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

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

A car leasing company leased a vehicle to an individual who defaulted on payments soon after the lease began. Despite having the right to repossess the car, the company did not do so. Two years later, the lessee was stopped by police in Butler, New Jersey, for driving with a suspended license, suspended registration, and no insurance. The police seized the car and had it towed by a contractor, Malanga’s Automotive. The lessee was informed of the tow but did not retrieve the vehicle. The towing company did not notify the leasing company that it possessed the car until nearly a year later, at which point it demanded payment of towing and storage fees before releasing the vehicle.The leasing company filed suit in the Superior Court of New Jersey against the towing company, later adding the Borough of Butler as a defendant and asserting claims under 42 U.S.C. § 1983 for violations of the Fourteenth Amendment’s Due Process Clause, the Fourth Amendment, and the Fifth Amendment. The case was removed to the United States District Court for the District of New Jersey, which granted summary judgment to Butler on all claims. The District Court found that the company had a property interest in the vehicle but concluded that Butler’s policies provided sufficient notice and opportunity to be heard, and that the seizure and retention of the vehicle were reasonable and did not constitute a taking.On appeal, the United States Court of Appeals for the Third Circuit held that Butler’s policies violated the Fourteenth Amendment’s Due Process Clause because they failed to require prompt notice to all holders of property rights in seized vehicles and did not provide an opportunity for a hearing to challenge the lawfulness of the tow or the fees. The court reversed and remanded the due process claim. However, it affirmed the District Court’s judgment on the Fourth and Fifth Amendment claims, finding no unreasonable seizure or unconstitutional taking. View "Honda Lease Trust v. Malanga's Automotive" on Justia Law

Five teenage boys disappeared in Newark, New Jersey, in 1978, and the case remained unsolved for decades. In 2008, police charged Lee Evans with their murders, relying primarily on a confession from Philander Hampton, Evans’s cousin. Evans was later acquitted at trial. He then filed a civil lawsuit, alleging that Detectives Lou Carrega and William Tietjen coerced Hampton’s confession and fabricated evidence to implicate him. Hampton later recanted, stating that his confession was false and coerced by the detectives.The United States District Court for the District of New Jersey reviewed the case after Evans brought claims for malicious prosecution against the detectives. The detectives moved for summary judgment, arguing they were entitled to qualified immunity. The District Court denied summary judgment on the malicious prosecution claims, finding that a reasonable jury could conclude the detectives made reckless, material omissions by failing to disclose that Hampton’s confession was coerced, and that these omissions led to Evans’s prosecution without probable cause. The detectives appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s denial of summary judgment. The Third Circuit held that qualified immunity does not shield law enforcement officers from liability for malicious prosecution when the prosecution is based on evidence that was allegedly manufactured or coerced. The court affirmed the District Court’s order denying summary judgment to the detectives on the malicious prosecution claim, concluding that a reasonable jury could find the officers violated Evans’s constitutional rights by arresting and prosecuting him without probable cause, based on fabricated evidence. The court also remanded for further consideration of the timeliness of Evans’s separate fabrication of evidence claim. View "Evans v. City of Newark" on Justia Law

An incarcerated individual alleged that, while detained at a county jail, he was assaulted by corrections officers, resulting in a fractured orbital bone, denied proper medical care, and unlawfully restrained for an extended period. He claimed to have submitted a grievance regarding the incident by placing it in the slot of his cell door, as he was in segregated housing and could not access the grievance box directly. The jail officials disputed his account, asserting that their use of force was justified, that he received prompt medical attention, and that he was restrained for a shorter period than he claimed.The United States District Court for the Western District of Pennsylvania reviewed the case after both parties moved for summary judgment. The defendants argued that the plaintiff failed to exhaust administrative remedies as required by the Prison Litigation Reform Act, supporting their position with a declaration that no grievance from the plaintiff was found in the jail’s records. The plaintiff, proceeding without counsel, reiterated his claim of submitting a grievance, but did so only in unsworn statements within his complaint and opposition brief. The District Court concluded that these unsworn statements could not be considered as evidence and granted summary judgment in favor of all defendants on the basis of non-exhaustion.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decision. The Third Circuit held that, while unsworn statements cannot create a genuine dispute of material fact at summary judgment, the District Court erred in concluding it was entirely barred from considering such statements for other purposes, such as deciding whether to permit the plaintiff an opportunity to cure procedural defects under Federal Rule of Civil Procedure 56(e). The Third Circuit vacated the District Court’s grant of summary judgment and remanded the case for further proceedings consistent with its opinion. View "Lauria v. Lieb" on Justia Law