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

Jamal Morton was convicted in 2012 in the Virgin Islands Superior Court of second-degree murder and various firearm offenses, receiving a fifty-year sentence. After his conviction was affirmed on direct appeal, Morton filed a territorial habeas petition in 2014, raising twenty claims, including violations of his Fifth and Sixth Amendment rights. Despite his numerous attempts to move the case forward, including motions for default judgment, discovery requests, and status conference requests, the Superior Court took no substantive action for nearly six years.Frustrated by the inaction, Morton filed a federal habeas petition in the U.S. District Court of the Virgin Islands in April 2020, raising the same claims. The District Court dismissed his petition without prejudice, citing his failure to exhaust territorial court remedies. The court reasoned that Morton had not taken sufficient steps, such as seeking a writ of mandamus from the Virgin Islands Supreme Court, to address the delay in the territorial court.The United States Court of Appeals for the Third Circuit reviewed the case and found that the nearly six-year delay in the territorial court, coupled with the lack of progress and Morton’s reasonable efforts to advance his case, constituted inordinate delay. The Third Circuit held that the District Court erred by not requiring the Government to justify the delay before dismissing Morton’s petition. The court vacated the District Court’s dismissal and remanded the case, instructing the lower court to allow the Government to provide any justifications for the delay and proceed accordingly. View "Morton v. Director Virgin Islands Bureau of Corrections" on Justia Law

Residents of St. Croix, Virgin Islands, sued Limetree Bay Terminals and Limetree Bay Refining after the companies reopened an oil refinery that released oil mist onto nearby properties, contaminating water supplies. The residents, who rely on cisterns for water, claimed the contamination posed health risks. The companies attempted to clean the cisterns and compensate affected residents, but not all residents had access to clean water. The residents sought a preliminary injunction to require the companies to provide bottled water.The District Court for the Virgin Islands granted the preliminary injunction, finding that both Terminals and Refining were responsible for the contamination under their federal operating permit. The court determined that the residents were likely to succeed on the merits of their case and faced irreparable harm without access to clean water. The court limited the bottled-water program to residents in certain neighborhoods who received need-based government assistance and required the residents to post a $50,000 bond.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit agreed that the residents were likely to succeed on the merits and faced irreparable harm. The court also found that the balance of equities and public interest favored the residents. The Third Circuit upheld the $50,000 bond, noting that the District Court had carefully considered the residents' ability to pay and the relative hardships to each party. The court concluded that the District Court had properly applied the law and exercised its discretion in granting the preliminary injunction and setting the bond amount. View "Boynes v. Limetree Bay Ventures LLC" on Justia Law

In 2008, Diontai Moore was investigated for drug crimes, leading to his arrest and a guilty plea for distributing cocaine base. He was sentenced to 72 months in prison followed by three years of supervised release. In 2013, while on supervised release, Moore was found with a handgun and subsequently pleaded guilty to being a felon in possession of a firearm, resulting in a 60-month prison sentence and another three years of supervised release. In 2021, during his supervised release, Moore used a firearm to confront intruders at his fiancée’s home, leading to his arrest and charges for violating 18 U.S.C. § 922(g)(1).The United States District Court for the Western District of Pennsylvania sentenced Moore to 84 months in prison followed by three years of supervised release after he pleaded guilty to the firearm possession charge. Moore reserved the right to appeal the constitutionality of § 922(g)(1) as applied to him.The United States Court of Appeals for the Third Circuit reviewed the case and held that Moore, as a convict on supervised release, does not have a Second Amendment right to possess a firearm. The court found that historical analogues, such as 18th-century forfeiture laws, supported the disarmament of convicts during their sentences. The court concluded that these historical practices justified the application of § 922(g)(1) to Moore. Consequently, the court affirmed Moore’s conviction, rejecting his as-applied and facial challenges to the statute. View "United States v. Moore" on Justia Law

Quintez Talley, a Pennsylvania inmate, filed a federal civil rights lawsuit alleging mistreatment while in restrictive custody. Talley claimed he was unable to file grievances due to lack of access to forms and writing implements from January 6 to February 8, 2018, while on suicide watch. He regained access on February 9, 2018, but did not file a grievance, instead filing the lawsuit.The United States District Court for the Eastern District of Pennsylvania dismissed Talley’s federal claims for failure to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA). The court noted that Talley should have requested an extension to file a late grievance under the state prison system’s policy. Talley did not oppose the motion to dismiss and moved for a default judgment, which was denied. The court dismissed the complaint against all defendants, including those who had not appeared, because the claims were integrally related. The court also declined to exercise supplemental jurisdiction over state law claims.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The appellate court held that under the PLRA, Talley was required to request an extension to file a grievance once he regained access to the necessary materials. The court found that Talley’s failure to do so rendered his federal claims unexhausted. The court also rejected Talley’s argument that the dismissal was improper for defendants who had not appeared, noting that the failure to exhaust was apparent from the face of the complaint. The court concluded that the District Court did not abuse its discretion in declining to exercise supplemental jurisdiction over the state law claims. View "Talley v. Clark" on Justia Law

The case involves a dispute between SPS Corp I, Fundo de Investimento em Direitos Creditórios Não Padronizados (SPS), and General Motors Co. (GM). GM Brazil, a subsidiary of GM, sued the Brazilian government to recover tax overpayments made by car dealerships. After winning the right to recover, GM Brazil filed a claim with Brazil’s tax agency, Receita Federal do Brasil (RFB), to determine the exact amount. Meanwhile, SPS, as the assignee of thirty-five dealerships, sought to recover the tax overpayments from GM Brazil in Brazilian courts but faced adverse decisions regarding standing and preliminary discovery.The District Court for the District of Delaware reviewed SPS’s application for discovery against GM under 28 U.S.C. § 1782, which allows for discovery in aid of foreign litigation. The District Court denied the request, citing the factors from the Supreme Court’s decision in Intel Corp. v. Advanced Micro Devices, Inc. The court found that the discovery sought was within the jurisdictional reach of Brazilian courts, which had already denied similar requests by SPS. The court also noted that allowing the discovery would undermine the decisions of the Brazilian courts and lead to inefficiency.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decision. The Third Circuit affirmed the lower court’s ruling, agreeing that the Intel factors weighed against granting SPS’s discovery request. The court emphasized that the Brazilian courts had jurisdiction over the requested documents and had already denied SPS’s requests. The Third Circuit found no abuse of discretion in the District Court’s decision to respect the Brazilian courts’ rulings and to avoid circumventing foreign proof-gathering restrictions. View "SPS Corp I v. General Motors Co." on Justia Law

Joseph Marcy was convicted by a Pennsylvania jury of raping his five-year-old daughter, D.M., based on her testimony and corroborating evidence from caseworkers and a physician. Years later, D.M. recanted parts of her testimony during a state postconviction relief hearing, leading Marcy to petition for a writ of habeas corpus, arguing that due process required his release due to the recantation.After his conviction, Marcy filed a motion for a new trial, which was denied. He then appealed to the Superior Court of Pennsylvania, which affirmed his conviction. Marcy did not appeal to the Pennsylvania Supreme Court. He subsequently filed two premature state petitions for postconviction relief, which were dismissed. A later petition included a note from a third party suggesting D.M. had not told the truth at trial. The Court of Common Pleas found D.M.’s recantation credible and granted Marcy a new trial, but the Superior Court vacated that decision, citing procedural waiver. The Pennsylvania Supreme Court declined to review the case.The United States Court of Appeals for the Third Circuit reviewed Marcy’s habeas petition. The court held that Marcy’s claim was barred by Teague v. Lane, which prevents the application of new constitutional rules to cases on collateral review unless they are substantive or watershed rules of criminal procedure. The court found that Marcy’s proposed rule—that a conviction based on recanted testimony violates due process regardless of the government’s knowledge of the falsity—was a new procedural rule and not dictated by precedent. Consequently, the court affirmed the District Court’s order dismissing Marcy’s petition. View "Marcy v. Superintendent Phoenix SCI" on Justia Law

Timothy Mullins, a coal miner, suffered an ankle stress fracture in 2015 while working as a Section Supervisor at a coal mine owned by CONSOL Energy, Inc. He initially received long-term disability benefits under CONSOL's ERISA-governed Long-Term Disability Plan, administered by Lincoln Financial Group. However, his benefits were terminated in 2020 after Lincoln determined, based on medical evaluations and a vocational assessment, that Mullins did not demonstrate "total disability" as required under the Plan. Lincoln's decision was based on a vocational report that incorrectly listed Mullins's job as "Mine Superintendent" rather than Section Supervisor.The United States District Court for the Western District of Pennsylvania upheld Lincoln's decision to terminate Mullins's benefits, granting summary judgment in favor of the Plan. The District Court found that Lincoln's decision was supported by substantial medical and vocational evidence and was not arbitrary and capricious. Mullins appealed the decision, arguing that Lincoln's reliance on the incorrect job title in the vocational report led to an erroneous termination of his benefits.The United States Court of Appeals for the Third Circuit reviewed the case and found that Lincoln's reliance on the incorrect vocational report was arbitrary and capricious. The court noted that the error in the job title led to an incorrect assessment of Mullins's qualifications and experience, which in turn resulted in the wrongful termination of his benefits. The Third Circuit vacated the District Court's judgment and remanded the case for reinstatement of Mullins's long-term disability benefits. The court also instructed the District Court to consider Mullins's claim regarding the improper offset of benefits due to Social Security disability benefits. View "Mullins v. Consol Energy Inc Long Term Disability Plan" on Justia Law

Rachel Spivack, an employee at the Philadelphia District Attorney’s Office (DAO), was subject to a COVID-19 vaccine mandate. The DAO denied her request for a religious exemption, leading to her termination. Spivack then sued the City of Philadelphia and District Attorney Lawrence Krasner, alleging that the mandate violated her constitutional right to the free exercise of religion.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the defendants, holding that the vaccine mandate was neutral and generally applicable, thus subject to rational basis review. The court found that the mandate was rationally related to the DAO’s interests in curtailing the spread of COVID-19, avoiding staffing shortages, and reducing the risk of death and serious illness among DAO staff and the public. The court also held that the mandate satisfied strict scrutiny as an alternative ruling. Spivack appealed the decision.The United States Court of Appeals for the Third Circuit reviewed the case and found that there were disputes of material fact that needed to be resolved by a jury. Specifically, the court noted that it was unclear whether Spivack’s exemption request was evaluated under the August 2021 policy, which allowed for individualized, discretionary religious exemptions, or the January 2022 policy, which categorically denied religious exemptions. Additionally, the court found that comments made by Krasner during his deposition could be interpreted as showing hostility toward religious beliefs, which would undermine the neutrality of the policy.The Third Circuit vacated the District Court’s order and remanded the case for trial, instructing that a jury must resolve these factual disputes to determine the applicable standard of scrutiny. If the policy is found to be neutral and generally applicable, it would be subject to rational basis review. If not, it would be subject to strict scrutiny. View "Spivack v. City of Philadelphia" on Justia Law

Atina Knowles appealed a District Court order denying her motion to strike Temple University's request for taxation of costs, resulting in a $2,578.93 award. Temple, as the prevailing party in a previous summary judgment on Knowles's due process claims, filed a bill of costs for service of subpoenas, deposition and hearing transcripts, and copies. Knowles moved to strike these costs, but the District Court denied her motion and awarded Temple the costs, including $625 for private process servers, $1,743.55 for transcripts, and $210.38 for copies.The United States District Court for the Eastern District of Pennsylvania initially reviewed the case, granting summary judgment to Temple University on Knowles's due process claims. Following this, Temple filed for reimbursement of litigation costs, which Knowles contested. The District Court held a conference and subsequently denied Knowles's motion to strike the costs, awarding Temple the specified amounts under Federal Rule of Civil Procedure 54(d) and 28 U.S.C. § 1920.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that costs for private process servers are not taxable under 28 U.S.C. § 1920(1), which only permits reimbursement for fees of public actors like marshals. The court reversed the award for private process server fees but affirmed the award for transcript and copy costs, as these were deemed necessary for Temple's trial preparation. The court concluded that the District Court acted within its discretion in awarding the transcript and copying fees, but not the private process server fees. View "Knowles v. Temple University" on Justia Law

Steven Baker was charged with bank robbery and using a firearm during the robbery. The government offered him a plea deal to plead guilty to these charges and admit to two other bank robberies without being charged for them. Baker’s counsel incorrectly advised him that he faced 15-17 years if he accepted the plea and 21 years for the firearm charges if he went to trial. In reality, he faced a 57-year mandatory minimum for the firearm charges due to the statute’s “stacking” provision. Misled by this advice, Baker rejected the plea, went to trial, and was convicted on all counts, receiving a 57-year sentence for the firearm charges plus 87 months for the bank robberies.Baker appealed, and the United States Court of Appeals for the Third Circuit affirmed his conviction and sentence. He then filed a Section 2255 motion, arguing ineffective assistance of counsel due to the miscalculation of his sentence exposure. The District Court for the District of New Jersey denied relief, finding that Baker could not show prejudice from his counsel’s error.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that Baker’s counsel’s performance was objectively unreasonable due to the significant miscalculation of his sentence exposure. The court also determined that Baker demonstrated prejudice because there was a reasonable probability he would have accepted the plea offer if he had been correctly advised. The court noted the substantial disparity between the plea offer (15-17 years) and the actual sentence (57 years plus 87 months) and credited Baker’s testimony that he would have accepted the plea but for his counsel’s error. The court reversed the District Court’s decision and remanded with instructions to order the government to reoffer the original plea agreement to Baker. View "Baker v. United States" on Justia Law