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

Lynell Guyton was convicted by a jury of nine drug-trafficking, firearm, and money-laundering offenses. His criminal activities included ordering large quantities of fentanyl analogues from China, using Skype to communicate with suppliers, and making payments through MoneyGram. Law enforcement intercepted a package containing fentanyl analogues addressed to a pseudonym used by Guyton, leading to his arrest. Subsequent investigations revealed Guyton's continued involvement in drug trafficking and possession of firearms.The United States District Court for the Western District of Pennsylvania denied Guyton's motion for judgment of acquittal and sentenced him to 360 months' imprisonment on the primary drug charges, with concurrent sentences on the remaining counts. The court also applied recidivist enhancements based on Guyton's prior state conviction. Guyton appealed, raising several arguments, including instructional errors, constructive amendment of the indictment, and improper application of recidivist enhancements.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that the District Court erred in denying Guyton's motion for judgment of acquittal on one of the firearm possession charges (Count 3) due to insufficient evidence of constructive possession. The court vacated this conviction and remanded for a judgment of acquittal on that count. However, the court affirmed the remaining convictions and sentences, finding no reversible error in the jury instructions, the alleged constructive amendment, or the application of recidivist enhancements. The court concluded that the instructional errors did not affect Guyton's substantial rights and that the evidence overwhelmingly supported the remaining convictions. View "United States v. Guyton" on Justia Law

Axalta Coating Systems LLC ("Axalta") provided a can of flammable paint to FedEx for air shipment. The paint spilled during transit due to a loose lid. The Federal Aviation Administration (FAA) filed an administrative complaint alleging Axalta failed to package the paint according to the Hazardous Materials Regulations (HMR). An Administrative Law Judge (ALJ) found Axalta in violation and imposed a $1,900 penalty, which the FAA Administrator affirmed. Axalta petitioned for review, arguing the administrative adjudication violated the Seventh Amendment's jury trial guarantee, referencing the Supreme Court's decision in SEC v. Jarkesy.The ALJ denied Axalta's motion to dismiss the complaint and a motion to disqualify the ALJ. After a hearing, the ALJ concluded Axalta violated 49 C.F.R. § 171.2(e) and 49 C.F.R. § 173.24(b)(1), assessing a $1,900 penalty. Axalta appealed, and the FAA cross-appealed for a higher penalty. The Administrator affirmed the ALJ's decision. Axalta then petitioned the United States Court of Appeals for the Third Circuit for review.The Third Circuit held that the administrative adjudication did not violate the Seventh Amendment. The court distinguished the case from Jarkesy, noting that the HMR's technical standards were not derived from common law, unlike the securities fraud provisions in Jarkesy. The court concluded that the FAA's enforcement action was a public right that could be adjudicated administratively without a jury. The court also rejected Axalta's additional arguments, including claims of unconstitutional delegation of legislative power, improper ALJ appointment, statute of limitations issues, and due process violations. The petition for review was denied. View "Axalta Coating Systems LLC v. Federal Aviation Administration" on Justia Law

Mohammad M. Qatanani, a Palestinian and citizen of Jordan, was admitted to the United States in 1996 on a work visa. In 1999, he applied to adjust his status to that of a Lawful Permanent Resident (LPR). An Immigration Judge (IJ) twice granted his application, in 2008 and 2020, after finding in his favor on fact and credibility determinations. The Department of Homeland Security (DHS) appealed the 2008 order, leading the Board of Immigration Appeals (BIA) to vacate and remand the case. The IJ's 2020 order became final when DHS did not appeal within 30 days.The BIA later invoked an agency regulation to self-certify an appeal of the IJ’s 2020 order eleven months after it was issued, ultimately reversing the IJ’s decision and ordering Qatanani removed from the United States. Qatanani petitioned the United States Court of Appeals for the Third Circuit for review of the BIA’s decision.The Third Circuit held that the BIA exceeded its authority by using an agency regulation to undo Qatanani’s adjustment to LPR status in a manner inconsistent with the procedures set out by Congress in the Immigration and Nationality Act (INA). The court emphasized that once the 30-day appeal period lapsed without an appeal, Qatanani’s adjustment to LPR status became final by operation of law. The court vacated the BIA’s order, reaffirming that the Attorney General must follow the statutory recission process if seeking to revoke LPR status. The court granted Qatanani’s petition for review and vacated the BIA’s order of removal. View "Qatanani v. Attorney General" on Justia Law

Erik Harris, a frequent marijuana user, purchased three pistols over a short period. Each time, he falsely stated on federal forms that he was not an unlawful user of marijuana. After losing one of the guns while intoxicated, Harris reported it stolen and bought a replacement. When the missing gun was found with a felon, Harris admitted to regular marijuana use during police questioning.The United States District Court for the Western District of Pennsylvania denied Harris's motion to dismiss the charges, which included three counts under 18 U.S.C. §922(g)(3) for possessing guns as an unlawful drug user and three counts under §922(a)(6) for lying to obtain the guns. The court concluded that §922(g)(3) was constitutional as applied to Harris, using means-end scrutiny. Harris then pleaded guilty to all counts but preserved his right to appeal the denial of his motion to dismiss.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that history and tradition justify §922(g)(3)’s restrictions on those who pose a special danger of misusing firearms due to frequent drug use. However, the court found insufficient facts to determine whether the law's restrictions are constitutional as applied to Harris. The court affirmed the statute's constitutionality in general but vacated Harris's conviction under §922(g)(3) and remanded the case for further fact-finding. The court also held that §922(g)(3) is not unconstitutionally vague as applied to Harris and upheld his convictions under §922(a)(6) for lying on the federal forms. View "United States v. Harris" on Justia Law

Kevin Johnson was convicted of first-degree murder in 1986 for the killing of Lyndon "Cowboy" Morris, a drug dealer in Philadelphia. Four witnesses identified Johnson as the shooter, with three positively identifying him and one expressing doubts. Johnson claimed mistaken identity and presented an alibi, but his testimony conflicted with his alibi witnesses. The jury convicted him, and he was sentenced to life in prison. The Superior Court affirmed his conviction and sentence.Johnson sought post-conviction relief under the Pennsylvania Post Conviction Relief Act (PCRA), claiming ineffective assistance of counsel and presenting new evidence of witness recantations. The PCRA court denied his petition, but the Superior Court remanded for an evidentiary hearing. After the hearing, the state courts dismissed his petition, and the dismissal was affirmed. Johnson then filed a federal habeas petition, which was pending when new evidence emerged, leading to additional PCRA petitions that were ultimately dismissed as time-barred.The United States District Court for the Eastern District of Pennsylvania reviewed Johnson's federal habeas petition. Johnson and the Philadelphia District Attorney's Office attempted to settle the case by waiving procedural defenses, but the District Court rejected the procedural-default waiver. The court found that Johnson's Brady claims, based on witness recantations and arrest photos, were not material and did not warrant habeas relief. The court also rejected Johnson's ineffective assistance of counsel claims.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The court held that the District Court had discretion to reject the procedural-default waiver and that Johnson failed to show cause and prejudice or a fundamental miscarriage of justice to overcome the default. The court also found that Johnson did not qualify for an evidentiary hearing under 28 U.S.C. § 2254(e)(2) and that his remaining Brady and ineffective assistance claims lacked merit. View "Johnson v. Superintendent Mahanoy SCI" on Justia Law

In 2015, product liability cases involving the blood-pressure medication Olmesartan were consolidated into a multidistrict litigation (MDL) in the United States District Court for the District of New Jersey. Adam Slater and his law firm, Mazie Slater Katz & Freeman, LLC, represented over 200 plaintiffs, and the case settled for over $300 million. Subsequently, Anthony Martino, a plaintiff in the MDL, filed a class action in New Jersey state court against his former lawyers, alleging they received contingent fees in violation of New Jersey court rules. The case was removed to federal court and dismissed, with the dismissal affirmed on appeal.Following this, twenty-one individuals represented by the same defendants in the MDL filed a similar action in New Jersey state court, alleging breach of contract, legal malpractice, conversion, and unjust enrichment. Defendants removed the case to the District Court, citing diversity and federal-question jurisdiction. The District Court denied the plaintiffs' motion to remand, asserting ancillary enforcement jurisdiction, and granted defendants' motion for judgment on the pleadings, applying issue preclusion. The court also dismissed the parties' motions for sanctions as moot.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that ancillary enforcement jurisdiction does not confer original jurisdiction sufficient for removal under 28 U.S.C. § 1441(a). The court also found that the plaintiffs' state-law claims did not necessarily raise a federal issue to establish federal-question jurisdiction. The court vacated the District Court's judgment and remanded the case to determine if the amount in controversy exceeded $75,000 for diversity jurisdiction. Additionally, the court vacated the order dismissing the motions for sanctions as moot, instructing the District Court to consider the merits of each motion. View "Johnson v. Mazie" on Justia Law

Plaintiffs, representing a class of drivers, alleged that Progressive Specialty Insurance and Progressive Advanced Insurance systematically underestimated the actual cash value (ACV) of their totaled vehicles, thereby breaching their insurance agreements. The plaintiffs claimed that Progressive's method of calculating ACV, which included a "Projected Sold Adjustment" (PSA) to account for the fact that used cars often sell for less than their listed prices, was improper and resulted in underpayment.The United States District Court for the Eastern District of Pennsylvania certified two damages classes, finding that the plaintiffs' claims centered on the legitimacy of the PSAs and that this issue could be resolved on a class-wide basis. The court held that the plaintiffs had standing and rejected Progressive's arguments against commonality, predominance, superiority, and adequacy.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the District Court had abused its discretion in certifying the classes. The Third Circuit held that proving whether Progressive undercompensated each class member was an individual issue that could not be resolved on a class-wide basis. The court emphasized that the key issue was whether each class member received less than the true ACV of their vehicle, which would require individualized inquiries. As a result, the court found that common issues did not predominate over individual ones, and the District Court's certification of the classes was reversed and remanded for further proceedings. View "Drummond v. Progressive Specialty Insurance Co." on Justia Law

Ronell Moses was driving through his Pittsburgh suburb when Officer Dustin Hess, in a marked police SUV, smelled burnt marijuana and saw that Moses's car windows were tinted very dark, both of which are illegal. The officer followed Moses to his home, where Moses parked in his driveway. The officer walked up the driveway, searched Moses's car, and found a loaded, stolen pistol. Moses, a felon on probation, was arrested and charged with possessing a gun and ammunition as a felon.The United States District Court for the Western District of Pennsylvania denied Moses's motion to dismiss the indictment, which challenged the constitutionality of the law under the Second Amendment. The court also denied his motion to suppress the gun, rejecting his claim that the officer had invaded his home's curtilage without a warrant. Moses then pleaded guilty conditionally, preserving his right to appeal the curtilage issue and the constitutionality of the law.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the officer did not invade Moses's curtilage by walking halfway up the driveway, as the driveway was not an extension of Moses's home. The court applied a de novo standard of review to curtilage decisions, aligning with other circuits. The court also held that the officer's actions were constitutional and that Moses, as a felon on parole, could be prosecuted for possessing a gun. The court affirmed Moses's conviction. View "United States v. Moses" on Justia Law

Robert Lanoue, a Canadian citizen and lawful permanent resident of the United States, pleaded guilty to submitting false claims to the government under 18 U.S.C. § 287. He operated a scuba school that was part of a government program funded by the post-9/11 GI Bill, which reimbursed him for teaching veterans. Lanoue admitted to submitting false and fraudulent claims, resulting in a loss of over $3 million to the Department of Veterans' Affairs. Following his conviction, the government initiated removal proceedings, arguing that his crime was an aggravated felony involving fraud or deceit with losses exceeding $10,000.The Immigration Judge found that Lanoue's crime met the criteria for an aggravated felony and denied his request for a waiver of inadmissibility. The Board of Immigration Appeals upheld this decision, leading Lanoue to petition for review.The United States Court of Appeals for the Third Circuit reviewed the case. The court determined that Lanoue's conviction under 18 U.S.C. § 287 categorically involved deceit, as the statute requires knowingly submitting false claims to the government. The court also found that the government had proven by clear and convincing evidence that the loss exceeded $10,000, based on Lanoue's stipulation and plea agreement indicating losses between $1.5 and $3.5 million.Lanoue's argument for a retroactive waiver under 8 U.S.C. § 1182(h) was rejected. The court noted that to qualify for such a waiver, a lawful permanent resident must have been convicted or admitted to the crime at the time of reentry, which was not the case for Lanoue.The Third Circuit held that filing false claims under 18 U.S.C. § 287 is an aggravated felony involving deceit, and the government sufficiently proved the loss amount. Consequently, Lanoue is removable and ineligible for a waiver. The court denied his petition for review. View "Lanoue v. Attorney General United States of America" on Justia Law

Kelvin Rosa, a state prisoner, sought federal habeas relief, claiming ineffective assistance of counsel during his trial for burglarizing a check-cashing store and shooting a responding police officer. Rosa was captured after a high-speed chase, during which he and others threw burglary tools and a stolen gun out of their car. The state presented extensive prior-bad-acts evidence, including details of other burglaries Rosa allegedly committed, to link him to the gun used in the check-cashing store burglary.The state habeas court denied Rosa's claim, concluding that his counsel was effective and that any deficiencies did not prejudice him. Rosa then filed a pro se petition for federal habeas relief, raising the same ineffective-assistance claim. The United States District Court for the District of New Jersey granted habeas relief, finding that the state habeas court had unreasonably applied the Strickland v. Washington standard for ineffective assistance of counsel.The United States Court of Appeals for the Third Circuit reviewed the case and agreed with the District Court. The Third Circuit held that Rosa's trial counsel was deficient for failing to object to the extensive prior-bad-acts evidence and for not requesting timely and specific limiting instructions to mitigate its prejudicial impact. The court found that the state habeas court's conclusion that counsel was effective was unreasonable, as it did not consider whether counsel should have taken further action during the trial.The Third Circuit also found that the state habeas court unreasonably concluded that Rosa was not prejudiced by his counsel's deficiencies. The court noted that the evidence against Rosa was not overwhelming, and the extensive prior-bad-acts evidence likely influenced the jury's verdict. The court affirmed the District Court's grant of habeas relief, concluding that Rosa's trial was unfair due to his counsel's ineffective assistance. View "Rosa v. Administrator East Jersey State Prison" on Justia Law