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

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

Joseph Johnson was convicted of making a false statement and aggravated identity theft after he used a lawyer’s signature without consent to file an exhibit in federal court. This exhibit accused a plaintiff in a separate case of underreporting taxable income. The government prosecuted Johnson, and a jury convicted him. However, the United States Court of Appeals for the Third Circuit later vacated his conviction, finding that the government failed to prove the materiality of Johnson’s false statement.Johnson then sought compensation under 28 U.S.C. § 1495, which requires proving that he did not cause his own prosecution through misconduct or neglect. The United States District Court for the Eastern District of Pennsylvania denied his petition, concluding that Johnson’s use of the lawyer’s signature was misconduct that directly led to his prosecution.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court’s decision. The Third Circuit held that Johnson’s misconduct was a but-for cause of his prosecution, meaning that if he had not filed the exhibit using the lawyer’s signature, the government would not have prosecuted him. Therefore, Johnson could not satisfy the requirement under 28 U.S.C. § 2513(a)(2) that he did not cause his own prosecution by misconduct or neglect. The court emphasized that the statutory language did not incorporate proximate causation principles and that Johnson’s actions directly led to his prosecution. Consequently, Johnson was not entitled to a certificate of innocence or compensation. View "USA v. Johnson" on Justia Law

In 2016, John O. Kalu, an inmate at FCI Allenwood, alleged that he was sexually assaulted on three separate occasions by Lieutenant K. Middernatch. Kalu reported the first two incidents to Warden Spaulding, who responded that he would investigate but took no further action. Following his report, Kalu was placed in the Special Housing Unit (SHU) and later returned to the general population, where he was assaulted a third time. Kalu also claimed that he was subjected to inhumane conditions of confinement, including being forced to sleep on a cold metal bunk in freezing temperatures without adequate clothing.Kalu filed a pro se complaint in the Middle District of Pennsylvania against Warden Spaulding and Lt. Middernatch, seeking damages under Bivens for violations of his Eighth Amendment rights. The District Court dismissed Kalu’s claims against Warden Spaulding for lack of personal involvement but allowed the sexual assault claim against Lt. Middernatch to proceed. Kalu later amended his complaint, but the District Court ultimately dismissed all claims, determining that they presented new Bivens contexts and that special factors counseled against extending Bivens remedies.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court’s dismissal. The court held that Kalu’s Eighth Amendment sexual assault and conditions-of-confinement claims presented new Bivens contexts. It found that special factors, including the availability of alternative remedies through the Bureau of Prisons’ Administrative Remedy Program, Congress’s omission of a standalone damages remedy in the Prison Litigation Reform Act (PLRA) and the Prison Rape Elimination Act (PREA), and separation of powers principles, counseled against extending Bivens liability. The court also agreed that Kalu’s complaint failed to allege sufficient facts to establish a plausible claim against Warden Spaulding for deliberate indifference or failure to protect. View "Kalu v. Spaulding" on Justia Law

Rose McAvoy, an undergraduate student at Dickinson College, alleged that the college violated Title IX and breached its contract by failing to respond adequately to her sexual assault claim. McAvoy reported that she was sexually assaulted by a fellow student, TS, in October 2017. She initially did not disclose TS's name but later requested a formal Title IX investigation in December 2017. Dickinson initiated an investigation, issued a no-contact directive, and provided McAvoy with various accommodations and support services.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of Dickinson College. The court found that McAvoy failed to produce sufficient evidence that Dickinson acted with deliberate indifference under Title IX and did not show sufficient evidence of breach of contract damages. The court noted that Dickinson's response, including the investigation and accommodations provided, was not clearly unreasonable under the circumstances.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit held that Dickinson's actions, including the thorough investigation and the support provided to McAvoy, did not constitute deliberate indifference. The court emphasized that the investigation's length, while longer than the college's sixty-day objective, was justified by the need for thoroughness and fairness. Additionally, the court found no evidence that the lack of written notice about the investigation's delay caused McAvoy's claimed injuries, such as encountering TS on campus or delaying her graduation.The Third Circuit concluded that Dickinson's response to McAvoy's assault claim was not clearly unreasonable and that McAvoy did not establish a causal connection between the alleged breach of contract and her damages. Therefore, the court affirmed the summary judgment in favor of Dickinson College. View "McAvoy v. Dickinson College" on Justia Law

Tony Fisher, a federal inmate, filed a lawsuit against several prison officials, alleging they were deliberately indifferent to the risk of sexual assault by another inmate, resulting in his rape. Fisher entered federal prison in 2013 and was transferred to Fort Dix, where he reported past sexual assault and harassment by other inmates. Despite these reports, prison staff did not classify him as at high risk for sexual assault. Shortly after, Fisher was raped by another inmate. Fisher claimed that a prison official, Captain Fitzgerald, discouraged him from reporting the assaults and seeking legal help, warning him of potential retaliation.The United States District Court for the District of New Jersey dismissed Fisher’s complaint, ruling it was time-barred under New Jersey’s two-year statute of limitations for personal injury actions. Fisher appealed, arguing that the statute of limitations should be tolled due to the prison official’s threats and his mental health issues.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The court held that no Bivens cause of action exists for failure to protect an inmate from another inmate’s violence, following the Supreme Court’s decision in Egbert v. Boule. The court also ruled that even if such a claim were cognizable, Fisher’s complaint was untimely. The court found that Fisher did not qualify for equitable tolling because he was transferred away from the influence of the threatening official shortly after the assaults and did not exercise due diligence in pursuing his claims. Additionally, the court held that New Jersey’s revival statute for sexual assault claims did not apply to Bivens actions. View "Fisher v. Hollingsworth" on Justia Law

David Schaffner, Jr. and Theresa Sue Schaffner filed a lawsuit against Monsanto Corporation, alleging that Monsanto violated Pennsylvania law by failing to include a cancer warning on the label of its weed-killer, Roundup. The Schaffners claimed that this omission caused Mr. Schaffner to develop non-Hodgkin’s lymphoma due to his exposure to Roundup. The case was initially filed in the Court of Common Pleas of Allegheny County, Pennsylvania, and was later removed to the United States District Court for the Western District of Pennsylvania. The Judicial Panel on Multi-District Litigation (JPML) then transferred the case to the Northern District of California for consolidated pretrial proceedings.In the Northern District of California, the MDL Court had previously ruled in similar cases that the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) did not preempt state-law tort duties to include a cancer warning on Roundup’s label. Following this precedent, the MDL Court denied Monsanto’s motion for summary judgment on preemption grounds. The case was subsequently remanded to the Western District of Pennsylvania, where the parties stipulated to a judgment in favor of the Schaffners, reserving Monsanto’s right to appeal the preemption issue.The United States Court of Appeals for the Third Circuit reviewed the case and focused on whether FIFRA preempted the Pennsylvania duty to warn. The court held that FIFRA’s preemption provision, which prohibits states from imposing labeling requirements different from those required under federal law, did preempt the state-law duty to include a cancer warning. The court reasoned that the Environmental Protection Agency (EPA) had approved Roundup’s label without a cancer warning, and FIFRA regulations require pesticide labels to conform to the EPA-approved label. Therefore, the Pennsylvania duty to warn was not equivalent to the federal requirements and was preempted by FIFRA. The Third Circuit reversed the judgment of the District Court. View "Schaffner v. Monsanto Corporation" on Justia Law

In 2015, Eddie Williams was prosecuted in Pennsylvania for crimes related to a drug dispute that resulted in one death and one serious injury. Williams, along with Rick Cannon and Akeita Harden, was implicated in the incident. Cannon pleaded guilty to twenty charges, including homicide and conspiracy, some of which named Williams as a coconspirator. During Williams's trial, his attorney misrepresented Cannon's plea, leading the judge to read Cannon's entire Criminal Information to the jury, which included references to Williams as a coconspirator.Williams was found guilty on all counts and sentenced to life imprisonment plus additional years. He filed a Post-Conviction Relief Act (PCRA) petition, arguing ineffective assistance of counsel due to his attorney's actions. The PCRA court denied relief, finding no Confrontation Clause violation and concluding that the attorney's strategy was reasonable. The Superior Court affirmed, and the Pennsylvania Supreme Court denied further appeal.Williams then filed a habeas corpus petition in the United States District Court for the Middle District of Pennsylvania, which granted relief, finding that the reading of Cannon's Criminal Information violated the Confrontation Clause and that Williams's counsel was ineffective for not objecting. The Commonwealth appealed this decision.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The court held that the reading of Cannon's Criminal Information, which included references to Williams, was testimonial and violated the Confrontation Clause. The court also found that Williams's counsel was ineffective for failing to object to the reading, which prejudiced Williams's defense. The court concluded that these errors had a substantial and injurious effect on the jury's verdict, warranting habeas relief. View "Williams v. Greene" on Justia Law

Alison George sought to represent a class and obtain damages from Rushmore Service Center, LLC, based on a letter that identified Premier Bankcard, LLC as the “current/original creditor” instead of the actual credit card company. George alleged that this violated the Fair Debt Collection Practices Act (FDCPA) by failing to identify the creditor to whom the debt was owed and providing misleading information. She claimed that this would confuse the least sophisticated consumer about the legitimacy of the debt.The United States District Court for the District of New Jersey granted Rushmore’s motion to stay proceedings and compel individual arbitration. George lost in arbitration, where the arbitrator ruled in favor of Rushmore, finding that George was not misled because she admitted she did not read the letter. The District Court then declined to vacate the arbitration award, rejecting George’s arguments that the arbitrator disregarded evidence and law.The United States Court of Appeals for the Third Circuit reviewed the case and focused on whether George had standing to sue. The court concluded that George lacked standing from the outset because her complaint did not allege any specific adverse effects or confusion she personally experienced due to the letter. The court held that confusion alone is insufficient to establish a concrete injury under Article III. Consequently, the Third Circuit vacated the District Court’s orders and remanded with instructions to dismiss the case for lack of standing. The court declined to vacate the arbitration award itself, leaving its enforceability to be determined in a jurisdictionally correct proceeding. View "George v. Rushmore Service Center LLC" on Justia Law

Delaware residents and organizations challenged two new state gun laws in federal court. One law bans the possession, manufacture, sale, and transport of "assault weapons," while the other bans magazines that hold more than seventeen rounds. The plaintiffs argued that these laws violate the Second and Fourteenth Amendments and sought a preliminary injunction to prevent their enforcement.The United States District Court for the District of Delaware consolidated three related cases and held a preliminary-injunction hearing. The plaintiffs did not present live witnesses or evidence that Delaware had attempted to enforce the laws against them. The court found that the plaintiffs were unlikely to succeed on the merits because the laws were consistent with the nation's historical tradition of firearm regulation. It also found that the plaintiffs had not demonstrated irreparable harm, as they still had access to other means of self-defense. Consequently, the court denied the preliminary injunction.The United States Court of Appeals for the Third Circuit reviewed the District Court's decision. The appellate court emphasized that a preliminary injunction is an extraordinary remedy that should not be granted automatically, even if the plaintiffs are likely to succeed on the merits. The court found that the plaintiffs had not shown irreparable harm, as they did not provide evidence that the laws were being enforced against them or that they had an urgent need for the banned firearms and magazines. The court also noted that the plaintiffs delayed seeking the injunction, which undermined their claim of urgency. The Third Circuit affirmed the District Court's denial of the preliminary injunction, stating that the plaintiffs had other avenues for prompt relief, such as an accelerated trial. View "Delaware State Sportsmens Association Inc v. Delaware Department of Safety and Homeland Security" on Justia Law

A twelve-year-old boy named Maxwell was abused and killed by his father and stepmother. His mother, Sara Coon, sued Lebanon County and several county officials, alleging that the county knew about the abuse and had a state-law duty to protect Maxwell. The complaint stated that the county's Children and Youth Services agency failed to act despite multiple warnings about the abuse.The United States District Court for the Middle District of Pennsylvania dismissed the federal claims brought under 42 U.S.C. § 1983, concluding that Pennsylvania’s Child Protective Services Law did not create a property interest in having the county agency protect Maxwell from child abuse. The court also remanded the state-law claims to state court.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that due process protects interests in life, liberty, or property, and to state a claim for violating procedural due process, a plaintiff must show a legitimate claim of entitlement to a protected property interest. The court found that Pennsylvania law did not create such a property interest in having a county agency protect a child from abuse. The court compared this case to Town of Castle Rock v. Gonzales and Burella v. City of Philadelphia, where similar statutory language did not create a property interest. Consequently, the Third Circuit affirmed the District Court’s order dismissing the federal claims and remanding the state claims to state court. View "Coon v. County of Lebanon" on Justia Law