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

Plaintiffs Tommy Coleman and Jason Perkins, who worked as oil and gas pipeline inspectors for System One Holdings, LLC, were paid a flat daily rate without overtime compensation, even when working over forty hours a week. They filed a lawsuit claiming this violated the Fair Labor Standards Act (FLSA) and sought unpaid overtime on behalf of themselves and a putative class of similarly compensated inspectors.The United States District Court for the Western District of Pennsylvania reviewed the case. System One moved to dismiss and compel arbitration, arguing that the plaintiffs had signed arbitration agreements enforceable under the Federal Arbitration Act (FAA). The plaintiffs countered that they fell under the transportation workers' exemption to the FAA. The District Court, following the precedent set in Guidotti v. Legal Helpers Debt Resolution, L.L.C., ordered limited discovery into the arbitrability of the claims before deciding on the motion to compel arbitration. System One's motion for reconsideration of this order was denied.The United States Court of Appeals for the Third Circuit reviewed the case to determine if it had jurisdiction over the interlocutory appeal from the District Court's order. The Third Circuit held that it lacked appellate jurisdiction because the District Court's order did not formally deny the motion to compel arbitration but rather deferred its decision pending limited discovery. The court emphasized that the FAA permits appeals from specific types of orders, and the order in question did not fall within those categories. Consequently, the appeal was dismissed for lack of jurisdiction. View "Coleman v. System One Holdings LLC" on Justia Law

In 2020, Christopher Lamont Stimpson, Jr. contacted Benuel Stoltzfus, an Amish man in Lancaster County, Pennsylvania, to purchase five French bulldog puppies for $23,500. On the day of the sale, Stimpson and his associate, Wilbert Artis, visited the Stoltzfus home. After inspecting the puppies, Stimpson agreed to the purchase, but before the money count was complete, Artis took the puppies to their vehicle. A struggle ensued when Stimpson attempted to leave with the cash, during which he allegedly brandished a handgun. Stimpson and Artis fled with the puppies and most of the cash, leaving the Stoltzfus family with $4,140.The United States District Court for the Eastern District of Pennsylvania convicted Stimpson of Hobbs Act robbery and interstate transportation of stolen goods. Stimpson filed a motion to suppress evidence obtained from search warrants on social media accounts, arguing they were overbroad and lacked probable cause. The District Court denied the motion, but the government did not use the evidence obtained from the warrants at trial. Stimpson was convicted by a jury without the suppressed evidence.The United States Court of Appeals for the Third Circuit reviewed the case. Stimpson appealed the denial of his suppression motion and the application of a sentencing enhancement under USSG §2B3.1(b)(2)(D) for using a dangerous weapon. The Third Circuit found the suppression issue moot since the evidence was not used at trial. The court also upheld the sentencing enhancement, concluding that the District Court did not err in finding by a preponderance of the evidence that Stimpson used a dangerous weapon during the robbery.The Third Circuit affirmed Stimpson’s conviction and sentence. View "USA v. Stimpson" on Justia Law

Judith Maureen Henry was mistakenly arrested on a warrant intended for another woman with the same name who had skipped parole in Pennsylvania. The warrant included Henry's home address and driver’s license photo. Henry was detained for over two weeks, despite her repeated claims of innocence and requests for fingerprint comparison. She was eventually released after Pennsylvania officials confirmed her fingerprints did not match those of the actual parole violator.The United States District Court for the District of New Jersey reviewed the case and denied a motion to dismiss filed by six deputy United States Marshals. The Marshals argued for qualified immunity, claimed that Henry could not pursue her claims under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, and contended that her complaint failed to state a claim. The District Court rejected these arguments, citing a need for further factual development.The United States Court of Appeals for the Third Circuit reviewed the case and reversed the District Court’s decision. The Third Circuit held that Henry’s claims presented a new context under Bivens, as her arrest was based on a valid warrant and her mistaken-identity arrest was constitutionally valid. The court found that the Marshals’ actions did not violate the Fourth Amendment and that Henry’s other claims, including those for failure to investigate her innocence and failure to present her to a magistrate, also presented a new context. The court concluded that separation of powers concerns precluded extending Bivens to this new context. Additionally, Henry’s claims under 42 U.S.C. § 1985(3) and the New Jersey Civil Rights Act were dismissed, as she failed to provide sufficient factual allegations of discriminatory animus and the Westfall Act barred her NJCRA claim. The Third Circuit remanded the case for dismissal of Henry’s claims against the Marshals. View "Henry v. Essex County" on Justia Law

A ten-year-old girl named Nylah Anderson died after attempting the "Blackout Challenge," a dangerous activity promoted in a video recommended to her by TikTok's algorithm. Her mother, Tawainna Anderson, sued TikTok and ByteDance, Inc., alleging that the companies were aware of the challenge, allowed such videos to be posted, and promoted them to minors, including Nylah, through their algorithm.The United States District Court for the Eastern District of Pennsylvania dismissed the complaint, ruling that TikTok was immune under Section 230 of the Communications Decency Act (CDA), which protects interactive computer services from liability for content posted by third parties. The court found that TikTok's role in recommending the video fell under this immunity.The United States Court of Appeals for the Third Circuit reviewed the case and reversed the District Court's decision in part, vacated it in part, and remanded the case. The Third Circuit held that TikTok's algorithm, which curates and recommends videos, constitutes TikTok's own expressive activity, or first-party speech. Since Section 230 of the CDA only provides immunity for third-party content, it does not protect TikTok from liability for its own recommendations. Therefore, the court concluded that Anderson's claims were not barred by Section 230, allowing the lawsuit to proceed. View "Anderson v. TikTok Inc" on Justia Law

Fernando Nunez, Jr., an inmate in Pennsylvania, filed a lawsuit against officials of the Pennsylvania Department of Corrections (DOC) under the Religious Land Use and Institutionalized Persons Act (RLUIPA). Nunez, a devout Muslim, claimed that the DOC violated his religious rights by denying him accommodations to consummate his marriage and have ongoing conjugal visits, engage in congregate prayer with visitors, and undergo a religious circumcision.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the DOC. The court concluded that the DOC had compelling interests in denying Nunez's requests and that there were no less restrictive alternatives available. The court relied on affidavits from DOC officials, which cited concerns about safety, security, health, and resource constraints. The court found that Nunez failed to disprove that the DOC's policies were the least restrictive means of furthering these interests.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court did not properly hold the DOC to its burden under RLUIPA. The Third Circuit concluded that the DOC failed to provide sufficient evidence to support its claims of compelling interests and did not adequately consider less restrictive alternatives. The court emphasized that RLUIPA requires a rigorous and fact-intensive inquiry and that the DOC's "mere say-so" was insufficient to meet this standard. The Third Circuit vacated the District Court's judgment and remanded the case for further proceedings, allowing the DOC to supplement the record to meet its burden under RLUIPA. View "Nunez v. Wolf" on Justia Law

Gary Lall, born in Trinidad and Tobago, applied for a Certificate of Citizenship in 1990 through his adoptive parents, who were naturalized U.S. citizens. The government erroneously approved his application after he turned eighteen, issuing a certificate stating he "became a citizen." However, Lall had not met the statutory requirements for citizenship. The error was discovered shortly after issuance, but the government waited twenty-one years to cancel the certificate. Lall, incarcerated at the time, filed a declaratory judgment action seeking recognition of his citizenship.The United States District Court for the Western District of Pennsylvania dismissed Lall's declaratory judgment action, finding he never obtained citizenship. Concurrently, the government initiated removal proceedings, and an Immigration Judge (IJ) ordered Lall's removal, rejecting his claim to citizenship. Lall appealed both the District Court's dismissal and the IJ's removal order.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that Lall never satisfied the statutory requirements for citizenship under the relevant sections of the Immigration and Nationality Act (INA) as they existed in 1991. The court emphasized that a Certificate of Citizenship is only prima facie evidence of citizenship and does not confer citizenship if statutory requirements are unmet. The court also ruled that equitable estoppel could not be used to confer citizenship, as courts lack the power to grant citizenship contrary to statutory requirements. Consequently, the Third Circuit affirmed the District Court's dismissal of Lall's declaratory judgment action and denied his petition for review of the IJ's removal order. View "Lall v. USICE" on Justia Law

A man was convicted of first-degree murder and sentenced to death for the killing of a police officer. The incident occurred during a traffic stop, where the officer was shot multiple times. The defendant was apprehended shortly after the shooting, and a firearm matching the bullets found at the scene was recovered from his vehicle. The defendant claimed he acted in self-defense, believing the officer was about to shoot him.The trial court, the Superior Court of California, found the defendant guilty and imposed the death penalty. The defendant appealed the conviction and sentence, arguing that the trial court made several errors, including improper jury instructions and the exclusion of certain evidence that could have supported his self-defense claim. The California Court of Appeal affirmed the conviction and sentence, rejecting the defendant's arguments. The defendant then sought review from the California Supreme Court.The California Supreme Court reviewed the case and upheld the lower court's decision. The court found that the trial court did not err in its jury instructions and that the exclusion of the evidence in question did not prejudice the defendant's case. The court also held that the evidence presented at trial was sufficient to support the conviction and the imposition of the death penalty. The court concluded that the defendant's actions were not justified as self-defense and that the killing of the officer was premeditated and deliberate. The conviction and death sentence were affirmed. View "USA v. Clark" on Justia Law

Cornelius Green, a member of the Infamous Ryders motorcycle club, was involved in an incident where Ishmael Snowell, who had declined membership in the club, was allegedly kidnapped. Green, along with co-defendant William Murphy and Steven Wong, met Snowell at the club's clubhouse. A fight ensued between Snowell and Murphy, with Green refereeing. Wong discovered photos of money on Snowell’s phone and demanded to know its location. Snowell claimed the money was at his aunt’s house in Reading, Pennsylvania. Murphy drove Snowell and Green, who was armed, to the house. Testimonies diverged on whether Murphy and Snowell could have escaped during a stop at a gas station. Upon arrival, they searched for the money, and Snowell claimed Wong ordered Green to shoot him. Snowell attempted to escape, leading to a fight with Green, which ended when neighbors called the police.The grand jury indicted Green, Murphy, and Wong for kidnapping and robbery. Green moved to sever his trial from Murphy and Wong, but the District Court denied the motion. Wong’s trial was later severed due to a change in attorneys, and he was acquitted. During the joint trial of Green and Murphy, Murphy testified that Wong coerced him into the kidnapping and that Green threatened Snowell with a gun. Green renewed his motion to sever, arguing that Murphy’s defense was antagonistic to his own, but the District Court denied it.The United States Court of Appeals for the Third Circuit reviewed the case and found that Green and Murphy presented mutually antagonistic defenses, which prejudiced Green’s right to a fair trial. The court held that the District Court abused its discretion in denying Green’s motion to sever. Consequently, the Third Circuit reversed the denial of the motion to sever, vacated Green’s conviction and sentence, and remanded for further proceedings. View "USA v. Green" on Justia Law

In 2001, the Commonwealth charged Robert Gene Rega with first-degree murder and other crimes for shooting a security guard, Christopher Lauth, during a robbery at the Gateway Lodge in Jefferson County, Pennsylvania. Rega, along with Shawn Bair, Raymond Fishel, and Stanford Jones, planned the robbery, while Jones’s wife, Susan, stayed at Rega’s home. During the robbery, Lauth was killed. The prosecution's case relied heavily on the testimonies of Bair, Fishel, and the Joneses, who identified Rega as the shooter. Additional evidence included a video of Rega purchasing ammunition and testimony from a friend that Rega asked for a false alibi.The Pennsylvania state court convicted Rega of first-degree murder and sentenced him to death. Rega's conviction and sentence were upheld on direct appeal and in a Post-Conviction Relief Act (PCRA) proceeding. Rega then filed a federal habeas petition. The United States District Court for the Western District of Pennsylvania denied his guilt-phase claims but granted relief from his death sentence, ordering a new sentencing hearing or life imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. Rega raised claims that the prosecutor withheld evidence in violation of Brady v. Maryland and presented false testimony in violation of Giglio v. United States and Napue v. Illinois. The Third Circuit affirmed the denial of relief on these claims, concluding that the evidence and testimony in question were not material to Rega’s murder conviction. The court found that the prosecutor’s noncommittal statements to witnesses about considering their cooperation in future plea deals did not significantly undermine their credibility, as the jury was already aware of their potential motives. Additionally, evidence of Susan Jones’s memory problems was deemed not material, as it did not sufficiently undermine her testimony or the overall case against Rega. View "Rega v. Secretary Pennsylvania Department of Corrections" on Justia Law

A Philadelphia police officer stopped Sunny Sok for making an illegal right turn. During the stop, the officer discovered that Sok's vehicle had an expired registration and mistakenly believed there was an active arrest warrant for Sok. The officer arrested Sok and claimed to smell marijuana from the vehicle, leading to a search that uncovered narcotics and a firearm. Sok was charged with drug and firearm offenses and moved to suppress the evidence, arguing the search was unlawful.The United States District Court for the Eastern District of Pennsylvania held a suppression hearing and found the officer's testimony about the marijuana odor not credible, thus ruling there was no probable cause for the search. However, the court denied Sok's motion to suppress, concluding that the evidence would have been inevitably discovered under Philadelphia’s Live Stop Policy, which mandates impounding unregistered vehicles and conducting inventory searches.Sok appealed to the United States Court of Appeals for the Third Circuit, arguing that the inevitable-discovery doctrine should not apply because the Government did not prove that impoundment of his vehicle was lawful or inevitable under the Live Stop Policy. The Third Circuit noted that Sok failed to raise these arguments in the District Court and thus could not consider them unless Sok showed good cause for the failure. The court found that Sok did not demonstrate good cause, as his counsel's misunderstanding of the law did not suffice. Consequently, the Third Circuit affirmed the District Court's judgment, upholding Sok's conviction and sentence. View "United States v. Sok" on Justia Law