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

A Mexican national who entered the United States without authorization in 2000 was detained by the Department of Homeland Security in 2023 and charged as removable. Between 2019 and 2021, he was arrested and convicted of multiple offenses, including several DUIs in different states. He conceded removability and applied for asylum, withholding of removal, protection under the Convention Against Torture (CAT), and later, cancellation of removal. At his hearing, the Immigration Judge (IJ) declined to hear live testimony from his wife and psychologist, relying instead on their written reports and other documentary evidence. The IJ denied all forms of relief, finding, among other things, that his DUI convictions precluded a finding of good moral character and that he failed to show his removal would cause his wife exceptional and extremely unusual hardship.On appeal, the Board of Immigration Appeals (BIA) dismissed his appeal. The BIA found that he had waived his challenges to the denial of asylum, withholding of removal, and CAT protection by failing to raise them in his notice of appeal or briefing, rendering those claims unexhausted. The BIA also agreed with the IJ that his multiple DUI convictions established a lack of good moral character, making him ineligible for cancellation of removal. The BIA rejected his due process claim, concluding he had received a full and fair hearing.The United States Court of Appeals for the Third Circuit reviewed both the IJ’s and BIA’s decisions. The court held that it lacked jurisdiction to review the unexhausted claims for asylum, withholding, and CAT protection. Regarding cancellation of removal, the court found that substantial evidence supported the finding that the petitioner lacked good moral character and that he failed to show prejudice from the exclusion of live witness testimony. The court dismissed the petition in part and denied it in part. View "Sanchez v. Attorney General" on Justia Law

A Guatemalan citizen who had been present in the United States since 2007 conceded removability for entering the country without admission or parole. He applied for cancellation of removal, which requires, among other things, at least ten years of continuous physical presence and a qualifying U.S. citizen relative who would suffer “exceptional and extremely unusual hardship” if he were removed. The Immigration Judge found that he met the good moral character and criminal history requirements but concluded he had not established the necessary continuous presence or that his U.S. citizen son was a qualifying relative, partly due to lack of documentation. The judge also found that, even if the son qualified, the hardship did not exceed what is ordinarily expected from a parent’s removal.The petitioner appealed to the Board of Immigration Appeals (BIA), which affirmed the Immigration Judge’s findings regarding the qualifying relative and hardship, dismissing the appeal. After the Immigration Judge’s decision but before the BIA’s decision, the petitioner’s U.S. citizen daughter was born. Following the BIA’s dismissal, he moved to reopen his case, arguing that his daughter’s birth was new evidence supporting his eligibility for relief. The BIA denied the motion, reasoning that the daughter’s birth was not “new” evidence because it occurred while the appeal was pending, and also found insufficient evidence of hardship. A motion for reconsideration was also denied, with the BIA reiterating its interpretation of “former hearing” and again finding no exceptional hardship.The United States Court of Appeals for the Third Circuit reviewed only the denial of the motion for reconsideration. The court held that “new” evidence for a motion to reopen is evidence unavailable at the last hearing before the Immigration Judge, not before the BIA. However, because the BIA considered the new evidence and found it insufficient, the court found the BIA’s error harmless and denied the petition for review. View "Suchite-Salguero v. Attorney General United States of America" on Justia Law

Paul Harmon, who had worked for decades as an accountant and controller at a family-owned electrical engineering firm, embezzled over a million dollars from the company. His actions led to significant financial losses for the business and its employees, including legal and accounting costs, overpaid taxes, and the eventual closure of the company. The president of the company detailed these hardships in a victim impact statement and letter submitted at Harmon’s sentencing.After Harmon pled guilty to wire fraud in the United States District Court for the Western District of Pennsylvania, the court imposed an upwardly varied sentence of 72 months, citing the severe impact of his crimes on the victims and the business. The presentence report and the government did not recommend, and the court did not apply, a sentencing enhancement for causing “substantial financial hardship.” In 2024, Harmon sought a sentence reduction under 18 U.S.C. § 3582(c)(2) based on a new, retroactive Sentencing Guideline provision, U.S.S.G. § 4C1.1, which excludes defendants who caused substantial financial hardship. The government did not oppose the motion. The District Court denied the reduction, relying on the earlier victim impact materials to find Harmon ineligible, and did not provide him an opportunity to contest those materials at this stage.The United States Court of Appeals for the Third Circuit reviewed the case. It held that due process protections under U.S.S.G. § 6A1.3(a)—requiring notice and an opportunity to contest new information—apply to sentence reduction motions under § 3582(c)(2). However, the court concluded that the victim impact statement and letter were not “new information” because they had already been relied upon at the original sentencing to find material facts. Therefore, the Third Circuit affirmed the District Court’s denial of Harmon’s motion for a sentence reduction. View "USA v. Harmon" on Justia Law

A Pennsylvania prisoner sentenced to death sought to reopen his federal habeas corpus proceedings to present expert evidence obtained in 1999, which he argued would support his claim that he was incompetent at the time of his guilty plea and sentencing. This evidence was not presented during his initial state postconviction proceedings due to his counsel’s alleged ineffectiveness. The prisoner contended that a subsequent Supreme Court decision, Martinez v. Ryan, should allow him to introduce this evidence in federal court, despite statutory restrictions.The United States District Court for the Middle District of Pennsylvania denied the prisoner’s motion under Federal Rule of Civil Procedure 60(b)(6), finding it untimely and concluding that Martinez did not apply because the ineffective assistance of trial counsel claim had already been adjudicated on the merits and was not procedurally defaulted. The District Court also determined that no extraordinary circumstances justified reopening the habeas proceedings and declined to issue a certificate of appealability. The United States Court of Appeals for the Third Circuit granted a certificate of appealability and reviewed the case.The United States Court of Appeals for the Third Circuit held that, while the prisoner could use Rule 60(b)(6) to challenge the District Court’s failure to hold an evidentiary hearing, his motion was timely. However, the court concluded that Martinez does not permit reopening the case to introduce new evidence where the underlying claim was already decided on the merits. Furthermore, even if Martinez applied, the Antiterrorism and Effective Death Penalty Act (AEDPA) bars the introduction of new evidence unless strict statutory requirements are met, which the prisoner could not satisfy. The Third Circuit affirmed the District Court’s order in part, vacated in part, and remanded with instructions to dismiss the portion of the motion constituting a successive habeas petition. View "Taylor v. Commissioner of Pennsylvania" on Justia Law

A federal inmate diagnosed with diabetes was initially prescribed medication and given certain accommodations while incarcerated. After being transferred to a new facility, his new medical provider discontinued his diabetes medication and accommodations based on a single blood test result, despite the inmate’s objections that the result was not representative of his condition. The inmate’s health deteriorated, leading to severe diabetic ulcers and ultimately the amputation of his toe. He alleged that medical staff repeatedly denied or delayed necessary care, and that his requests for treatment were falsely documented as refusals. The inmate later filed administrative claims with the Bureau of Prisons (BOP) and, after those were denied or not fully addressed, brought suit alleging deliberate indifference to his medical needs under the Eighth Amendment and also asserted a claim under the Rehabilitation Act.The United States District Court for the District of New Jersey screened the complaint and dismissed the Rehabilitation Act claim. The defendants moved to dismiss the Eighth Amendment claim brought under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics. The District Court granted the motion, reasoning that the case presented a new context from prior Supreme Court precedent because the injuries were not fatal and that the existence of the BOP’s administrative remedy program was a special factor counseling against extending Bivens. The inmate appealed.The United States Court of Appeals for the Third Circuit affirmed. The court held that the availability of the BOP’s administrative remedy program constituted a special factor not present in Carlson v. Green, and thus created a new context under the Bivens analysis. Because an alternative remedial structure existed and was available to the inmate, the court declined to extend a Bivens remedy. The court also affirmed dismissal of the Rehabilitation Act claim, as sovereign immunity barred damages claims against the federal government under that statute. View "Muniz v. United States" on Justia Law

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