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

A group of institutional investors brought a class action lawsuit against a pharmaceutical company and several of its officers, alleging violations of federal securities laws after the company’s share price dropped significantly following the rejection of a takeover bid and subsequent negative financial disclosures. One large investor, Sculptor, intended to pursue its own individual lawsuit rather than participate in the class action. The District Court certified the class and issued a notice specifying the procedure and deadline for class members to opt out. Although Sculptor intended to opt out, its counsel failed to submit the required exclusion request by the deadline. Both Sculptor and the company proceeded for years as if Sculptor had opted out, litigating the individual action and treating Sculptor as an opt-out plaintiff.The United States District Court for the District of New Jersey later approved a class settlement, which prompted the discovery that Sculptor had never formally opted out. Sculptor then sought to be excluded from the class after the deadline, arguing that its conduct showed a reasonable intent to opt out, that its failure was due to excusable neglect, and that the class notice was inadequate. The District Court rejected these arguments, finding that only compliance with the court’s specified opt-out procedure sufficed, that Sculptor’s neglect was not excusable under the relevant legal standard, and that the notice met due process requirements.The United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that a class member must follow the opt-out procedures established by the district court under Rule 23; a mere “reasonable indication” of intent to opt out is insufficient. The court also found no abuse of discretion in denying Sculptor’s late opt-out request and concluded that the class notice satisfied due process. View "Perrigo Institutional Investor Group v. Papa" on Justia Law

The appellant was charged, along with two others, with robbing a restaurant in Pennsylvania, in violation of federal statutes prohibiting Hobbs Act robbery and the use of firearms during a crime of violence. He pleaded guilty to both charges. At sentencing, the United States Probation Department recommended that he be classified as a career offender under the United States Sentencing Guidelines, based on two prior Pennsylvania state court robbery convictions—one in Dauphin County and one in Cumberland County. The appellant, through counsel, objected to the career offender designation, arguing that the two prior convictions should be treated as a single predicate. The United States District Court for the Middle District of Pennsylvania overruled this objection, designated him a career offender, and sentenced him to 210 months in prison.On direct appeal to the United States Court of Appeals for the Third Circuit, appellate counsel filed an Anders brief, asserting no nonfrivolous grounds for appeal. The Third Circuit affirmed the sentence and granted counsel’s motion to withdraw. The court also dismissed the appellant’s claim for relief under Johnson v. United States, finding no indication that the residual clause of the Guidelines was used in his designation. The court declined to rule on the ineffective assistance of counsel claim, noting it could be raised in a collateral proceeding. The appellant then filed a motion under 28 U.S.C. § 2255, arguing that his trial counsel was ineffective for failing to challenge whether his prior convictions qualified as crimes of violence. The District Court denied the motion without an evidentiary hearing, finding the records showed both prior convictions were for robbery under Pennsylvania law and qualified as crimes of violence.The United States Court of Appeals for the Third Circuit reviewed the denial of the § 2255 motion. The court held that the District Court did not err in finding that both prior convictions were for robbery under 18 Pa. Cons. Stat. § 3701(a)(1)(ii), which qualifies as a crime of violence under the Guidelines. The court also held that trial counsel was not ineffective for failing to challenge the career offender designation on the grounds raised. The Third Circuit affirmed the District Court’s judgment. View "USA v. Dobbin" on Justia Law

A website visitor in Pennsylvania interacted with a retail website that used session replay code provided by a third party to record her mouse movements, clicks, and keystrokes. The visitor did not enter any sensitive or personal information during her session. She later brought a putative class action against the website operator, alleging that the use of session replay code constituted intrusion upon seclusion and violated the Pennsylvania Wiretapping and Electronic Surveillance Control Act (WESCA).The United States District Court for the Western District of Pennsylvania dismissed the complaint with prejudice, finding that the plaintiff lacked Article III standing because she did not allege a concrete injury. The court reasoned that the mere recording of her website activity, which did not include any personal or sensitive information, was not analogous to harms traditionally recognized at common law, such as disclosure of private information or intrusion upon seclusion. The court also found that amendment would be futile.On appeal, the United States Court of Appeals for the Third Circuit reviewed the dismissal de novo and agreed that the plaintiff failed to allege a concrete injury sufficient for Article III standing. The Third Circuit held that the alleged harm was not closely related to the traditional privacy torts of disclosure of private information or intrusion upon seclusion, as the information recorded was neither sensitive nor publicly disclosed, and there was no intrusion into the plaintiff’s solitude or private affairs. The court also clarified that a statutory violation alone does not automatically confer standing without a concrete harm. However, the Third Circuit determined that the District Court erred in dismissing the complaint with prejudice and modified the order to a dismissal without prejudice, affirming the order as modified. View "Cook v. GameStop, Inc." on Justia Law

A consumer lender, GreatPlains Finance, LLC, owned by the Fort Belknap Indian Community, a federally recognized tribe, was sued by Rashonna Ransom for allegedly violating New Jersey consumer-protection laws. Ransom had taken out two high-interest loans from GreatPlains and claimed the lender broke several laws. GreatPlains argued it was protected by tribal sovereign immunity, as it was created by the tribe to generate revenue and was managed by a tribally owned corporation, Island Mountain Development Group.The United States District Court for the District of New Jersey denied GreatPlains' motion to dismiss, ruling that the lender was not an arm of the tribe and thus not entitled to sovereign immunity. The court based its decision partly on the control exerted by a non-tribal private-equity fund, Newport Funding, which had significant influence over GreatPlains' operations due to a loan agreement. GreatPlains' subsequent motion to reconsider was also denied, leading to this appeal.The United States Court of Appeals for the Third Circuit reviewed the case and applied a multi-factor test to determine whether GreatPlains was an arm of the tribe. The court considered factors such as the method of incorporation, the entity's purpose, tribal control, the tribe's intent to confer immunity, and the financial relationship between the tribe and the entity. The court found that while GreatPlains was created under tribal law and intended to benefit the tribe, the financial relationship was crucial. GreatPlains had not shown that a judgment against it would impact the tribe's finances, as it had not returned profits to the tribe. Consequently, the Third Circuit held that GreatPlains was not an arm of the tribe and lacked sovereign immunity, affirming the District Court's decision and remanding for further proceedings. View "Ransom v. GreatPlains Finance, LLC" on Justia Law

Brian Trematore Plumbing & Heating, Inc. (Trematore) entered into a collective bargaining agreement (CBA) with Sheet Metal Workers Local Union 25 (Local 25) for a project at High-Tech High School in Secaucus, New Jersey. The CBA, initially formed under § 8(f) of the National Labor Relations Act (NLRA), was later converted to a § 9(a) agreement when Local 25 demonstrated majority status. The CBA included an evergreen clause, automatically renewing unless terminated with notice, and a non-repudiation clause. Trematore ceased employing Local 25 members in September 2018 and later subcontracted work to non-union workers, leading to grievances and an unfair labor practice charge by Local 25.The United States District Court for the District of New Jersey denied Trematore's motion for judgment and granted Local 25's cross-motion, holding that the CBA remained in effect due to the evergreen provision and non-repudiation clause. The court found that Trematore could not repudiate the CBA under the one-employee unit rule and that the grievance regarding subcontracting was arbitrable.The United States Court of Appeals for the Third Circuit affirmed the District Court's judgment. The appellate court held that Trematore was bound by the CBA through its evergreen provision and non-repudiation clause, making its attempted repudiation ineffective. The court also held that the grievance concerning subcontracting was arbitrable, as it fell within the scope of the arbitration clause in the CBA. The court concluded that the CBA remained in effect and that Trematore was not entitled to injunctive relief. View "Brian Trematore Plumbing & Heating Co. v. Sheet Metal Workers Local Union 25" on Justia Law

A federal immigration agent, Keith Slatowski, was injured when his Sig Sauer P320 pistol fired a bullet into his hip and out his thigh during a training session. Slatowski claimed he did not touch the trigger, only the grip, and argued that the gun's design, which lacks an external safety, made it prone to accidental discharge. He sued Sig Sauer, alleging that the gun was defectively designed and that a different safety design, such as a tabbed trigger, would have prevented the accident.The United States District Court for the Eastern District of Pennsylvania excluded the causation testimony of Slatowski's two experts, Dr. James Tertin and Dr. William Vigilante, because their conclusions were based on speculation rather than reliable testing. The court allowed their testimony on the gun's design defects but granted summary judgment for Sig Sauer, reasoning that without expert testimony on causation, the jury could not determine what caused the gun to fire.The United States Court of Appeals for the Third Circuit reviewed the case. The court affirmed the District Court's exclusion of the expert testimony on causation, agreeing that the experts' conclusions were speculative. However, the Third Circuit reversed the grant of summary judgment, holding that the jury could still determine causation based on the admissible evidence and lay testimony. The court found that the jury, with the help of expert explanations of the gun's design, could understand the remaining causation question without further expert testimony. The case was remanded for trial. View "Slatowski v. Sig Sauer, Inc." on Justia Law

Roger Esteban Real, a native and citizen of Colombia, participated in protests in his home country, leading to his arrest and mistreatment by police. Fearing for his safety, he fled to the United States with his family in March 2022. Upon arrival, he surrendered to immigration authorities, who did not issue him a Notice to Appear (NTA) or inquire about his fear of returning to Colombia. He was instructed to attend a court hearing in 2025 and to check in regularly using a cell phone provided by the authorities.Real was later arrested for crimes related to a domestic dispute, and two months after this arrest, the Department of Homeland Security (DHS) issued him an NTA. An Immigration Judge (IJ) found him removable and, in July 2023, Real applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The IJ granted him withholding of removal but denied his asylum application, citing his failure to meet the one-year filing deadline and lack of extraordinary circumstances to excuse the delay. The Board of Immigration Appeals (BIA) dismissed his appeal, agreeing with the IJ's findings.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the government's failure to notify Real of the one-year asylum application deadline did not constitute a due process violation. Additionally, the court determined that it lacked jurisdiction to review Real's claim of extraordinary circumstances excusing his late filing, as such determinations are discretionary and not subject to judicial review. Consequently, the court denied the petition in part and dismissed it in part. View "Real v. Attorney General" on Justia Law

Juan Montas, a citizen of the Dominican Republic, entered the United States as a toddler in 1996. In 2017, he was convicted in the U.S. District Court for the District of New Jersey for conspiracy to distribute heroin and was subsequently deported in 2020. Montas reentered the U.S. illegally before April 2023 and was arrested by New Jersey State Police for possession of a false driver’s license, drug offenses, and money laundering. He pled guilty in 2023 to illegally reentering the United States.The U.S. District Court for the District of New Jersey sentenced Montas in 2024. During the sentencing, the court relied on the Presentence Investigation Report (PSR) and the hearing transcript from Montas’s 2017 sentencing without prior notice to Montas or his counsel. Montas’s counsel did not object to this reliance during the sentencing. The court imposed a 34-month imprisonment sentence, noting Montas’s previous statements and actions from the 2017 sentencing.Montas appealed to the United States Court of Appeals for the Third Circuit, arguing that the District Court violated Federal Rule of Criminal Procedure 32 by relying on information from the 2017 sentencing without prior notice. The Third Circuit reviewed the issue for plain error since Montas did not raise the objection in the lower court. The Third Circuit found that the District Court erred and that the error was clear. However, Montas failed to demonstrate that the error affected his substantial rights, as he could not show that the sentence would have been different with proper notice. Consequently, the Third Circuit affirmed the sentence. View "USA v. Montas" on Justia Law

Sun Valley Orchards, a New Jersey farm, was accused by the U.S. Department of Labor (DOL) of breaching an employment agreement under the H-2A nonimmigrant visa program. The DOL alleged that Sun Valley failed to provide adequate housing, meal plans, transportation, and guaranteed work hours to its workers, as stipulated in the job order. The DOL imposed civil penalties and back wages totaling hundreds of thousands of dollars through administrative proceedings.The case was first reviewed by an Administrative Law Judge (ALJ), who affirmed most of the DOL's findings but slightly modified the penalties and back wages. Sun Valley then appealed to the Administrative Review Board, which upheld the ALJ's decision. Subsequently, Sun Valley challenged the DOL's decision in the United States District Court for the District of New Jersey, arguing that the administrative proceedings violated Article III of the Constitution, among other claims. The District Court dismissed Sun Valley's claims, holding that the DOL's actions fit within the public-rights doctrine and that the agency had statutory authority to impose penalties and back wages.The United States Court of Appeals for the Third Circuit reviewed the case and held that Sun Valley was entitled to have its case decided by an Article III court. The court found that the DOL's enforcement action resembled a common law breach of contract suit, which traditionally would be heard in a court of law. The court also determined that the case did not fit within the public rights exception to Article III adjudication, as the H-2A labor certification regulations primarily concern domestic employment law rather than immigration control. Consequently, the Third Circuit reversed the District Court's decision and remanded the case with instructions to enter judgment in favor of Sun Valley. View "Sun Valley Orchards LLC v. United States Department of Labor" on Justia Law

Safehouse, a Pennsylvania nonprofit corporation, was established in 2018 to address opioid abuse in Philadelphia by providing overdose prevention services, including supervised illegal drug use. Safehouse argues that its activities are motivated by a religious belief in the value of human life and that government intervention substantially burdens its religious exercise.The United States District Court for the Eastern District of Pennsylvania initially determined that Safehouse’s proposed activities did not violate 21 U.S.C. § 856(a)(2). However, the Third Circuit Court of Appeals reversed this decision, holding that Safehouse’s activities would indeed violate the statute. On remand, the District Court dismissed Safehouse’s Religious Freedom Restoration Act (RFRA) and Free Exercise counterclaims, reasoning that non-religious entities are not protected by these provisions. Safehouse appealed this dismissal.The United States Court of Appeals for the Third Circuit reviewed the case and held that the District Court erred in its interpretation. The Third Circuit determined that RFRA and the Free Exercise Clause extend protections to non-natural persons, including non-religious entities like Safehouse. The court emphasized that RFRA’s plain text and Free Exercise doctrine protect any “person” exercising religion, which includes corporations and associations. The court reversed the District Court’s dismissal of Safehouse’s RFRA and Free Exercise counterclaims and remanded the case for further consideration of whether Safehouse has plausibly pleaded these claims. The appeal by José Benitez, President of Safehouse, was dismissed due to lack of appellate standing. View "United States v. Safehouse" on Justia Law