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

In a case before the United States Court of Appeals for the Third Circuit, a group of former union members alleged that their First Amendment rights were violated when their respective unions continued to deduct membership dues from their paychecks after they had resigned from the unions. The appellants had previously signed union membership applications authorizing the deduction of dues from their paychecks, with the authorizations being irrevocable for a year, regardless of membership status, unless the member provided written notice of revocation within a specified annual window. The appellants resigned from their respective unions after their annual revocation windows had passed, and the unions continued to deduct dues until the next annual revocation window. The appellants argued that 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, should extend to their situation. The Third Circuit disagreed, holding that Janus was focused on preventing forced speech by nonmembers who never consented to join a union, not members who voluntarily join a union and later resign. The court further rejected the appellants' due process claims, finding that they had not been deprived of any constitutional rights. The court also dismissed the appellants' contract defenses, finding that they had not alleged that the terms of their original membership agreements entitled them to membership in perpetuity. The court affirmed the District Court's orders dismissing the appellants' claims. View "Fultz v. AFSCME" on Justia Law

Appellant Gilroy St. Patrick Stewart was pulled over by Trooper George Tessitore for driving a vehicle with heavily tinted windows and a partially obstructed license plate, both violations of the Pennsylvania Vehicle Code. The United States Court of Appeals for the Third Circuit had to determine whether the officer unconstitutionally prolonged the traffic stop, thereby violating Stewart's Fourth Amendment rights.Upon pulling over Stewart, Tessitore asked for his driver's license and the vehicle’s registration. Stewart produced an Ohio driver's license and a vehicle that was registered to a Hazel Sparkes of Baldwin, New York. Stewart claimed the vehicle belonged to his aunt. Tessitore then questioned Stewart about his travel plans. During the stop, Tessitore discovered that Stewart had a history of arrests, including a money laundering arrest made by the Drug Enforcement Agency. Tessitore also noted that Stewart was driving on I-80, a well-known drug trafficking corridor, and that there was an air freshener hanging from Stewart's rear-view mirror, often used to mask the smell of narcotics.Stewart was subsequently charged with possession of five kilograms or more of cocaine with intent to distribute, after 20 kilograms of cocaine were found in a hidden compartment in his vehicle. Stewart moved to suppress the cocaine as the fruit of an unlawful search, a motion that was denied by the District Court.Upon review, the Court of Appeals held that the officer had reasonable suspicion of criminal activity when he extended the length of the stop, due to a combination of factors including Stewart's evasive and inconsistent answers, the darkly tinted car windows, the car's registration to a third party, Stewart's prior arrests, his travel along a known drug corridor, and the air freshener in his vehicle. As such, the officer did not unconstitutionally prolong the traffic stop, and Stewart's Fourth Amendment rights were not violated. The Court affirmed the District Court’s order denying Stewart's motion to suppress evidence from the traffic stop. View "USA v. Stewart" on Justia Law

This case involves Vertiv, Inc., Vertiv Capital, Inc., and Gnaritis, Inc., Delaware corporations, who sued Wayne Burt, PTE Ltd., a Singaporean corporation, for defaulting on a loan. Vertiv sought damages and a declaratory judgment. Later, Wayne Burt informed the court that it was in liquidation proceedings in Singapore and moved to vacate the judgments against it. The District Court granted the motion and vacated the judgments, reopening the cases. Wayne Burt then moved to dismiss Vertiv’s claims, either on international comity grounds in deference to the ongoing liquidation proceedings in Singapore, or due to a lack of personal jurisdiction. The District Court granted Wayne Burt’s motion to dismiss, concluding that extending comity to the Singaporean court proceedings was appropriate.On appeal, the United States Court of Appeals for the Third Circuit vacated the District Court's decision and remanded the case. The court clarified the standard to apply when deciding whether to abstain from adjudicating a case in deference to a pending foreign bankruptcy proceeding. The court held that a U.S. civil action is “parallel” to a foreign bankruptcy proceeding when: (1) the foreign bankruptcy proceeding is ongoing in a duly authorized tribunal while the civil action is pending in the U.S. court; and (2) the outcome of the U.S. civil action may affect the debtor’s estate. The court also held that a party seeking the extension of comity must show that (1) “the foreign bankruptcy law shares the U.S. policy of equal distribution of assets,” and (2) “the foreign law mandates the issuance or at least authorizes the request for the stay.” If a party makes a prima facie case for comity, the court should then determine whether extending comity would be prejudicial to U.S. interests. If a U.S. court decides to extend comity to a foreign bankruptcy proceeding, it should ordinarily stay the civil action or dismiss it without prejudice. View "Vertiv Inc. v. Wayne Burt PTE Ltd" on Justia Law

In the case before the United States Court of Appeals for the Third Circuit, the appellant, Narsan Lingala, was charged with four counts related to the attempted murder of his ex-wife. On appeal, Lingala argued that the District Court made jurisdictional, procedural, constitutional, and evidentiary errors. The Court of Appeals disagreed and affirmed the conviction. Lingala had argued that federal agents had improperly manufactured federal jurisdiction to prosecute a primarily local crime, but the Court of Appeals found that Lingala himself had initiated interstate travel and used facilities of interstate commerce, which satisfied the jurisdictional element of the statute. Lingala also argued that the District Court should have severed the murder-for-hire counts from the witness tampering counts, but the Court of Appeals found that these charges were connected in a common scheme or plan. Furthermore, Lingala argued that the prosecution team should have been disqualified because they had access to documents seized from Lingala, but the Court of Appeals found that Lingala could not show that the prosecution team had relied on these documents. Finally, Lingala argued that letters he had written to his co-conspirator were inadmissible, but the Court of Appeals found that these letters were properly authenticated, not unfairly prejudicial, and not in violation of the Confrontation Clause or hearsay rules. As a result, the Court of Appeals affirmed Lingala's conviction. View "USA v. Lingala" on Justia Law

The United States Court of Appeals for the Third Circuit denied petitions from energy generators and state utility commissions challenging the Federal Energy Regulatory Commission's (FERC) acceptance of a tariff filed by PJM Interconnection, L.L.C. The court held that FERC's constructive acceptance of the tariff was neither arbitrary nor capricious and was supported by substantial evidence in the record. The tariff, filed under Section 205 of the Federal Power Act (FPA), sought to change the Minimum Offer Price Rule (MOPR) used in interstate capacity auctions. The MOPR is designed to prevent the exercise of monopsony power by net buyers in the market. The new tariff would mitigate offers only where a capacity resource has the ability and incentive to exercise buyer-side market power or where a capacity resource receives state subsidies under a state program that is likely preempted by the FPA. The petitioners argued that the tariff was unjust, unreasonable, and discriminatory. They also argued that the FERC failed to adequately address potential reliance interests and unlawfully discriminates against competitive power suppliers. The court rejected these claims and upheld FERC's acceptance of the tariff. View "PJM Power Providers Group v. Federal Energy Regulatory Commission" on Justia Law

In a consolidated action before the United States Court of Appeals for the Third Circuit, several parties, including PJM Power Providers Group, Electric Power Supply Association, and Pennsylvania Public Utility Commission, challenged a tariff filed by PJM Interconnection, L.L.C., concerning energy resources subject to price mitigation in interstate capacity auctions. The revised tariff, which took effect by operation of law in 2021, was the outcome of a deadlock between the Federal Energy Regulatory Commission (FERC) commissioners. The court found that the deadlock was to be treated as an affirmative order by the FERC, allowing for judicial review under Section 205(g) of the Federal Power Act (FPA). The court held that it was required to review the FERC order under the same deferential standards set forth in the FPA and the Administrative Procedure Act. The court’s review included the entire record, including the deadlock commissioners' written statements explaining their reasoning. Upon review, the court denied all three petitions, holding that FERC’s acceptance of PJM’s tariff was neither arbitrary nor capricious and was supported by substantial evidence in the record. View "Electric Power Supply Associat v. FERC" on Justia Law

In this consolidated action, the United States Court of Appeals for the Third Circuit reviewed a case concerning the Federal Energy Regulatory Commission's (FERC) acceptance of a tariff filed by PJM Interconnection, L.L.C. (PJM), which took effect by operation of law in 2021. The tariff was at the center of a dispute over whether state-subsidized energy resources should be subject to price mitigation in interstate capacity auctions. Petitioners – the PJM Power Providers Group (P3), the Electric Power Supply Association (EPSA), and the Pennsylvania Public Utility Commission and Public Utilities Commission of Ohio (State Entities) – sought review under Section 205(g) of the Federal Power Act (FPA), a provision allowing for review of FERC's action by inaction. The court held that its review of FERC action, whether actual or constructive, proceeds under the same deferential standards set forth in the FPA and Administrative Procedure Act. The court further held that its review properly encompasses the Commissioners’ statements setting forth their reasons for approving or denying the tariff filing. After reviewing the petitions, the court denied all three, finding FERC’s acceptance of PJM’s tariff was neither arbitrary nor capricious and was supported by substantial evidence in the record. View "Pennsylvania Public Utility Co v. FERC" on Justia Law

This case involves the bankruptcy of FTX Trading Ltd., a multibillion-dollar cryptocurrency company that suffered a severe financial collapse. The collapse triggered criminal investigations revealing fraud and embezzlement of customers' funds, leading to the conviction of Samuel Bankman-Fried, FTX's primary owner. Following the financial collapse, the United States Trustee requested the appointment of an examiner to investigate FTX's management as per 11 U.S.C. § 1104(c)(2). The Bankruptcy Court denied the motion, interpreting the appointment of an examiner as discretionary under the statute.The United States Court of Appeals for the Third Circuit reversed the lower court's decision. The Appellate Court held that the appointment of an examiner under 11 U.S.C. § 1104(c)(2) is mandatory when requested by the U.S. Trustee or a party in interest, and if the debtor's total fixed, liquidated, unsecured debt exceeds $5 million. The Court based its decision on the plain text of the statute, ruling that the word "shall" in the statute creates an obligation impervious to judicial discretion. The Court also held that the phrase "as is appropriate" in Section 1104(c) refers to the nature of the investigation and not the appointment of the examiner. The case was remanded with instructions to order the appointment of an examiner. View "FTX Trading, Ltd. v. Vara" on Justia Law

In a case involving the Second Amendment rights of 18-to-20-year-olds in Pennsylvania, the United States Court of Appeals for the Third Circuit ruled that these individuals are included in "the people" whose right to bear arms is protected under the Second Amendment. The plaintiffs, including three individuals who were aged 18 to 20 when the case was filed, along with two gun rights organizations, challenged Pennsylvania's statutory scheme that effectively bans 18-to-20-year-olds from carrying firearms outside their homes during a state of emergency. The Court found that the term "the people" in the Second Amendment presumptively encompasses all adult Americans, including 18-to-20-year-olds, and there was no founding-era law that supported disarming this age group. The Court reversed the District Court's decision dismissing the case and denying the plaintiffs' request for preliminary injunctive relief, and remanded the case with instructions to enter an injunction forbidding the Commissioner of the Pennsylvania State Police from arresting law-abiding 18-to-20-year-olds who openly carry firearms during a state of emergency declared by the Commonwealth. View "Lara v. Commissioner PA State Police" on Justia Law

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