” in U.S.S.G. § 4A1.2(e) unambiguously refers only to the start of the conduct constituting the offense of conviction, not to other “relevant conduct.” Therefore, the District Court erred by including the earlier state-law violations in its calculation. The Third Circuit vacated the sentence and remanded for resentencing using the correct criminal history category. View "USA v. Josey" on Justia Law

In this case, the defendant broke into two gun stores in 2016, stealing a total of sixty-nine guns, a digital video recorder, and a cash register. Many of the stolen guns were later recovered from the defendant’s residence and vehicle. The thefts caused property damage to the stores, and the stores had to close for a week to recover from the incidents. The defendant pleaded guilty to stealing guns from federal firearms licensees and conspiracy, and as part of his plea agreement, he agreed to pay restitution.The United States District Court for the Middle District of Pennsylvania initially ordered restitution without accounting for insurance payments or the return of some stolen guns. On appeal, the United States Court of Appeals for the Third Circuit remanded the case for recalculation of the restitution amount, instructing the District Court to subtract any reimbursements. On remand, after an evidentiary hearing with testimony from the store owners and a federal agent, the District Court ordered the defendant to pay $57,044.96 in restitution, including the full retail value of the stolen guns and a week’s worth of lost income for each store.The United States Court of Appeals for the Third Circuit reviewed the case and held that the District Court erred by awarding restitution for lost income, as this resulted in double-counting the value of the stolen guns and included consequential damages not permitted under the Mandatory Victims Restitution Act. The Third Circuit vacated the lost-income portion of the restitution award and remanded for correction, but affirmed the remainder of the award, finding that the evidence supported the calculation of the value of the stolen guns and property damage. View "USA v. McCormack" on Justia Law

Rajeri Curry was investigated for drug trafficking after purchasing heroin and fentanyl in bulk from two brothers, Al-Tariq and Shadee Brown. Following a fatal overdose linked to drugs Curry sold, police arrested her and seized her iPhone. After being read her Miranda rights, Curry requested a lawyer. Detectives then asked for consent to search her phone, explaining that refusal would lead to a warrant and possible data loss. Concerned about losing her files, Curry provided her passcode and signed a consent form. The detectives did not question her about the charged offenses during this interaction.Curry was indicted in the United States District Court for the District of New Jersey for conspiracy to distribute heroin and fentanyl, possession with intent to distribute, and distribution resulting in death. Before trial, she moved to suppress evidence obtained from her phone, arguing it was inadmissible due to a violation of the Edwards v. Arizona rule. The District Court denied the motion, admitted the evidence, and allowed the prosecution to introduce Curry’s prior drug convictions. After trial, the jury convicted Curry of conspiracy and possession with intent to distribute, but did not reach a verdict on the distribution resulting in death count. The District Court denied Curry’s motion for judgment of acquittal and sentenced her as a career offender to 216 months’ imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that evidence derived from Curry’s phone was not subject to suppression under Edwards v. Arizona because Curry voluntarily provided her passcode and consented to the search. The court affirmed the District Court’s judgment, finding no error in the denial of the suppression motion, the sufficiency of evidence for conspiracy, the admission of prior convictions under Rule 404(b), and the application of the career-offender sentencing enhancement. View "USA v. Curry" on Justia Law

Yellow Corporation, a major trucking company, ceased operations and filed for bankruptcy in 2023. As a result, it withdrew from several multiemployer pension plans, triggering withdrawal liability—an amount owed to the pension plans to cover unfunded vested benefits for employees. The pension plans, which had received substantial federal funds under the American Rescue Plan Act of 2021 (ARPA) to stabilize their finances, filed claims against Yellow’s bankruptcy estate for withdrawal liability. The dispute centered on how much of the ARPA funds should be counted as plan assets when calculating Yellow’s liability, as well as whether certain contractual terms could require Yellow to pay a higher withdrawal liability than statutory minimums.The United States Bankruptcy Court for the District of Delaware reviewed the claims. It upheld two regulations issued by the Pension Benefit Guaranty Corporation (PBGC): the Phase-In Regulation, which requires ARPA funds to be counted as plan assets gradually over time, and the No-Receivables Regulation, which bars plans from counting ARPA funds as assets before they are actually received. The Bankruptcy Court found these regulations to be valid exercises of PBGC’s authority and not arbitrary or capricious. It also ruled that two pension plans could enforce a contractual provision requiring Yellow to pay withdrawal liability at a higher, agreed-upon rate, rather than the rate based solely on its actual contributions.On direct appeal, the United States Court of Appeals for the Third Circuit affirmed the Bankruptcy Court’s order. The Third Circuit held that the PBGC’s regulations were valid under ARPA and ERISA, as Congress had expressly delegated authority to the PBGC to set reasonable conditions on the allocation of plan assets and withdrawal liability. The court also held that pension plans could enforce contractual terms requiring higher withdrawal liability, as the statutory scheme sets a floor, not a ceiling, for such liability. View "In re: Yellow Corporation" on Justia Law