U.S. Court of Appeals for the Third Circuit - Justia Case Law Summaries

National Shooting Sports Foundation v. Attorney General New Jersey

2026-09-08T09:00:05-08:00

A national firearms industry trade association challenged the constitutionality of a New Jersey statute enacted in 2022, which imposes civil liability on gun industry members for certain “public nuisance” conduct related to the sale, manufacture, distribution, import, or marketing of firearms and related products. The law allows the state to bring enforcement actions against gun industry members for actions deemed unlawful or unreasonable, as well as for failing to implement “reasonable controls.” The association argued that the statute is unconstitutional under the Interstate Commerce Clause, the First and Second Amendments, and is preempted by the federal Protection of Lawful Commerce in Arms Act (PLCAA). Initially, the United States District Court for the District of New Jersey granted a preliminary injunction against enforcement of the law, but the United States Court of Appeals for the Third Circuit vacated that injunction, holding that the association lacked Article III standing because enforcement of the law was speculative at that time. After the state initiated several enforcement actions under the statute—including suits against two members of the association—the association moved to reopen the case, amend its complaint, and again seek a preliminary injunction. The District Court found standing but abstained from ruling on the merits under the Younger abstention doctrine, which generally prohibits federal courts from interfering with certain ongoing state proceedings. The United States Court of Appeals for the Third Circuit reviewed the case and held that the association now has standing due to the substantial risk of imminent enforcement against its members, evidenced by the state’s recent lawsuits. The court further held that Younger abstention does not apply because the association is not a party to any ongoing state proceeding and does not have the type of control or relationship with its members that would warrant abstention. Accordingly, the Third Circuit reversed the District Court’s order. View "National Shooting Sports Foundation v. Attorney General New Jersey" on Justia Law

Natural Resources Defense Council Inc v. New Jersey Department of Environmental Protection

2026-09-08T09:00:04-08:00

A company sought to expand its interstate natural gas pipeline by constructing a new pipeline segment beneath Raritan Bay, New Jersey. This work required dredging the bay floor, which would disturb sediment containing toxic contaminants. Several environmental organizations challenged the state agency’s decision to grant a Water Quality Certification for the project, arguing that the agency reversed a prior denial without adequate explanation, certified the project before resolving essential monitoring and management requirements, inadequately explained how the project would meet state water quality standards, and failed to provide sufficient public participation opportunities. Previously, the New Jersey Department of Environmental Protection (NJDEP) had denied the company’s application in 2019, citing insufficient information to determine compliance with water quality standards, including concerns over contaminants like 4,4’–DDE. The company submitted additional modeling and monitoring plans in subsequent applications, but NJDEP again denied certification in 2020 after New York rejected the corresponding application. In 2025, following New York’s approval, NJDEP granted the Water Quality Certification, imposing several conditions, including post-certification submission of finalized monitoring and adaptive management plans. The United States Court of Appeals for the Third Circuit reviewed the petitions after transfer from the Second Circuit. The court held that NJDEP acted arbitrarily and capriciously by deferring the finalization of material monitoring and adaptive management plans until after certification without requiring agency approval before the start of dredging. The court also found NJDEP failed to adequately explain how the project would comply with water quality standards, particularly regarding toxic contaminant monitoring and shellfish impacts. Accordingly, the Third Circuit granted the petitions, vacated the Water Quality Certification, and remanded the matter to NJDEP for further proceedings. View "Natural Resources Defense Council Inc v. New Jersey Department of Environmental Protection" on Justia Law

USA v. Berger

2026-09-01T09:00:06-08:00

Federal agents intercepted a package containing three silencers shipped from China to Joseph Berger’s residence in Bethlehem, Pennsylvania. Upon searching the home with a warrant, agents discovered more than sixty firearms, including thirteen fully automatic guns (mostly AK-47 variants), a dozen silencers, and parts for converting semi-automatic weapons into machine guns. Berger was indicted for possession of machine guns and unregistered silencers, violations of federal law. He is a Navy veteran who lived with his father, and evidence suggested both were involved in acquiring conversion parts. In the U.S. District Court for the Eastern District of Pennsylvania, Berger raised an as-applied Second Amendment challenge. The court denied his challenge, finding that machine guns were “dangerous and unusual weapons” not commonly used for self-defense, and that silencers were not “bearable arms” under the Second Amendment. Berger then pleaded guilty to possessing a machine gun and an unregistered silencer, reserving his right to appeal the Second Amendment issue. The government dismissed the charge of possessing an unregistered machine gun as part of the plea agreement. The United States Court of Appeals for the Third Circuit reviewed Berger’s appeal de novo, focusing on pure issues of law. The court held that the Second Amendment does not protect possession of machine guns because they are not commonly used for lawful purposes and are classified as “dangerous and unusual.” Furthermore, the registration requirement for silencers under the National Firearms Act imposes only a minimal, objective burden and does not infringe upon Second Amendment rights. The court affirmed Berger’s conviction and sentence, holding that both the machine-gun ban and the silencer registration requirement are constitutional as applied to Berger. View "USA v. Berger" on Justia Law

USA v. Walker

2026-09-01T09:00:05-08:00

Police investigating a suspicious package at a UPS facility in Pennsylvania discovered it contained methamphetamine after a drug-sniffing dog alerted and a search warrant was obtained for the box. Officers planned to track the package with a GPS device and sought judicial authorization for a “hit-and-hold” procedure: if the package was brought into any location other than the listed delivery address (Apartment 2), they would secure the package there and then apply for a search warrant for the new location. The judge issued a tracker order and a search warrant for Apartment 2 but did not explicitly authorize entry into any other apartment. When the package was instead brought into Apartment 1 by Davone Walker, officers entered Apartment 1 to secure the package, then obtained a search warrant for that apartment and found substantial quantities of drugs. Walker was charged with drug offenses in the United States District Court for the Eastern District of Pennsylvania. He moved to suppress the evidence found in Apartment 1, arguing that the officers’ warrant did not authorize entry into his apartment. The District Court found that Trooper Montz unreasonably believed he was permitted to enter Apartment 1 based on the tracker order but concluded this mistake was at most isolated negligence rather than gross negligence or deliberate misconduct, and thus denied the suppression motion. Walker then entered a conditional guilty plea, reserving the right to appeal. The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and legal conclusions de novo. The Third Circuit held that the exclusionary rule does not apply to evidence obtained through an officer’s isolated or negligent mistake unless the conduct is deliberate, reckless, grossly negligent, or part of systemic misconduct. Because Trooper Montz’s mistake was not grossly negligent, the court affirmed the denial of the suppression motion and Walker’s conviction. View "USA v. Walker" on Justia Law

USA v. Aleman-Lozano

2026-09-01T09:00:05-08:00

The case concerns a noncitizen from El Salvador who lawfully entered the United States on a nonimmigrant temporary visa with work authorization. While residing in the United States, he was stopped by a Pennsylvania state trooper for a traffic violation. During the stop, the officer observed a rifle cartridge in the vehicle, leading to a search warrant and the discovery of a loaded pistol without a serial number. The individual admitted to purchasing the pistol in Maryland. He was indicted by a grand jury for violating 18 U.S.C. § 922(g)(5)(B), a statute prohibiting nonimmigrant visa holders from possessing firearms. He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The United States District Court for the Middle District of Pennsylvania denied his motion, holding the statute constitutional. After entering a conditional guilty plea, reserving his right to appeal the constitutional issue, he was sentenced to twenty-four months’ imprisonment and one year of supervised release. On appeal, the United States Court of Appeals for the Third Circuit addressed whether 18 U.S.C. § 922(g)(5)(B) is facially unconstitutional under the Second Amendment. The Court, following the framework from New York State Rifle & Pistol Ass’n v. Bruen, assumed without deciding that some noncitizens may be included among “the people” protected by the Second Amendment. The Court then considered whether the statute is consistent with the nation’s historical tradition of firearm regulation. It found that there is a longstanding historical practice of disarming individuals considered disloyal to the sovereign, including noncitizens with allegiance to another country. Concluding that § 922(g)(5)(B) is relevantly similar to these historical analogues, the Court held that the statute does not violate the Second Amendment and affirmed the conviction. View "USA v. Aleman-Lozano" on Justia Law

Aristy-Rosa v. Attorney General United States of America

2026-09-01T09:00:04-08:00

The petitioner, a lawful permanent resident admitted to the United States in 1993, was ordered removed in 2011 based on a 1997 New York conviction for attempted third-degree criminal sale of cocaine. He did not appeal the removal order at that time but has since attempted several legal challenges to the order, including collateral attacks on his underlying conviction and multiple motions for reopening and reconsideration of the removal order. None of these efforts were successful, though a gubernatorial pardon in 2017 removed the aggravated felony basis for removal, leaving the controlled substance offense as the remaining ground. Following a 2023 decision by the United States Court of Appeals for the Second Circuit (United States v. Minter) interpreting the New York statute at issue, the petitioner filed new motions with the Board of Immigration Appeals (BIA) in 2024 seeking statutory reopening, statutory reconsideration, and sua sponte reopening, arguing that the Second Circuit’s reasoning undermined the basis for his removal. The BIA denied all motions, finding the statutory motions time-barred without justification for equitable tolling, and declined to exercise its sua sponte authority. The United States Court of Appeals for the Third Circuit reviewed the BIA’s decision. It held that a change in law is not a permissible basis for statutory reopening under 8 U.S.C. § 1229a(c)(7), and, while statutory reconsideration may in rare cases be justified by a change in law, the petitioner’s motion was untimely and did not meet the requirements for equitable tolling. The Third Circuit also concluded it lacked jurisdiction to review the BIA’s denial of sua sponte reopening. Accordingly, the court denied the petition as to the statutory motions and dismissed the petition as to sua sponte reopening. View "Aristy-Rosa v. Attorney General United States of America" on Justia Law

Millentine Coates v. Ford Motor Co

2026-08-31T09:00:04-08:00

The appellant was injured in a car accident while driving a 2002 Ford Explorer in the U.S. Virgin Islands when the vehicle’s airbags allegedly deployed spontaneously, resulting in a loss of control and a collision with a hillside. She claimed that a defect in the vehicle’s airbag system caused the incident. The vehicle had a lengthy history, having changed ownership multiple times, and had been involved in several prior accidents and repairs. Central to her claim was the vehicle’s restraint control module (RCM), which did not record any crash or deployment event during the incident, though its data was available for inspection. The appellant’s experts suggested further testing of the RCM and its sensors, but this was not performed. The case was originally filed in the Superior Court of the Virgin Islands and was removed to the District Court of the Virgin Islands. After various procedural steps, including a transfer to and from the United States District Court for the Eastern District of Michigan, the District Court of the Virgin Islands granted summary judgment to Ford. The court found that, even assuming the applicability of Section 3 of the Restatement (Third) of Torts (“malfunction theory”), the appellant had not provided sufficient evidence to show a defect existed at the time of sale, that such a defect caused the airbag deployment, or that it was the proximate cause of her injuries. The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the malfunction theory’s relaxed evidentiary standard did not apply because the allegedly defective product was available for inspection. Even if the standard applied, the appellant’s evidence was too speculative to create a genuine dispute of material fact. The court affirmed the District Court’s grant of summary judgment in favor of Ford. View "Millentine Coates v. Ford Motor Co" on Justia Law

MacDonald v. President NJ State Board of Medical Examiners

2026-08-31T09:00:04-08:00

Several plaintiffs challenged a New Jersey law requiring any doctor who wishes to provide telemedicine services to a patient located in New Jersey to first obtain a license from the state’s Board of Medical Examiners. The plaintiffs included two physicians licensed outside New Jersey and three New Jersey residents who wanted to receive virtual medical consultations from those doctors. The doctors argued that New Jersey’s licensing requirement placed an undue burden on their ability to provide telemedicine services, especially since they were already licensed in their home states. The patients and a parent also raised claims based on their rights to receive medical advice and direct their child’s care. The United States District Court for the District of New Jersey dismissed all the plaintiffs’ claims for failure to state a claim. The court held that the licensing requirement did not violate the First Amendment, the dormant Commerce Clause, the Privileges and Immunities Clause, or substantive due process. The plaintiffs appealed, maintaining that the law, as applied, unconstitutionally restricted their right to free speech and imposed excessive burdens on interstate medical practice. The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal of all claims, with one modification. The Third Circuit held that requiring a medical license to provide telemedicine services is a content-based restriction on speech, but such regulations have a long tradition and thus do not warrant strict scrutiny. Instead, the law survives intermediate scrutiny because the burdens imposed are not substantial compared to New Jersey’s interest in ensuring competent medical care. The court further held that the law does not violate the dormant Commerce Clause or the Privileges and Immunities Clause, as it applies equally to all doctors regardless of their state of residence. The court also found that the plaintiff asserting a substantive due process right lacked standing, and that claim was ordered dismissed without prejudice for lack of jurisdiction. View "MacDonald v. President NJ State Board of Medical Examiners" on Justia Law

Americans for Prosperity Foundation v. Albence

2026-08-31T09:00:04-08:00

Two nonprofit organizations that engage in nationwide issue advocacy challenged Delaware’s Elections Disclosure Act, which requires groups spending over $500 on electioneering communications near an election to publicly disclose donors giving more than $100 during the relevant cycle. The law’s disclosure obligations are broad: they are not limited to donors earmarking funds for political ads, nor can donors avoid disclosure by restricting the use of their contributions. The law also looks back several years for purposes of disclosure. The organizations, which have not previously run such communications in Delaware but claim they intend to do so in the upcoming election, argue that the law violates the First Amendment. After the organizations filed suit in the U.S. District Court for the District of Delaware, they sought a preliminary injunction to halt enforcement of the Act. The District Court denied the request, finding no likelihood of success on the facial challenge because prior Third Circuit precedent, Delaware Strong Families v. Attorney General of Delaware, had upheld the Act and the Supreme Court’s subsequent decision in Americans for Prosperity Foundation v. Bonta did not clearly abrogate that ruling. The court also doubted the as-applied challenge, citing the plaintiffs’ failure to offer specific evidence of harm to donors. The District Court emphasized the law’s decade-long enforcement and the lack of urgent need to change the status quo. The United States Court of Appeals for the Third Circuit reviewed the denial. Applying a deferential standard, the court found that the plaintiffs had not made a clear showing of entitlement to a preliminary injunction. It held that even with some likelihood of success and possible irreparable injury, the balance of equities and the public interest favored preserving the longstanding status quo. The court affirmed the District Court’s order denying the preliminary injunction. View "Americans for Prosperity Foundation v. Albence" on Justia Law

Santoro v. Tower Health

2026-08-28T09:00:05-08:00

Two individuals, who were patients of a regional healthcare provider, filed a class action lawsuit alleging that the provider’s website used tracking software to intercept and share users’ personally identifiable health information with a third-party technology company. This software, known as Meta Pixel, collected data such as IP addresses, device identifiers, and details about users’ interactions with the website, transmitting this information to the technology company, which then used it for commercial purposes, including targeted advertising. The healthcare provider also received data analysis from the technology company and was paid for allowing access to this information. The plaintiffs claimed they did not consent to this sharing of their health information. After the claims against the technology company were transferred to another district, the U.S. District Court for the Eastern District of Pennsylvania reviewed several amended complaints against the healthcare provider. The District Court dismissed the plaintiffs’ second amended complaint with prejudice, concluding that the allegations did not sufficiently specify what personal health information was actually shared and that further amendment would be futile. When the plaintiffs sought reconsideration and submitted a proposed third amended complaint, the District Court denied the motion, citing undue delay because the plaintiffs could have included the new details earlier and had been clearly informed of the deficiencies. The United States Court of Appeals for the Third Circuit reviewed the case and affirmed both orders of the District Court. The Third Circuit held that, although plaintiffs had Article III standing, the District Court did not abuse its discretion in dismissing the second amended complaint with prejudice or in denying the motion for reconsideration. The appellate court concluded that plaintiffs had sufficient notice of the complaint’s deficiencies after oral argument and did not act promptly to address them, justifying denial of further amendment. View "Santoro v. Tower Health" on Justia Law

Morocho v. Warden Philadelphia FDC

2026-08-28T09:00:04-08:00

Two individuals, citizens of Ecuador and Brazil, respectively, entered the United States without inspection in 2001 and 2014. In late 2025 and early 2026, each was arrested by U.S. Immigration and Customs Enforcement and detained, without the possibility of bond, under 8 U.S.C. § 1225(b)(2)(A). This marked a change in government practice, as similar noncitizens had previously been detained or released under 8 U.S.C. § 1226(a), which allows for discretionary bond if the person is not a danger or flight risk. In 2025, the government began applying § 1225(b)(2)(A) to noncitizens already present in the United States who entered without inspection, resulting in mandatory detention without bond. Both individuals filed habeas petitions in the United States District Court for the Eastern District of Pennsylvania, arguing their detentions violated the Immigration and Nationality Act (INA). The district courts granted their petitions, finding that § 1225(b)(2)(A) did not apply to them and that their continued detention without bond violated the INA. One district court also held that such detention violated the Fifth Amendment’s Due Process Clause. Both petitioners were subsequently released, and the government appealed these decisions. The United States Court of Appeals for the Third Circuit reviewed the statutory language and structure of the INA and considered relevant precedent. The court held that § 1225(b)(2)(A) applies only to noncitizens who are both “applicants for admission” and “seeking admission,” meaning those engaged in a present or ongoing attempt to gain lawful entry into the United States. The court concluded that noncitizens already present in the United States who are not actively seeking admission are not subject to mandatory detention under this provision and should be considered under § 1226(a), which allows for bond. The Third Circuit also held that detaining such individuals without a bond hearing violates the Due Process Clause. The court affirmed the district courts’ orders directing the release of the petitioners. View "Morocho v. Warden Philadelphia FDC" on Justia Law

USA v. McIver

2026-08-26T09:00:04-08:00

A member of Congress from New Jersey was charged with three counts of violating federal law after allegedly physically interfering with federal officials during an oversight visit to a federal immigration detention facility in Newark. During the visit, the Congresswoman and other Representatives encountered Newark’s Mayor, who was ordered to leave the premises by federal agents. When federal agents attempted to arrest the Mayor, the Congresswoman allegedly placed herself between the Mayor and an agent, forcibly made contact with the agent, and later pushed past another federal officer to reenter the facility. The charges stem from these physical altercations and the Congresswoman’s efforts to impede the Mayor’s arrest. The United States District Court for the District of New Jersey denied the Congresswoman’s motions to dismiss the indictment. The court found that her conduct was not protected by legislative immunity under the Speech or Debate Clause, concluding it was non-legislative in nature. The court also rejected her arguments based on the separation of powers doctrine, distinguishing between Presidential and legislative immunities. Additionally, the court ruled against her selective and vindictive prosecution claims, finding she failed to demonstrate discriminatory effect or personal animus by the prosecution. The United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit affirmed the denial of legislative immunity for Counts One and Two, holding that prosecution of those charges would not require the Congresswoman to answer for any legislative acts. The court vacated and remanded with respect to Count Three for further consideration as to whether legislative immunity might apply. The court dismissed the remainder of her appeal, including claims of selective and vindictive prosecution, for lack of jurisdiction. View "USA v. McIver" on Justia Law

USA v. Figueroa

2026-08-25T09:00:05-08:00

On June 6, 2014, the defendant armed himself and traveled from New York to Pennsylvania, where he attacked his ex-girlfriend (Victim 1), forcibly abducted her, and then drove her across state lines to New Jersey. During this ordeal, he threatened and physically assaulted her, then sexually assaulted her at a rest stop. After Victim 1 managed to escape, the defendant assaulted a National Park Service maintenance worker (Victim 2) and stole his vehicle, then proceeded to commit arson at a business owned by his former partners. He was apprehended after a police chase in New York. A grand jury in the United States District Court for the District of New Jersey initially indicted the defendant on six counts, including kidnapping, aggravated sexual abuse, firearm offenses, assault of a federal employee, and arson. Over nearly eight years, the case was continued multiple times due to plea negotiations, questions of competency, and the defendant’s own motions and changes in counsel. The defendant entered into a plea agreement, pled guilty to several charges, and waived certain statute of limitations defenses, but later moved to withdraw his plea, claiming innocence and coercion. The District Court accepted the withdrawal. The government subsequently filed superseding indictments, and the defendant continued to challenge the timeliness of certain charges and raised speedy trial concerns, but the District Court denied these motions. At trial, the defendant pled guilty to two counts and was found guilty on the remaining charges by a jury. The United States Court of Appeals for the Third Circuit reviewed several claims, including whether the statute of limitations waiver in the earlier plea agreement remained enforceable after the plea was withdrawn, whether the District Court erred in its jury instructions regarding the elements of kidnapping and the status of the assaulted federal employee, and whether the lengthy pretrial delay violated the defendant’s speedy trial rights. The Third Circuit held that the statute of limitations waiver survived the plea withdrawal due to the language of the agreement, and that the guilty plea to one count barred a statute of limitations challenge to that conviction. The court found any jury instruction errors harmless in light of overwhelming evidence, and concluded that, under the Barker v. Wingo factors, the delay did not violate the defendant’s constitutional right to a speedy trial. The Third Circuit affirmed the judgment of the District Court. View "USA v. Figueroa" on Justia Law

Mejia-Henriquez v. Attorney General United States of America

2026-08-25T09:00:05-08:00

A citizen of El Salvador entered the United States illegally in 2015 and later applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). He settled near Baltimore, worked in construction, started a family, but encountered legal trouble, including a conviction for conspiracy to commit armed robbery. The government initiated removal proceedings, and he conceded removability. He argued that, due to his tattoos, criminal history, and a Salvadoran indictment linking him to gang activity, he would face torture in El Salvador, either from the government or gangs, and thus sought CAT relief. An Immigration Judge found the petitioner not credible, denied all forms of relief, and ordered removal. The judge concluded that the poor prison conditions in El Salvador did not amount to torture and found insufficient evidence that the petitioner would be singled out for torture. The Board of Immigration Appeals (BIA) affirmed the Immigration Judge’s decision, and the petitioner challenged only the denial of CAT relief to the United States Court of Appeals for the Third Circuit. While his petition was pending, the Third Circuit lifted a stay of removal, resulting in his deportation to El Salvador, where he was detained. The United States Court of Appeals for the Third Circuit dismissed the petition as moot. The court held that, because the petitioner had already been removed and was incarcerated abroad, there was no longer any removal to defer, and thus no effectual relief could be provided. The court further concluded that the collateral consequences of removal, such as a bar on reentry, were not redressable by granting CAT relief, since CAT relief does not disturb the underlying removal order. The court also found that the government’s policy of facilitating returns did not apply to the petitioner’s circumstances. View "Mejia-Henriquez v. Attorney General United States of America" on Justia Law

Timofey V v. USA

2026-08-25T09:00:04-08:00

Two individuals associated with a Russian nonprofit registered the domain name waronfakes.com through a Russian registrar in March 2022. This domain hosted content focused on Russian political issues. In August 2024, the United States government seized the domain and others, alleging violations of the international money laundering statute and the International Emergency Economic Powers Act (IEEPA). The government claimed the domain was used to promote Russian disinformation on behalf of sanctioned individuals and entities, and that the purchase of the domain involved funds transferred for the benefit of a blocked person under U.S. sanctions. Five days after the seizure, the nonprofit and its director were added to the U.S. Treasury’s blocked persons list, which prohibits the transfer or dealing in their U.S.-based property without a license. The applicants, Timofey V and ANO Dialog, moved in the United States District Court for the Eastern District of Pennsylvania for the return of the domain under Federal Rule of Criminal Procedure 41(g). The government opposed the motion, arguing that the applicants were not lawfully entitled to possess the property as they were now blocked persons under U.S. sanctions and lacked the required license from the Office of Foreign Assets Control (OFAC). The District Court denied the motion without an evidentiary hearing, concluding that the applicants could not lawfully receive the domain. On appeal, the United States Court of Appeals for the Third Circuit held that although the applicants had standing due to a sufficient possessory interest, they failed to establish lawful entitlement to the property because transfer to them was blocked by sanctions and no OFAC license had been obtained. The court further found no abuse of discretion in the District Court’s denial of an evidentiary hearing, as the legal impediment to transfer was undisputed. The judgment of the District Court was affirmed. View "Timofey V v. USA" on Justia Law

Salvatora v. XTO Energy Inc

2026-08-24T09:00:04-08:00

Six landowners in Western Pennsylvania, believing that XTO Energy, Inc. was underpaying royalties owed under oil and gas leases, brought a class action in the U.S. District Court for the Western District of Pennsylvania. None of the named plaintiffs’ leases included arbitration clauses, but the proposed class definitions were broad enough to cover leaseholders whose leases did contain arbitration clauses. The plaintiffs sought damages on behalf of themselves and similarly situated landowners. After the suit was filed, the District Court oversaw extensive class discovery and certified classes that included some members whose leases had arbitration clauses. XTO did not assert arbitration as a defense in its answers or move to compel arbitration before class certification or before the expiration of the class opt-out period. It only moved to compel arbitration against those unnamed class members with arbitration clauses after the opt-out period closed. Relying in part on the then-controlling district court decision in Valli v. Avis Budget Rental Car Group, LLC, a Magistrate Judge found that XTO had waived its right to arbitrate by demonstrating a preference for litigation over arbitration, and the District Court adopted that ruling. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s waiver determination de novo as to legal conclusions and for clear error as to factual findings. The Third Circuit held that, under its intervening precedential decision in Valli v. Avis Budget Group, Inc., a defendant does not waive its right to compel arbitration against unnamed class members with arbitration clauses in their leases merely by litigating prior to class certification, where none of the named plaintiffs are subject to arbitration. The court found XTO’s conduct did not constitute an implied waiver. The Third Circuit vacated the District Court’s order denying XTO’s motion to compel arbitration and remanded for further proceedings. View "Salvatora v. XTO Energy Inc" on Justia Law

Parkin v. Avis Rent a Car System LLC

2026-08-24T09:00:04-08:00

Two foreign nationals from the United Kingdom rented vehicles from a car rental company during separate visits to the United States. Each used a third-party website to reserve vehicles and selected a package that included supplemental liability insurance. Upon arriving at the rental location, they signed rental forms and received a “rental jacket” that contained additional terms, including a statement that supplemental liability insurance would be provided via an excess automobile policy and an arbitration clause requiring most disputes to be resolved through arbitration. Later, the customers believed the company did not actually secure the promised insurance policy but intended to pay claims from its own funds. They filed a putative class action in the U.S. District Court for the District of New Jersey, asserting breach of contract, fraudulent misrepresentation, and a violation of Florida’s consumer protection law. The District Court dismissed the fraud and statutory claims but allowed the contract claim to proceed. The defendants, Budget and its parent company, reserved their right to arbitrate and pursued discovery. After deposing the plaintiffs, the defendants moved to compel arbitration, arguing the plaintiffs were aware of the arbitration clause when they received the rental jackets. The District Court denied the motion, finding that by litigating into discovery before moving to compel arbitration, the defendants had impliedly waived their right to arbitrate. On appeal, the United States Court of Appeals for the Third Circuit reviewed the waiver determination de novo. The Third Circuit held that the defendants did not impliedly waive their right to arbitrate. Because factual development was necessary to determine arbitrability under a prior circuit decision, the defendants’ conduct—reserving their arbitration right and moving to compel after depositions—was not inconsistent with an intent to arbitrate. The Third Circuit vacated the District Court’s order and remanded for further proceedings on the motion to compel arbitration. View "Parkin v. Avis Rent a Car System LLC" on Justia Law

USA v. Epps

2026-08-21T09:00:13-08:00

A woman was arrested in Delaware for selling drugs from a motel room, and police recovered heroin and fentanyl in labeled packets from her possession. After her arrest, she cooperated with police and identified her supplier as a man who would be delivering more drugs to the motel. Police surveilled the motel and, after a series of monitored calls, arrested Philip Epps when he arrived in a white SUV, matching the description provided. Evidence seized included two iPhones (one linked to the supplier), large amounts of cash, firearms, and more drugs with the same identifying labels. Forensic evidence further tied Epps to the operation, and the government presented this at trial. Epps offered no evidence in his defense. The United States District Court for the District of Delaware conducted the jury trial. After deliberating for a few hours, the jury indicated it was deadlocked. The court provided a supplemental instruction, which incorrectly stated, “you have to” reach a unanimous verdict. Neither party objected at the time. The jury subsequently returned guilty verdicts on all counts. Two weeks later, Epps moved for a new trial under Federal Rule of Criminal Procedure 33, arguing the supplemental instruction was unduly coercive. The District Court initially denied the motion, but upon reconsideration, it granted a new trial, concluding that justice required it due to the problematic instruction. The government appealed. The United States Court of Appeals for the Third Circuit reviewed the case. It held that while the District Court’s supplemental instruction misstated the law by suggesting the jury was required to reach a verdict, this error, when considered in the context of the entire jury charge, was not unduly coercive and did not prejudice Epps. Therefore, the Third Circuit reversed the District Court’s order granting a new trial and remanded for further proceedings. View "USA v. Epps" on Justia Law

USA v. Birry

2026-08-21T09:00:13-08:00

Police officers in Blakely, Pennsylvania, stopped a car with a cracked windshield and expired registration. The car had two occupants: the driver, who lacked a valid insurance card and was unsure about his recent whereabouts, and Christopher Essameddin Birry, the passenger. When the officers discovered that the driver had an outstanding arrest warrant, they detained him and announced that the car would be towed. While processing the scene, the officers asked Birry for identification and questioned him about his relationship with the driver. After several requests for Birry to keep his hands visible, one officer asked for consent to search Birry, which Birry granted. During the pat-down, officers found drugs, a loaded firearm, and other contraband in Birry’s pantleg. Birry was indicted on several counts, including possession with intent to distribute controlled substances and firearm offenses. The United States District Court for the Middle District of Pennsylvania held an evidentiary hearing on Birry’s motion to suppress the evidence found during the stop. Birry argued that the officers unlawfully prolonged the stop and exceeded the scope of his consent during the search. The District Court denied the motion, finding both the duration of the stop and the scope of the search constitutionally permissible. Birry entered a conditional guilty plea, reserving his right to appeal the suppression ruling. The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and its legal conclusions de novo. The appellate court concluded that the officers’ questioning and actions were within the permissible bounds of a traffic stop and that the search did not exceed the scope of Birry’s consent. Accordingly, the Third Circuit affirmed the District Court’s denial of Birry’s motion to suppress, holding that both the stop and search were constitutional. View "USA v. Birry" on Justia Law

USA v. Strickland

2026-08-18T09:00:12-08:00

Kenneth Strickland was indicted for one count of conspiracy to distribute and possess with intent to distribute fentanyl and heroin, and five counts of fentanyl distribution, all based on undercover transactions that occurred between November 2019 and May 2020. At trial, the government presented testimony from an undercover officer who identified Strickland as the person who sold him the drugs, as well as testimony from other officers, a co-conspirator, forensic chemists, and various surveillance evidence. The government also introduced several bags of drugs as physical evidence. Strickland’s defense focused on mistaken identity, challenging the reliability of the officer’s identification and raising doubts about the chain of custody of the physical evidence. The United States District Court for the District of New Jersey presided over the trial. During the charge conference, Strickland requested a jury instruction that would require the government to prove the chain of custody beyond a reasonable doubt, based on the Third Circuit’s Model Criminal Jury Instructions. The District Court declined to include the final sentence of that model instruction, reasoning that its substance was already covered by other instructions regarding the government’s burden of proof. The jury found Strickland guilty on all counts, and he was sentenced to 132 months in prison. Strickland appealed, raising four issues, including the jury instruction, the exclusion of certain expert testimony, the admission of recorded calls, and the sufficiency of the evidence for conspiracy. The United States Court of Appeals for the Third Circuit affirmed the convictions. The court held, as a matter of first impression, that it is not legally required for the government to prove chain of custody beyond a reasonable doubt, as chain of custody is not an element of the crime. The panel also found that any error in excluding expert testimony or admitting recordings in bulk was harmless, and that sufficient evidence supported the conspiracy conviction. The court affirmed the District Court’s judgment. View "USA v. Strickland" on Justia Law

USA v. Tavares

2026-08-17T09:00:11-08:00

Jose Tavares was involved in a scheme, operating between July 2020 and February 2021, to fraudulently obtain COVID-19 unemployment benefits using stolen identities. He joined the conspiracy after being recruited by his then-romantic partner, Christopher Valerio. Together with other co-conspirators, they submitted fraudulent unemployment applications to the New York Department of Labor, received debit cards in victims’ names, and withdrew funds for personal use. Tavares admitted in a proffer session with the Government that he was aware of and participated in the scheme. Following a criminal complaint in December 2021, Tavares entered into a written proffer agreement with the Government, which restricted the use of his admissions except to rebut evidence or arguments he presented. In January 2024, a federal grand jury indicted Tavares for conspiracy to commit wire fraud. At trial in the United States District Court for the District of New Jersey, Tavares’s counsel argued he was unaware of the fraudulent scheme and portrayed him as an unwitting participant. The District Court allowed the Government to introduce Tavares’s proffered admissions, finding the defense’s opening statement had triggered the waiver provision of the agreement. The Court also excluded testimony regarding Tavares’s immigration status and lack of prior criminal record, permitting limited evidence about his residency status. The jury found Tavares guilty, and the District Court denied his request for a sentence reduction for a mitigating role, ultimately sentencing him to 40 months in prison and ordering restitution. On appeal, the United States Court of Appeals for the Third Circuit reviewed Tavares’s claims that the District Court erred in admitting his proffered statements, excluding character evidence, denying a mitigating role reduction, and imposing an unreasonable sentence. The Third Circuit held that the District Court did not err in any respect and affirmed the conviction and sentence. The main holding was that a proffer waiver in an agreement can be triggered by an opening statement that advances a factual theory contrary to the defendant’s admissions, even if opening statements are not evidence. View "USA v. Tavares" on Justia Law

Aristy-Rosa v. Attorney General

2026-08-14T09:00:13-08:00

The petitioner, a noncitizen who has resided in the United States for nearly three decades, has faced a final order of removal for approximately 15 years, primarily due to a 1997 narcotics conviction in New York. He has made several unsuccessful attempts to challenge this removal order. In the present matter, he contests the Board of Immigration Appeals’ (BIA) denial of his first motion for statutory reconsideration, his second motion for statutory reopening, and his third motion for sua sponte reopening. His arguments are grounded in recent case law from another circuit, which he claims constitutes a change in the legal landscape affecting his removal. Previously, an Immigration Judge entered a final removal order on consent in 2011. The BIA subsequently denied his motions for reconsideration and reopening, citing procedural and substantive bars. The petitioner’s efforts to reopen his case in the administrative process have been repeatedly rejected, and the current petition represents his fourth attempt to avoid removal. Throughout these proceedings, he has also sought to stay his removal while his petition is pending. The United States Court of Appeals for the Third Circuit reviewed the petitioner’s request to continue a stay of removal. Applying the four-factor test from Nken v. Holder, the Third Circuit found that the petitioner failed to demonstrate a likelihood of success on the merits, irreparable harm, or that the balance of equities favored a stay. The court also determined that the public interest and the government’s interests weighed against any further delay. Additionally, the court denied the petitioner’s motion to hold the case in abeyance pending a new collateral attack on his underlying conviction, finding it untimely and not material to the immigration proceedings. As a result, the Third Circuit vacated the stay of removal, allowing the government to proceed with enforcement of the removal order. View "Aristy-Rosa v. Attorney General" on Justia Law

Gabriel v. DSM Biomedical Inc

2026-08-13T09:00:12-08:00

A black factory manager worked for a biomedical company that had been placed on a corporate safety watchlist due to recurring safety issues. He became responsible for the factory’s operations and safety. The company conducted several safety audits, including a special unannounced audit after two safety incidents were reported late. The manager believed that the head of the safety department, a white executive, targeted him with excessive scrutiny and was rude, later attributing these actions to racial bias based on his own experiences and discussions with other black employees. The company investigated possible bias after concerns were raised, finding the executive had been rude and had engaged in some microaggressions or unconscious bias, but no blatant racial discrimination. After the factory manager filed a discrimination charge with the EEOC, a dispute with the interim president led him to send group messages that a recipient interpreted as threatening. The company suspended the manager with pay pending investigation. He then left the company and filed suit under Title VII, alleging racial discrimination and retaliation. The United States District Court for the Eastern District of Pennsylvania granted summary judgment to the employer. It found no evidence that the alleged actions harmed any identifiable term or condition of the manager’s employment, nor that any actions were racially motivated. The court also concluded there was no evidence of retaliation, as the suspension was due to the perceived threatening messages. The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The Third Circuit held that the manager failed to establish a prima facie case of racial discrimination or retaliation under Title VII. The court found that neither the alleged conduct nor the suspension constituted unlawful discrimination or retaliation. View "Gabriel v. DSM Biomedical Inc" on Justia Law

Timmons v. Bohinski

2026-08-12T09:00:12-08:00

An inmate at a Pennsylvania state prison alleged that a supervisory official publicly labeled him a “snitch” in front of other inmates, allegedly as retaliation for the inmate’s previous lawsuits against correctional staff. The inmate claimed this exposed him to risk and also asserted that the official later admitted using the term to deter further lawsuits. After several claims were dismissed, the only ones remaining were brought under 42 U.S.C. § 1983, alleging violations of the First, Eighth, and Fourteenth Amendments. The defendant argued that these claims should be dismissed because the inmate did not exhaust available administrative remedies as required by the Prison Litigation Reform Act (PLRA). In response, the inmate, representing himself, submitted a sworn declaration stating that the prison’s grievance process was unavailable to him due to intimidation and threats by corrections officers, which deterred him from filing grievances against the defendant. The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the defendant, finding the declaration insufficient to show the grievance process was unavailable. The United States Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. The appellate court held that the District Court erred in rejecting the inmate’s declaration at the summary judgment stage, as the declaration provided enough specific facts to create a genuine dispute regarding whether the grievance process was rendered unavailable by intimidation. The Third Circuit vacated the summary judgment and remanded the case for further proceedings, instructing the District Court to determine whether a jury trial on exhaustion is required due to potential intertwinement with the merits, as set forth in Perttu v. Richards, 605 U.S. 460 (2025). View "Timmons v. Bohinski" on Justia Law

USA v. Clerfe

2026-08-10T10:00:12-08:00

Between December 2017 and February 2018, Derby Clerfe purchased nine 9mm handguns from a Pennsylvania sporting goods store. Federal authorities, finding this purchasing pattern suspicious, interviewed Clerfe, who admitted arranging for the guns to be shipped to Haiti through a third party, without declaring them as required by law. He acknowledged the guns may have been concealed and had not yet arrived in Haiti. Clerfe was charged with conspiracy to violate U.S. laws prohibiting the export of firearms without proper filing, as well as transferring firearms to an unlicensed out-of-state resident. The U.S. District Court for the Western District of Pennsylvania reviewed the charges. Clerfe moved to dismiss the indictment on the grounds that the laws he was charged under violated the Second Amendment, constituted an unconstitutional delegation of legislative authority to the executive branch, and were unconstitutionally vague. The District Court denied his motion. Clerfe then pleaded guilty to one count of conspiracy but reserved the right to appeal the denial of his motion on Second Amendment and non-delegation grounds. The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the laws prohibiting Clerfe from exporting handguns to Haiti did not violate the Second Amendment because the right to “keep and bear Arms” does not encompass sending firearms abroad in violation of export laws. The court further held that the Arms Export Control Act’s delegation to the President to designate “defense articles” for export control satisfies the constitutional “intelligible principle” standard, and thus does not violate the non-delegation doctrine. Accordingly, the Third Circuit affirmed the District Court’s denial of Clerfe’s motion to dismiss the indictment. View "USA v. Clerfe" on Justia Law

S.A.S.B. CORP v. Johnson & Johnson Health Care Systems Inc

2026-08-07T09:00:20-08:00

A Florida pharmacy received a two-page fax from subsidiaries of Johnson & Johnson, which described a patient support program called Janssen CarePath that offered resources and savings options to help patients afford Xarelto, a prescription anticoagulant. The fax outlined how the program could assist patients regardless of their insurance status and included information about Xarelto’s uses and side effects, with instructions to explore savings options on a website. The pharmacy alleged that this fax was an unsolicited advertisement in violation of the Telephone Consumer Protection Act (TCPA). The United States District Court for the District of New Jersey initially dismissed the pharmacy’s complaint on two grounds: that the fax was not an advertisement under the TCPA and that the pharmacy did not plausibly allege the defendants had sent the fax. The pharmacy amended its complaint, and the defendants again moved to dismiss. The District Court granted the second motion solely on the basis that the fax did not qualify as an advertisement within the meaning of the TCPA, declining to address other arguments. The United States Court of Appeals for the Third Circuit reviewed the case, applying plenary review to the District Court's grant of the motion to dismiss. The Third Circuit held that a reasonable factfinder could determine the fax promoted Xarelto with profit as an aim, making it plausible that it was an unsolicited advertisement under the TCPA. The court also found that the pharmacy adequately alleged the defendants sent the fax and put both defendants on notice. The Third Circuit reversed the District Court's dismissal, allowing the pharmacy's claim to proceed. View "S.A.S.B. CORP v. Johnson & Johnson Health Care Systems Inc" on Justia Law

Prospect Capital Management LP v. Stratera Holdings LLC

2026-08-04T09:00:11-08:00

This case involves a dispute among business partners regarding the calculation and distribution of administrative fees earned from the sale of shares in a jointly managed investment fund. Prospect Capital Management L.P. (“Prospect”) acted as the fund administrator, while Stratera Holdings, LLC (“Stratera”) and Destra Capital Managers LLC (“Destra”) were entitled to share in fees depending on how fund shares were issued, including through a dividend reinvestment program (“DRIP”). After a change in sub-wholesaler, ambiguity arose in the contract language about whether certain DRIP shares—specifically, those issued by Stratera’s predecessor, Provasi—should be included in fee calculations. Prospect excluded these shares, reducing the amount paid to Stratera and Destra. Stratera and Destra initiated arbitration under the contract’s dispute resolution clause. The arbitration panel’s initial “Interim Award” found that Prospect had breached the contract by excluding DRIP shares for which Destra served as sub-wholesaler, but the award’s language left unclear whether this ruling applied to DRIP shares issued earlier by Provasi. When the parties could not agree on the scope of the award, the panel issued a revised interim award clarifying that fees were owed for DRIP shares issued by both Provasi and Destra. Prospect then petitioned the United States District Court for the District of Delaware to vacate the revised award, arguing that the arbitrators had unlawfully revisited a final decision in violation of the functus officio doctrine. The District Court rejected this claim, finding that the ambiguity exception to functus officio permitted the arbitrators’ clarification. On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s order. The court held that the ambiguity exception to the functus officio doctrine applied because the interim award was susceptible to more than one reasonable interpretation. Therefore, the panel acted within its authority in clarifying its award. View "Prospect Capital Management LP v. Stratera Holdings LLC" on Justia Law

Lisenby v. Olympus Corporation of the Americas

2026-08-04T09:00:11-08:00

An executive at a group of medical device companies that sell products to the federal government raised internal concerns in early 2024 that the company was violating Food and Drug Administration (FDA) regulations related to product design, quality management, and testing. He believed that selling a particular product without addressing these regulatory deficiencies could result in misrepresenting data to the FDA to obtain approval. Over a two-week period, he communicated these concerns to multiple executives and suggested implementing changes to improve compliance. Shortly after these communications, his position was eliminated. Following his termination, the executive filed suit in the United States District Court for the Eastern District of Pennsylvania, alleging, among other claims, that his employer retaliated against him in violation of the False Claims Act (FCA)’s anti-retaliation provision. The District Court dismissed the FCA retaliation claim, holding that the complaint failed to allege a sufficient connection between the plaintiff’s concerns about FDA violations and the submission of false claims for payment to the federal government, and thus did not constitute protected conduct under the FCA. On appeal, the United States Court of Appeals for the Third Circuit reviewed two questions: whether FCA retaliation claims are subject to Rule 9(b)’s heightened pleading standard, and what constitutes protected conduct under the “other efforts” prong of the FCA’s anti-retaliation provision. The court held that FCA retaliation claims are not subject to Rule 9(b), but instead require only notice pleading under Rule 8(a). It further held that, to constitute protected conduct, a plaintiff’s actions must be motivated by an objectively reasonable belief that the employer is submitting or will submit false or fraudulent claims for payment to the government. Finding no such allegation in the complaint, the Third Circuit affirmed the District Court’s dismissal of the FCA retaliation claim. View "Lisenby v. Olympus Corporation of the Americas" on Justia Law

Pennsylvania Game Commission v. Proctor Heirs Trust

2026-07-31T09:00:12-08:00

The dispute centers on ownership rights to the subsurface estate—specifically oil, gas, and mineral rights—of a tract of land known as the Josiah Haines warrant in northeastern Pennsylvania. In 1894, the surface estate was sold to Union Tanning Company, but the subsurface rights were expressly reserved by Thomas E. Proctor, the Trust’s predecessor. The surface estate passed through several owners, ultimately to Central Pennsylvania Lumber Company (CPLC). After CPLC failed to pay taxes in 1907, the land was sold at a 1908 tax sale to Calvin H. McCauley, Jr., a close associate of CPLC. Shortly thereafter, McCauley transferred the land back to CPLC. In 1920, CPLC conveyed the land to the Pennsylvania Game Commission, subject to the prior reservation of subsurface rights. Both the Game Commission and the Trust sought to quiet title and establish ownership of the subsurface estate. The U.S. District Court for the Middle District of Pennsylvania held a bench trial to resolve factual disputes, including the nature of the 1908 tax sale and whether McCauley acted as CPLC’s agent. The District Court found that CPLC was obligated to pay taxes on the surface estate and had breached that duty, and that McCauley acted as CPLC’s agent in purchasing the property at the tax sale. The court concluded that, under Pennsylvania law, this transaction did not extinguish the Trust’s subsurface rights and ruled in favor of the Trust. The U.S. Court of Appeals for the Third Circuit reviewed whether the Game Commission was a citizen of Pennsylvania for diversity jurisdiction purposes, applying the Supreme Court’s recent framework from Galette v. New Jersey Transit Corp. The Third Circuit held that the Game Commission is a citizen, not an arm of the state, thus diversity jurisdiction was proper. The Court affirmed the District Court’s judgment, holding that the 1908 tax sale did not divest the Trust of its subsurface ownership. View "Pennsylvania Game Commission v. Proctor Heirs Trust" on Justia Law

Hartmann v. Chudzik

2026-07-31T09:00:12-08:00

Several individuals arrested in Lancaster County, Pennsylvania, were detained pending trial after cash bail was set at their preliminary arraignments. At these arraignments, which were conducted via video without counsel present, the Magisterial District Judges allegedly imposed bail without considering the defendants’ ability to pay or other required factors under state law. Because they could not afford bail, the plaintiffs remained incarcerated. They brought a class action against four Magisterial District Judges (in their official capacities), Lancaster County, and the Warden of the county prison, alleging violations of their rights to equal protection, due process, and counsel. The United States District Court for the Eastern District of Pennsylvania first dismissed the plaintiffs’ Sixth Amendment claim, holding that the right to counsel attaches at the preliminary arraignment but does not require counsel’s presence at that proceeding, relying on Supreme Court precedent. The District Court later abstained from hearing the equal protection and due process claims under the doctrine established in Younger v. Harris, reasoning that federal intervention would improperly intrude upon ongoing state criminal proceedings and that state courts could address the plaintiffs’ bail-related claims. On appeal, the United States Court of Appeals for the Third Circuit reviewed both rulings. The Third Circuit held that Younger abstention was inappropriate because the plaintiffs did not seek to enjoin ongoing state criminal prosecutions but rather challenged procedures ancillary to those prosecutions—specifically, the process by which bail was set. Therefore, the District Court’s abstention was vacated and the matter remanded for further proceedings on the equal protection and due process claims. However, the Third Circuit affirmed the dismissal of the Sixth Amendment claim, holding that the preliminary arraignment under Pennsylvania law is not a “critical stage” requiring the presence of counsel, even though the right to counsel attaches at that point. View "Hartmann v. Chudzik" on Justia Law

USA v. Turbe

2026-07-31T09:00:11-08:00

A defendant was arrested in November 2024 at the Cyril E. King Airport in the Virgin Islands after law enforcement discovered nearly 12 kilograms of marijuana in his luggage. He subsequently pled guilty to possession with intent to distribute marijuana. The presentence report calculated an advisory Guidelines range of 12 to 18 months’ imprisonment and two to three years of supervised release, taking into account two prior convictions and three earlier arrests, although only two of these arrests had factual descriptions; the circumstances of the third were unknown. The District Court for the Virgin Islands sentenced the defendant to six months’ imprisonment followed by three years of supervised release, with the first six months served under home detention. The defendant requested probation, while the government sought a 12-month prison sentence. The District Court denied the defendant’s objection to the inclusion of the arrest records in the PSR, explaining that while it did not place much weight on arrests not leading to convictions, they could be relevant for other purposes. The District Court imposed a within-Guidelines sentence and addressed arguments regarding the defendant’s criminal history, deterrence, and sentencing disparities. The United States Court of Appeals for the Third Circuit reviewed the case on appeal. The main holding is that the District Court did not violate the defendant’s due process rights by impermissibly relying on his bare arrest record when determining his sentence. The Third Circuit found that the District Court did not actually rely on the defendant’s arrests not leading to conviction, but only referenced them in passing, and the record showed reliance on prior convictions alone. The Court also held that the District Court adequately explained its sentence and that the sentence was substantively reasonable. The judgment and sentence of the District Court were affirmed. View "USA v. Turbe" on Justia Law

Anash Inc v. Borough of Kingston

2026-07-30T09:00:11-08:00

A municipality in Pennsylvania investigated two properties owned by a rabbi after receiving complaints about their use. One property was used as a residence for young men engaging in religious study, while the other served as a space for prayer, study, and religious instruction. Both properties were located in a commercially zoned district. Citing a new zoning ordinance, the municipality issued violation notices to the rabbi, asserting that such religious uses were not permitted in the district. The municipality then obtained administrative search warrants, conducted inspections, and condemned the properties the day before a major religious holiday, barring occupancy until the buildings were brought into compliance. The municipality also threatened daily fines for continued non-compliance. The rabbi and his congregation filed suit in the U.S. District Court for the Middle District of Pennsylvania against the municipality and its officers, raising several claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA), among other federal and state claims. They sought a preliminary injunction to regain access to the properties and halt enforcement actions during litigation. The District Court denied their request, finding no likelihood of success on the merits or irreparable harm, and reasoning that alternative locations for religious activities were available. On interlocutory appeal, the United States Court of Appeals for the Third Circuit reviewed the denial of preliminary injunctive relief. The Third Circuit held that the plaintiffs were likely to succeed on their RLUIPA substantial-burden claim as to the zoning ordinance, since enforcement prevented access to property for religious exercise and imposed significant penalties. The court found irreparable harm and determined that the balance of hardships and public interest favored the plaintiffs. The Third Circuit reversed the District Court’s order denying a preliminary injunction and remanded for further proceedings, instructing the lower court to enter appropriate injunctive relief. View "Anash Inc v. Borough of Kingston" on Justia Law

Cornish-Adebiyi v. Caesars Entertainment Inc

2026-07-29T09:00:11-08:00

A group of consumers who rented rooms at several Atlantic City casino-hotels alleged that the hotels and their shared software provider, Cendyn Group, conspired to fix prices for hotel rooms in violation of Section 1 of the Sherman Antitrust Act. The plaintiffs claimed that the hotels supplied non-public pricing and occupancy data to Cendyn’s Rainmaker software, which uses artificial intelligence to generate room rate recommendations. According to the plaintiffs, the hotels overwhelmingly accepted these rate recommendations, resulting in inflated room prices and diminished competition, as the hotels no longer competed aggressively on room rates to attract guests to their casinos. Previously, the United States District Court for the District of New Jersey dismissed the complaint. The District Court concluded that the plaintiffs failed to plausibly allege a hub-and-spoke price-fixing conspiracy because there was insufficient evidence of an agreement or “rim” among the hotel defendants themselves. The court found that the complaint’s allegations mainly described parallel conduct and did not adequately show that the hotels exchanged confidential information or coordinated their pricing decisions through the software platform. The United States Court of Appeals for the Third Circuit reviewed the District Court’s dismissal de novo. The Third Circuit held that the complaint’s well-pleaded allegations, taken as true, plausibly supported the existence of a horizontal price-fixing conspiracy facilitated by the dynamic pricing algorithm. The court found that the combination of the hotels’ use of the same software, the exchange of non-public data, the high rate of adherence to the algorithm’s recommendations, and the economic circumstances provided sufficient circumstantial evidence—augmented by “plus factors”—to infer collusion. The Third Circuit reversed the District Court’s dismissal and remanded the case for further proceedings. View "Cornish-Adebiyi v. Caesars Entertainment Inc" on Justia Law

In re Alecto Healthcare Services LLC

2026-07-28T09:00:11-08:00

A healthcare holding company with several subsidiaries faced significant financial distress during the COVID-19 pandemic, resulting in the closure of one of its hospitals and the loss of hundreds of jobs. Former employees of this hospital, known as the Reed Creditors, obtained a judgment against the company for unpaid wages. Shortly after this judgment, the company filed for bankruptcy under Subchapter V of Chapter 11, which is available only to debtors with less than $7.5 million in liquidated, noncontingent debt. The company’s filings listed a disputed debt to LHP Hospital Group, Inc. (LHP) as unliquidated and contingent, based on the terms of a recent settlement agreement that required LHP to make a written demand for payment before any obligation would arise. The United States Bankruptcy Court for the District of Delaware found that, because LHP had not made a demand before the bankruptcy filing, the debt was both contingent and unliquidated. This meant the company qualified for Subchapter V relief. The Bankruptcy Court also approved the company’s reorganization plan, which included a settlement with insiders in exchange for a release of potential avoidance (fraudulent transfer) claims. The court determined, after hearing testimony, that there was little likelihood of success on those claims and that the settlement was reasonable. The United States District Court for the District of Delaware affirmed both the eligibility determination and the approval of the plan, concluding the Reed Creditors had not shown the settlement was unreasonable. The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court’s rulings. It held that the LHP debt was properly classified as contingent and unliquidated, allowing the company to proceed under Subchapter V. The court also held that the Bankruptcy Court did not abuse its discretion in approving the settlement with insiders and overruling the Reed Creditors’ objections. The company’s motion to dismiss the appeal as moot was denied. View "In re Alecto Healthcare Services LLC" on Justia Law

Williams v. Superintendent Fayette SCI

2026-07-23T09:00:11-08:00

Stanford Williams was tried three times for the 1993 murder of Omar Massey. The first trial ended in a hung jury, and the second trial was interrupted when a key witness, John Faingnaert, changed his expected testimony regarding Williams’s exposure to gun residue. Williams’s attorney, John Elash, contemplated becoming a witness to rebut Faingnaert but acknowledged he could not continue representing Williams if he did so. The trial court concluded that Elash could not waive a potential ineffective assistance claim and, after discussion, granted a mistrial. Williams was convicted at his third trial and sentenced to life in prison. Following his conviction, Williams argued that the third trial violated his protection against double jeopardy, asserting that he had not requested or consented to the mistrial in the second trial. The Allegheny County Court of Common Pleas rejected this claim, finding that Williams had moved for a mistrial. The Pennsylvania Superior Court affirmed, holding that Williams waived his double jeopardy claim by not raising it before the third trial and that the claim lacked merit because he had requested the mistrial. Williams sought post-conviction relief, and the same trial judge found again that Williams requested the mistrial; the Superior Court affirmed this finding. Williams then filed for habeas corpus relief in the United States District Court for the Western District of Pennsylvania. The District Court granted his petition, holding that the third trial violated double jeopardy and that his counsel was ineffective for failing to raise the claim. On appeal, the United States Court of Appeals for the Third Circuit applied AEDPA deference to the state court’s findings and concluded that Williams did not provide clear and convincing evidence that the state court erred in finding he requested a mistrial. The Third Circuit held that the third trial did not violate the Double Jeopardy Clause and that Williams’s counsel was not ineffective for failing to raise a meritless double jeopardy claim. The District Court’s order was reversed. View "Williams v. Superintendent Fayette SCI" on Justia Law

Doe v. Princeton University Trustees

2026-07-21T09:00:20-08:00

A male sophomore at a private university was accused by two female students of physically assaulting them in separate incidents involving alleged choking. Both incidents occurred during the 2023 academic year and involved evolving accounts from the complainants, contradictory witness testimony, and a lack of immediate reporting. The accused, John, denied the accusations and provided evidence and witnesses in his defense, including text messages and accounts from a sole eyewitness supporting his version of events. Despite this, the university’s internal investigation and disciplinary hearing were alleged to have been conducted in an imbalanced way, favoring the complainants, limiting the accused’s ability to present witnesses, and subjecting him and his witness to more rigorous questioning. The hearing concluded with John being found responsible and suspended for two years, which he appealed internally without success. The United States District Court for the District of New Jersey reviewed John’s subsequent lawsuit against the university, which asserted claims under Title IX for sex discrimination as well as state law claims for breach of contract and breach of the implied covenant of good faith and fair dealing. The District Court dismissed the complaint, holding that John’s allegations were insufficient to plausibly state a claim under federal or state law. On appeal, the United States Court of Appeals for the Third Circuit reversed the District Court’s dismissal. The Third Circuit held that, taking the allegations as true, John had plausibly alleged that the university’s disciplinary process was influenced by both external and internal pressure to favor female complainants over male respondents, and that procedural irregularities and evidence of biased treatment supported an inference of sex discrimination under Title IX. The court also found that John plausibly alleged breaches of contract and the implied covenant of good faith and fair dealing based on the university’s failure to follow its own procedures and to provide a fundamentally fair process. The case was remanded for further proceedings. View "Doe v. Princeton University Trustees" on Justia Law

In re Avandia Marketing

2026-07-21T09:00:20-08:00

Several third-party payors who covered prescriptions for Avandia, a diabetes medication manufactured by GlaxoSmithKline LLC, brought a putative class action alleging that the company misrepresented Avandia’s cardiovascular risks and benefits. They claimed these misrepresentations led health care providers to prescribe Avandia more frequently than less expensive alternatives, causing the payors to reimburse for prescriptions that otherwise would not have been issued. The plaintiffs sought class certification on behalf of entities that paid for Avandia prescriptions during a specified period. The United States District Court for the Eastern District of Pennsylvania previously reviewed this case. It denied GlaxoSmithKline’s motion to dismiss the plaintiffs’ Racketeer Influenced and Corrupt Organizations Act (RICO) claim, and the Third Circuit affirmed that denial. Later, the District Court granted summary judgment to GlaxoSmithKline on certain claims, but the Third Circuit reversed in part and remanded for further proceedings. Most recently, the District Court granted class certification, finding the class ascertainable and concluding that common issues would predominate regarding causation. It relied on evidence of a common scheme to deceive and statistical analyses showing marketing campaigns increased prescriptions. The United States Court of Appeals for the Third Circuit reviewed the District Court’s class certification. The Third Circuit held that while the class is ascertainable, the record does not yet demonstrate that common questions predominate on causation. The court clarified that plaintiffs in pharmaceutical fraud RICO class actions may use statistical evidence to prove causation, but such evidence must establish causation, not merely correlation. Because the plaintiffs’ statistical evidence failed to satisfy this standard, the Third Circuit vacated the District Court’s class certification and remanded for further fact-finding on predominance under the clarified standard. View "In re Avandia Marketing" on Justia Law

Hileman v. West Penn Allegheny Health System Inc

2026-07-20T09:00:20-08:00

Cheryl Hileman worked as a CAT scan technologist at Forbes Hospital, operated by West Penn Allegheny Health System. After about a year of employment, she was reprimanded for frequent absences and informed of the process to request a disability accommodation or medical leave. She did not make such a request. Several months later, a coworker reported concerns that Hileman was sleeping during her shift. When confronted, Hileman denied sleeping but mentioned, for the first time, that she had diabetes and was experiencing fatigue and dry eyes due to a medication change. She did not request an accommodation or leave. Shortly thereafter, Hileman was terminated for misconduct related to sleeping on the job. Hileman filed suit in the U.S. District Court for the Western District of Pennsylvania, asserting claims under the Americans with Disabilities Act, the Pennsylvania Human Relations Act, and the Family and Medical Leave Act, including disability discrimination, failure to accommodate, retaliation, wrongful termination, and interference with medical leave. The District Court granted summary judgment in favor of West Penn, finding that Hileman was discharged for misconduct and had not requested an accommodation or leave prior to the investigation. On appeal, the United States Court of Appeals for the Third Circuit reviewed the case de novo. The court rejected Hileman’s attempt to supplement the record on appeal and sanctioned her attorney for submitting a motion containing misquotations. On the merits, the court held that an employee must notify the employer of a disability and request an accommodation or leave before the employer is obligated to act. Because Hileman did not request an accommodation or leave, and there was no clear indication that she needed one, her claims failed. The Third Circuit affirmed the District Court’s decision. View "Hileman v. West Penn Allegheny Health System Inc" on Justia Law

Byers v. Finishing Systems Inc.

2026-07-20T09:00:20-08:00

At a U.S. Army depot in Pennsylvania, workers used pumps to transfer flammable paint thinner in a paint-mixing room. The depot hired a contractor, Finishing Systems, to upgrade these pumps and provide brief operational training. The pump manufacturer, Carlisle Fluid Technologies, installed the pumps and, per contract, agreed to assist and train personnel in their use, care, and maintenance. Carlisle’s employee provided limited training focused on operation, not safety procedures. Two months after installation, a worker, wearing ordinary clothing rather than required anti-static gear, released vapors while swapping drums. A static discharge sparked a fire, killing two employees and severely injuring another. The survivors and estates of the deceased sued several parties, including Carlisle, alleging negligence for failure to provide adequate safety training. The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of Carlisle, concluding that it owed no duty of care to train workers on safety beyond its limited contract to provide operational instruction. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s summary judgment de novo. The Third Circuit held that, under Pennsylvania law and Section 324A of the Restatement (Second) of Torts, Carlisle’s duty was no broader than its contractual undertaking to sell, install, and provide basic operational training for the pumps. Carlisle did not increase the risk of harm, assume the depot’s safety training duties, or induce reliance for comprehensive safety training. The court found no legal basis to impose a broader duty. Accordingly, the Third Circuit affirmed the District Court’s summary judgment for Carlisle. View "Byers v. Finishing Systems Inc." on Justia Law

Association of New Jersey Rifle and Pistol Clubs I v. Attorney General

2026-07-17T10:00:13-08:00

New Jersey enacted laws that ban the possession of so-called “assault firearms”—including a list of over thirty models and types of semi-automatic rifles, such as the AR-15, and any firearm “substantially identical” to those listed—as well as laws restricting possession of “large capacity ammunition magazines” (LCMs), defined as magazines holding more than ten rounds. The statutes contain narrow exemptions, mostly for military, police, and certain target-shooting purposes, but in practice, they amount to a near-total prohibition on civilian possession of these weapons and magazines. Gun owners and advocacy groups challenged both sets of laws under the Second Amendment, and one group also raised a Takings Clause claim after New Jersey amended the LCM law in 2018 to further reduce the permitted capacity. The United States District Court for the District of New Jersey consolidated three related lawsuits and ruled on cross-motions for summary judgment. The District Court found New Jersey’s ban on the Colt AR-15 unconstitutional under the Second Amendment but upheld the LCM restrictions and rejected the Takings Clause challenge. The plaintiffs and the State appealed. The United States Court of Appeals for the Third Circuit, sitting en banc, applied the Supreme Court’s Second Amendment framework from New York State Rifle & Pistol Association v. Bruen and related cases. The Third Circuit held that the Second Amendment protects possession of semi-automatic rifles and large-capacity magazines, as both are “in common use for lawful purposes.” The court concluded New Jersey’s ban on semi-automatic rifles and its LCM restrictions are inconsistent with the Nation’s tradition of firearm regulation and thus violate the Second Amendment. The court modified the District Court’s order to invalidate the ban as to all semi-automatic rifles, reversed the ruling upholding the LCM provisions, and remanded for further proceedings, including as to other weapons regulated by the statutes. View "Association of New Jersey Rifle and Pistol Clubs I v. Attorney General" on Justia Law

City of Chester v. PHCC LLC

2026-07-17T09:00:12-08:00

The city at the center of this case, after decades of financial distress and unsuccessful efforts to revitalize its economy through projects like a waste facility and a casino, declared bankruptcy in 2022. Prior to the bankruptcy filing, the city had pledged certain revenue streams—including payments from a casino, a waste facility, and agreements with the county—to secure debt issued through complex arrangements. These pledges were established through city ordinances and related contracts with creditors, including a trust indenture and a contribution agreement. The revenue streams and contractual rights to payment became the focal point of disputes in the bankruptcy proceedings. Bankruptcy Judge Ashely M. Chan of the United States Bankruptcy Court for the Eastern District of Pennsylvania heard adversary claims from the city against its creditors. The creditors asserted that their liens on the pledged revenues survived the bankruptcy, arguing that their interests were statutory liens or arose from special revenues or proceeds exempt from discharge. The Bankruptcy Court held that the creditors had properly perfected their interests but determined that their liens were consensual, not statutory, and thus cut off by 11 U.S.C. § 552(a). The court also found that the pledged revenues were not "special revenues" under bankruptcy law and ordered that certain excess funds be transferred to the city. The creditors appealed these determinations. On appeal, the United States Court of Appeals for the Third Circuit affirmed the Bankruptcy Court's rulings on three key issues: the liens were not statutory and thus did not survive the bankruptcy; the pledged revenues were not special revenues; and the Trust Indenture required excess funds to be transferred to the city. However, the appellate court remanded for further proceedings on whether certain contract language conveyed a right to payment from which post-petition proceeds could be derived, and whether the creditors’ interests extended to pre-petition accrued amounts not yet paid to the city. View "City of Chester v. PHCC LLC" on Justia Law

Wang v. University of Pittsburgh

2026-07-07T10:00:11-08:00

An academic cardiologist published a peer-reviewed article questioning race-based affirmative action in medical education, expressing concerns that such practices might discriminate against some minority groups, violate the law, and harm the intended beneficiaries. After initial silence, the article drew criticism from his colleagues and superiors at both a public university and its affiliated private hospital system. He was demoted from his leadership role, barred from teaching, subjected to public denunciations, and his article was retracted by the journal following pressure from his employers. The fallout led to isolation at work and significant reputational harm. The U.S. District Court for the Western District of Pennsylvania reviewed his lawsuit, which alleged defamation and retaliation under several civil-rights statutes. The court dismissed his defamation claims, finding the statements were either true or not made with actual malice, and rejected most retaliation claims on the pleadings or at summary judgment, reasoning he had not engaged in protected activity or failed to plausibly allege state action. Additionally, the court dismissed his First Amendment claims for lack of state action and vicarious liability, and found insufficient allegations regarding federal funds supporting employment for Title VI claims. The United States Court of Appeals for the Third Circuit held that the plaintiff plausibly alleged defamation against five defendants, including two individuals, the university, the hospital system, and the professional association, finding sufficient allegations of actual malice and harm to reputation. The court also determined that there were genuine disputes of material fact regarding retaliation under Title VII, the PHRA, § 1981, and Title VI (for the hospital system), and revived those claims. However, it affirmed dismissal of the First Amendment retaliation claim due to lack of state action. The court affirmed in part, vacated in part, and remanded for further proceedings. View "Wang v. University of Pittsburgh" on Justia Law

Lynn v. Bank of New York Mellon

2026-07-06T09:00:11-08:00

The appellant, a Black man, worked at a large financial institution from 2019 to 2021. He initially received positive reviews and bonuses from his supervisor, who later expressed political opinions critical of the Black Lives Matter movement but encouraged open discussion. In early 2021, the supervisor suggested the appellant seek another director-level position, which the appellant pursued and obtained with the supervisor’s assistance. After transitioning to the new role, the appellant inserted a footnote in a presentation alleging the division was unsafe for Black employees, referencing his supervisor’s earlier comments. This was not reported to human resources directly but was discovered and investigated, with the claims found unsubstantiated. The appellant then experienced performance issues in his new team, was placed on a performance improvement plan, filed an EEOC charge, and ultimately had his position eliminated during a reorganization. His responsibilities were distributed among existing employees, and he was not replaced. The case was first reviewed by the United States District Court for the District of New Jersey. The appellant sued the institution and its parent company, alleging race discrimination, retaliation, and a hostile work environment under federal and New Jersey law. The District Court granted summary judgment to the defendants on all claims, finding insufficient evidence for the discrimination and hostile work environment claims and determining that the employer’s reasons for termination were not pretextual. The United States Court of Appeals for the Third Circuit reviewed the appeal de novo. It held that the appellant failed to make out a prima facie case of race discrimination regarding both his termination and alleged demotion, as he voluntarily left his prior position and was not replaced. The Court further held that while temporal proximity established a prima facie case of retaliation, the appellant failed to present evidence of pretext or retaliatory animus. The Court thus affirmed the District Court’s order granting summary judgment for the defendants. View "Lynn v. Bank of New York Mellon" on Justia Law

USA v. Rosario

2026-07-01T09:00:13-08:00

A man with previous felony drug convictions sold drugs to an individual named Correa at a Pennsylvania gas station. Later that day, Correa was found dead in his car, with toxicology revealing fentanyl-laced heroin and cocaine in his system. An investigation uncovered that Correa had arranged the transaction with the man through text messages and Facebook Messenger, and security footage confirmed their meeting. The man admitted to supplying cocaine but denied selling heroin. A search warrant was obtained for the man’s Facebook records, leading to the discovery of extensive drug-related communications, including evidence of a gun-for-drugs exchange. A federal grand jury indicted the man on multiple counts: conspiracy to possess with intent to distribute narcotics resulting in death or serious bodily injury, possession with intent to distribute drugs, possession of a firearm in furtherance of drug trafficking, and conspiracy to possess a firearm in furtherance of drug trafficking. He was convicted on all counts by a jury. Before trial, he moved to suppress the Facebook evidence, arguing the search warrant was overbroad and lacked particularity, and requested a Franks hearing, alleging falsehoods in the warrant affidavit. The United States District Court for the Middle District of Pennsylvania denied these motions, admitted certain witness testimony, and imposed a mandatory life sentence under 21 U.S.C. § 841(b)(1)(C) based on his prior convictions and the resulting death. The United States Court of Appeals for the Third Circuit affirmed the convictions, holding that the good faith exception shielded the Facebook evidence from suppression, that the evidence was sufficient to support all convictions (including firearm possession via gun-for-drugs trades), and that the evidentiary rulings were not erroneous. However, the Court vacated the life sentence, holding that the District Court erred by not applying the traditional categorical approach to determine whether the prior state drug convictions qualified as “felony drug offenses” under federal law, and remanded for resentencing. View "USA v. Rosario" on Justia Law

USA v. Aumiller

2026-07-01T09:00:12-08:00

Between 2011 and 2017, the Internal Revenue Service sought to collect unpaid taxes from an individual and his business. The individual was indicted on two counts of tax evasion. The indictments alleged that, among other acts, he attempted to evade the collection of taxes by using a bank account that was not disclosed to the IRS, and specifically by submitting financial disclosure forms that omitted these accounts when disclosure was required. The case was first heard in the United States District Court for the Middle District of Pennsylvania. The defendant moved to dismiss the indictments, arguing that the government had not alleged or proven an affirmative act of evasion within the applicable six-year statute of limitations. The District Court denied these motions. At trial, the government presented evidence that the defendant had knowingly failed to disclose certain bank accounts on forms submitted to the IRS within the limitations period. After the government’s case, the defendant’s motion for judgment of acquittal was denied. The jury found him guilty on both counts. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s denials. The Third Circuit held that intentionally filing forms with the IRS that omitted required disclosure of bank accounts constitutes an affirmative act of tax evasion under 26 U.S.C. § 7201. The court found that the indictments, together with the bill of particulars, sufficiently identified this conduct within the statute of limitations. It also held that there was sufficient evidence for a rational jury to find guilt beyond a reasonable doubt. The Third Circuit affirmed the judgment of the District Court. View "USA v. Aumiller" on Justia Law

USA v. Craddock

2026-07-01T09:00:12-08:00

After being arrested following a slow-speed pursuit in November 2020, the defendant was found with a disassembled Glock pistol and ammunition. The firearm contained two serial numbers: one was fully legible on the slide, while the other, located on the pistol frame, was partially visible but mainly scratched off, rendering several characters illegible. As a convicted felon, the defendant was charged with unlawful possession of a firearm and pleaded guilty. Prior to sentencing, the U.S. Probation Office recommended a four-level sentence enhancement under § 2K2.1(b)(4)(B)(i) of the U.S. Sentencing Guidelines, which applies if any firearm involved had a serial number modified to be illegible or unrecognizable to the unaided eye. At the sentencing hearing, the United States District Court for the Middle District of Pennsylvania found that certain characters of the serial number on the pistol frame were not legible, thus applying the four-level enhancement. The District Court ruled that the presence of a separate, legible serial number on the firearm’s slide was irrelevant to the enhancement’s application. The defendant appealed this decision. The United States Court of Appeals for the Third Circuit reviewed the District Court’s interpretation of the Guidelines de novo. The appellate court concluded that the plain language of § 2K2.1(b)(4)(B)(i) requires only that a firearm have at least one serial number rendered illegible or unrecognizable, regardless of whether another serial number on the same firearm remains legible. The court rejected the defendant’s argument that the enhancement should not apply if the firearm retains any complete, legible serial number. The Third Circuit affirmed the judgment of the District Court, holding that the enhancement applies so long as any serial number on the firearm has been modified to be illegible. View "USA v. Craddock" on Justia Law

USA v. Riddy

2026-07-01T09:00:12-08:00

DEA investigators received information indicating that an individual was distributing cocaine base with a co-defendant in Monroe County, Pennsylvania. The individual often requested payments from customers via Cash App and either conducted drug transactions personally or sent the co-defendant to do so. Cash App records showed approximately $180,000 in payments. Agents arranged controlled purchases, during which the co-defendant drove the individual's vehicle for several transactions. After executing a search warrant at the individual's residence, agents seized cocaine, paraphernalia, a drug ledger, financial records, and cash. The individual was later charged in a federal superseding indictment with several drug-related counts and pled guilty to conspiracy to distribute and possess with intent to distribute cocaine. The United States District Court for the Middle District of Pennsylvania reviewed the presentence report, which recommended a two-level leadership enhancement under U.S.S.G. § 3B1.1(c) for being a “manager” or “supervisor” of criminal activity. This enhancement resulted in a guideline range of 120 to 135 months, subject to a statutory minimum sentence of ten years. Without the enhancement, the individual would have been eligible for a sentence below the statutory minimum under the safety valve provision. The individual objected, but the District Court relied on Sentencing Guidelines commentary and applied the enhancement, sentencing him to 120 months’ imprisonment. The appeal challenged only the District Court’s application of the leadership enhancement. The United States Court of Appeals for the Third Circuit reviewed the District Court’s interpretation of the Sentencing Guidelines de novo and factual findings for clear error. The Third Circuit held that the District Court erred by deferring to the Guidelines’ commentary without first determining whether the Guideline text was genuinely ambiguous as required by circuit precedent. However, since the terms “manager” and “supervisor” were not genuinely ambiguous, and the factual findings supported the enhancement, the error was harmless. The Third Circuit affirmed the District Court’s judgment of sentence. View "USA v. Riddy" on Justia Law

USA v. Williams

2026-06-30T09:00:12-08:00

The defendant was arrested after sexually abusing a 13-year-old girl and making and possessing child pornography, having coerced multiple minors into sending him explicit images and meeting him for sex. Law enforcement officers posed as one of the victims to apprehend him, and a grand jury indicted him on five federal charges, including traveling interstate to have sex with a minor, sexual exploitation of a child, coercion and enticement of a minor, and possession of child pornography. Following his arrest, the defendant repeatedly delayed proceedings, changed his mind about legal representation, and ultimately chose to represent himself at trial after several Faretta hearings, during which the District Court misinformed him about the maximum penalty on one count. The U.S. District Court for the District of New Jersey, after thorough Peppers colloquies, allowed the defendant to proceed pro se with standby counsel, despite the sentencing misinformation. During trial, the defendant behaved disruptively and withdrew his pro se status for closing arguments. The jury convicted him on all counts. Before sentencing, the government revealed the sentencing error, and the defendant moved for a new trial, claiming his waivers of counsel were neither knowing nor voluntary, and challenging the admission of certain evidence. The District Court denied the motion, finding the waivers valid based on the overall record, and sentenced him to life imprisonment. The United States Court of Appeals for the Third Circuit reviewed the appeal and affirmed the conviction and sentence. The court held that the defendant’s waivers of his right to counsel were both knowing and voluntary, even in light of the District Court’s error, because he was aware he faced a functional life sentence. It clarified that in cases where a defendant seeks to represent himself for improper purposes, courts may review the entire record to verify waiver validity. The court also rejected the evidentiary challenges to chat messages and evidence of other crimes. View "USA v. Williams" on Justia Law

Bracey v. Superintendent Rockview SCI

2026-06-26T09:00:11-08:00

In 1995, a man was convicted by a jury in the Dauphin County Court of Common Pleas for first-degree murder following the shooting death of another individual related to a drug deal. Two key prosecution witnesses, both facing pending charges themselves, testified against him in exchange for plea agreements. The prosecution did not disclose all pending charges against these witnesses, though defense counsel was able to impeach their credibility based on other known charges. Despite this, the jury convicted the defendant, who was sentenced to life imprisonment. He unsuccessfully challenged his conviction on direct appeal and through multiple post-conviction proceedings in state court. After eventually discovering the full extent of the witnesses' pending charges, the petitioner filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Middle District of Pennsylvania, asserting a Brady violation. The District Court denied the petition as untimely under the statute of limitations, and subsequent requests for a certificate of appealability were also denied. Following a significant change in Third Circuit law announced in Dennis v. Secretary, Pennsylvania Department of Corrections, the petitioner sought to reopen his federal habeas case under Federal Rule of Civil Procedure 60(b)(6). After a remand for further analysis, the District Court again denied the Rule 60(b)(6) motion, finding that the factors for extraordinary relief were not met. The United States Court of Appeals for the Third Circuit reviewed the denial, applying an abuse-of-discretion standard and weighing the Cox factors. The Court held that, although the materiality and diligence factors favored the petitioner, the remaining factors—likelihood of success, finality and comity, lack of actual innocence, and non-capital sentence—strongly disfavored relief. The Third Circuit affirmed the District Court’s denial of the Rule 60(b)(6) motion. View "Bracey v. Superintendent Rockview SCI" on Justia Law

Steidle v. United States Liability Insurance Co

2026-06-24T09:00:12-08:00

The appellant was employed by an insurance company and struggled with mental health issues, including major depressive disorder and later posttraumatic stress disorder and anxiety. Over several years, he received annual salary increases and bonuses. In 2020, after transferring to a new team and informing his supervisor about his mental health struggles, he took FMLA leave for treatment. While he was on leave, his supervisor approved a significantly reduced bonus and salary increase compared to prior years. Upon returning to work, he received positive performance reviews and requested accommodations related to his disability. He was granted some accommodations and continued working remotely. In 2021, after requesting further accommodations, he received another reduced bonus and salary increase. Later, after extended medical leave and unsuccessful attempts to return with additional accommodations, his employment was terminated. The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the employer on all claims. It found that the appellant had not established a prima facie case of discrimination or retaliation under the ADA and FMLA. Specifically, the District Court held that the reduced bonuses and salary increases did not constitute adverse employment actions and that there was no causal connection between the protected activities (requests for leave and accommodations) and the adverse actions. The United States Court of Appeals for the Third Circuit reviewed the summary judgment order. The court applied the Burlington Northern standard, holding that the less restrictive “materially adverse” standard for retaliation claims under Title VII also applies to ADA and FMLA retaliation claims. The court found that unusually suggestive temporal proximity between the appellant’s FMLA leave and his 2020 bonus established a prima facie case for retaliation, but that such proximity was lacking for the 2021 bonus. The Third Circuit vacated the summary judgment as to the 2020 bonus retaliation claims and remanded for the District Court to consider pretext, while affirming summary judgment as to the 2021 bonus retaliation claims. View "Steidle v. United States Liability Insurance Co" on Justia Law

Ahn v. Cigna Health and Life Insurance Co

2026-06-24T09:00:11-08:00

Dr. Jeffrey M. Ahn, an otolaryngologist practicing in New Jersey and New York, treated patients insured by Cigna Health and Life Insurance Company, which provides ERISA-governed health plans. After submitting claims for approximately fifty treatments, Dr. Ahn received denial notices from Cigna, many of which stated his claims were rejected because he was not a licensed provider. Upon appeal, Cigna sometimes reversed or modified the denial reasons. Dr. Ahn contended that these statements were defamatory and filed suit in New Jersey Superior Court, alleging defamation, defamation per se, and tortious interference. Cigna removed the case to the United States District Court for the District of New Jersey and sought dismissal or summary judgment, arguing ERISA preemption and a statute of limitations defense. Initially, the District Court deferred ruling on preemption, as it was unclear which claims related to ERISA plans. After discovery, Dr. Ahn withdrew two claims, leaving only defamation per se. Cigna again moved for summary judgment, submitting evidence that all relevant plans were governed by ERISA. Dr. Ahn presented no contrary evidence. The District Court found the plans were ERISA plans and held that Dr. Ahn’s defamation per se claim was preempted because it concerned statements made in explanation of benefits forms, which are part of ERISA plan administration. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. The Third Circuit held that ERISA preempts a healthcare provider’s state-law defamation claim when the alleged defamatory statements appeared in explanation of benefits forms sent to beneficiaries of ERISA plans. The court reasoned that such communications are a central aspect of plan administration and that allowing state-law claims would undermine uniformity in ERISA administration. The Third Circuit affirmed the District Court’s grant of summary judgment in favor of Cigna. View "Ahn v. Cigna Health and Life Insurance Co" on Justia Law

USA v. Dangleben

2026-06-24T06:00:26-08:00

Richardson Dangleben, Jr. was initially charged in Virgin Islands Superior Court with first-degree murder and using a firearm during a violent crime. While released on pretrial conditions, Dangleben was involved in a shootout with police, resulting in the death of Detective Phipps. Following these events, a federal grand jury indicted Dangleben on several charges, including using a firearm during a crime of violence resulting in death, making him eligible for the death penalty. The predicate crimes for these charges were all Virgin Islands territorial offenses. After indictment, the Federal Public Defender inquired about the government's intent to seek the death penalty. The U.S. Attorney’s Office indicated it would not recommend the death penalty, though the final decision rested with the Attorney General. By agreement of the parties, the District Court of the Virgin Islands set a deadline for the government to file any notice of intent to seek the death penalty. The government missed the deadline, later changing its position and seeking to pursue the death penalty after a change in federal policy. The District Court struck the government’s death penalty notice as untimely and, in a separate order, dismissed counts that relied on territorial offenses as predicates for federal firearm charges, concluding only federal crimes could serve as predicate offenses under 18 U.S.C. § 924(c). The United States Court of Appeals for the Third Circuit reviewed both rulings. It held that a district court has authority to set and enforce a deadline for the government to file its notice of intent to seek the death penalty under 18 U.S.C. § 3593(a), and affirmed the District Court’s striking of the government’s late notice. However, the Third Circuit reversed the District Court’s ruling on predicate crimes, holding that Virgin Islands territorial offenses can serve as predicate “crimes of violence” under 18 U.S.C. § 924(c)(1)(A), and remanded with instructions to reinstate the dismissed counts. View "USA v. Dangleben" on Justia Law

Johnson v. Quest Diagnostics Inc

2026-06-22T09:00:11-08:00

Employees participating in a 401(k) plan offered by their employer, a clinical laboratory company, brought a class action alleging that the plan’s fiduciaries breached their duties under ERISA by retaining two particular investment options: the Fidelity Freedom Funds and the Invesco Global Real Estate Fund. The plaintiffs argued that these funds underperformed compared to alternatives, were riskier, and that the plan’s managers failed to remove them despite subpar performance. They also claimed that internal policy statements required the funds’ removal and that the plan’s managers failed in their duty to monitor investments and breached trust obligations. The United States District Court for the District of New Jersey initially denied a motion to dismiss the case, allowing discovery to proceed. After discovery, the District Court granted summary judgment in favor of the defendants. The court found that the plan’s fiduciaries had fulfilled their obligations by hiring investment advisors, regularly reviewing investment performance, seeking relevant training, and following up on concerns regarding the challenged funds. The court concluded there was no breach of fiduciary duty or related failures. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s grant of summary judgment de novo, considering all facts and inferences in favor of the plaintiffs. The Third Circuit held that ERISA’s fiduciary standard is process-oriented, not outcome-based. The Court found that the fiduciaries had used a prudent process—hiring advisors, critically assessing their recommendations, meeting with fund managers, and maintaining regular oversight—even if the investments did not always outperform alternatives. The Court further held that internal policy statements were nonbinding and that the fiduciaries did not abuse their discretion. Consequently, the Third Circuit affirmed the District Court’s summary judgment in favor of the defendants on all claims. View "Johnson v. Quest Diagnostics Inc" on Justia Law

Asay v. New Jersey Transit Rail Operations Inc

2026-06-18T09:00:13-08:00

A locomotive engineer had longstanding concerns about her employer’s train scheduling practices, believing they led to unsafe conditions by pressuring employees to cut corners. Over a two-year period, she reported these concerns to her union, federal and state agencies, and the Governor’s office. Following a fatal train crash, she raised the issue again at a safety meeting attended by Liberty Mutual Insurance and New Jersey Transit employees. The specifics of this meeting, including which company personnel attended or knew about her participation, remained unclear. After the safety meeting, the engineer committed two significant infractions: first, she operated a train at a speed well above the limit, resulting in suspension after a disciplinary hearing. Her suspension was upheld by internal review boards. Later, she ran a train through a stop signal, leading to her termination after another disciplinary process. The identities of those responsible for the disciplinary decisions were uncertain, and testimony indicated that the signatory on her termination notice was absent at the time. A review board subsequently upheld the termination. After exhausting administrative remedies, the engineer filed suit under the Federal Railroad Safety Act, alleging retaliation for her whistleblowing. The United States District Court for the District of New Jersey granted summary judgment for the employer, finding insufficient evidence of retaliation. The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the employee failed to provide evidence that any person involved in the decision to discipline or terminate her knew of her protected activity. The court clarified that, under the Federal Railroad Safety Act, a plaintiff must show knowledge of protected activity by an agent who influenced the adverse action. Because such evidence was lacking, the court affirmed the District Court’s grant of summary judgment for the employer. View "Asay v. New Jersey Transit Rail Operations Inc" on Justia Law

City of Philadelphia v. DOI

2026-06-18T09:00:12-08:00

The dispute centers on the President’s House Exhibit in Independence National Historical Park, which commemorates the history of enslaved Africans who lived there during George Washington’s presidency. The City of Philadelphia and the National Park Service (NPS) had established the exhibit through a series of cooperative agreements, culminating in a 2009 amendment that transferred ownership and maintenance responsibility to NPS. In 2026, following an executive order, NPS unilaterally removed interpretive panels and video exhibits from the site without consulting the City, prompting the City to file a lawsuit seeking restoration of the materials. The United States District Court for the Eastern District of Pennsylvania reviewed the City’s claims and granted a preliminary injunction, ordering NPS to restore the President’s House Site to its previous physical status and prohibiting further changes without mutual agreement. The District Court concluded that it had jurisdiction over four claims brought under the Administrative Procedure Act (APA), found that the City had standing based on statutory and contractual rights to mutual agreement and consultation, and determined that NPS’s actions constituted final agency action subject to judicial review. The United States Court of Appeals for the Third Circuit addressed the appeal by first confirming the City’s standing based on alleged contractual injury. However, the court determined that the APA did not permit review of Counts II through V because the NPS’s removal of exhibits was not “agency action” as defined by the APA, nor did it constitute “final agency action.” The court also clarified that statutory provisions requiring mutual agreement applied only to Independence Hall National Historic Site, not the entire park or the President’s House. Accordingly, the Third Circuit vacated the District Court’s preliminary injunction and remanded with instructions to dismiss Counts II through V for lack of jurisdiction. View "City of Philadelphia v. DOI" on Justia Law

USA v. Harry

2026-06-17T09:00:13-08:00

Two individuals were prosecuted for their roles in a violent drug-trafficking organization in the U.S. Virgin Islands. One defendant was identified as the leader, convicted by a jury of 22 counts including drug, firearm, and racketeering charges; the other, an armorer, was convicted of seven counts relating to racketeering and firearms. Their trial occurred in March 2022, shortly after the District Court resumed in-person proceedings following COVID-19 restrictions. Initially, all public spectators were required to observe the proceedings from an overflow room via audiovisual feed, rather than in the courtroom itself. After the first day, some spectators, including family members, were permitted into the courtroom, but for several days, court security personnel prevented the defendants’ mothers from entering, even when seats were available. Following their convictions, the defendants moved for a new trial in the District Court of the Virgin Islands, arguing that their Sixth Amendment right to a public trial was violated by these restrictions. After an evidentiary hearing, the court found that some seating was always available on a first-come basis and that any interruptions in the audiovisual feed were brief. The District Court denied the motions, concluding that the public was not excluded from the trial. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and legal conclusions de novo, but applied plain error review due to the defendants’ failure to make timely objections. The Third Circuit held that there were errors: the initial exclusion of all public spectators and the subsequent exclusion of the defendants’ mothers were unjustified. However, the court also held that these errors did not seriously affect the fairness, integrity, or public reputation of judicial proceedings and therefore did not warrant reversal. The judgments of conviction were affirmed. View "USA v. Harry" on Justia Law

Justman v. Accenture LLP

2026-06-17T09:00:12-08:00

The appellant, Mark Justman, sought to recover accidental death life insurance benefits following the death of his wife, Karen Justman, who died from septic shock caused by a bacterial infection after eating raw oysters. At the time of her death, she was employed by Accenture LLP and was covered by both basic and optional accidental death and dismemberment (AD&D) insurance through a group plan. Prudential Insurance Company of America served as the Claims Administrator in 2021, while Accenture was designated as the Plan Administrator. After Prudential denied Justman’s claim on the grounds that the death was due to illness rather than an accident, Justman exhausted Prudential’s administrative appeals process without success. Justman then filed suit in the United States District Court for the Eastern District of Pennsylvania against both Prudential and Accenture, asserting wrongful denial of benefits under ERISA § 502(a)(1)(B) and breach of fiduciary duty for allegedly failing to provide required summary plan descriptions (SPDs). Prudential settled, leaving only Accenture as a defendant. The District Court dismissed Justman’s claims, finding insufficient factual allegations that Accenture controlled the benefits determination or failed to provide SPDs within statutory deadlines. The court allowed Justman to amend his complaint multiple times but found that further amendment would be futile and dismissed the case with prejudice. On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s rulings. The Third Circuit held that a proper defendant in an ERISA § 502(a)(1)(B) claim is the entity with authority over benefits determinations, which in this case was Prudential, not Accenture. The court also concluded that Justman’s claims regarding failure to provide SPDs and breach of fiduciary duty were not plausibly pleaded. The Third Circuit found no abuse of discretion in the denial of leave to amend or reconsideration and affirmed the dismissal with prejudice. View "Justman v. Accenture LLP" on Justia Law

Williams v. Superintendent Rockview SCI

2026-06-15T09:00:11-08:00

After being convicted in 2007 of kidnapping, corruption of a minor, and various drug offenses, a Pennsylvania prisoner was sentenced to fifteen to thirty years in state prison. He argued that he deserved additional credit for time served, which led him through a series of challenges in both Pennsylvania and federal courts. The Pennsylvania Superior Court remanded his case for a hearing on the time-credit issue, resulting in a modified sentence from the Court of Common Pleas granting him three months and twelve days of additional credit. His appeal for further credit was denied, and subsequent collateral challenges, including a federal habeas petition contesting his convictions and sentence enhancement, were unsuccessful. The United States District Court for the Western District of Pennsylvania dismissed his 2013 federal habeas petition as an unauthorized second or successive petition, finding that the revised sentence did not constitute a “new judgment” under Magwood v. Patterson. He did not appeal that decision, but later filed additional habeas petitions and applications for certificates of appealability, which were all denied. In 2022, nearly eight years after the dismissal, he moved under Federal Rule of Civil Procedure 60(b) to reopen the prior judgment, arguing that later precedent (Lesko v. Secretary, Pa. Dep’t of Corr.) justified relief. The District Court denied the motion, finding no extraordinary circumstances. The United States Court of Appeals for the Third Circuit reviewed whether the District Court abused its discretion in denying relief under Rule 60(b)(6). The Court of Appeals held that a change in procedural law alone does not constitute an extraordinary circumstance justifying reopening a final judgment absent additional equitable factors. Because the petitioner failed to present any facts showing extreme or unexpected hardship or other supporting circumstances, the Third Circuit affirmed the District Court’s denial of the Rule 60(b) motion. View "Williams v. Superintendent Rockview SCI" on Justia Law

Gelis v. BMW of North America LLC

2026-06-11T09:00:11-08:00

Several plaintiffs brought a class action against BMW of North America, alleging the company sold vehicles with defective timing chains. After partial dismissal of initial claims and additional discovery totaling approximately 12,000 pages, the parties reached a settlement resolving the merits of the dispute. However, they could not agree on attorneys’ fees, so a settlement agreement stipulated that class counsel would apply to the court for “reasonable attorneys’ fees” to be paid separately from class relief, with BMW not opposing fees up to $1.5 million and class counsel requesting up to $3.7 million. The U.S. District Court for the District of New Jersey used the lodestar method to calculate fees, finding the hours and rates reasonable and applying a lodestar multiplier that resulted in a $3.7 million award. BMW appealed, and the U.S. Court of Appeals for the Third Circuit previously vacated the fee award, finding the record insufficient to support it and remanding for further proceedings. On remand, class counsel supplemented their billing records and again sought $3.7 million. The district court approved the hours and rates, applied a reduced multiplier, and awarded the same amount. BMW appealed again, challenging the use and calculation of the multiplier and the reasonableness of the hours. The U.S. Court of Appeals for the Third Circuit held that constraints imposed by the Supreme Court on lodestar multipliers in statutory fee-shifting cases, particularly Perdue v. Kenny A. ex rel. Winn, also apply to contractual fee-shifting arrangements governed by federal law. The court found the district court erred by applying a multiplier without considering Perdue’s “strong presumption” that the unenhanced lodestar is reasonable and by approving excessive hours without sufficient justification. The Third Circuit vacated the fee award and remanded for further proceedings. View "Gelis v. BMW of North America LLC" on Justia Law

Thomas v. City of Philadelphia

2026-06-09T09:00:12-08:00

Milton Thomas filed for Chapter 13 bankruptcy in 2004, listing the City of Philadelphia as a creditor for liens on several properties. Thomas used a lawful process to reduce (“cram down”) the value of the City’s claims and had a bankruptcy plan confirmed in 2005, after which a discharge order was issued in 2009. Despite receiving notice of the proceedings and participating in them by filing claims, the City later sought to collect on liens relating to two properties, the 1618 Property and the 1620 Property, which Thomas argued violated the discharge order. After the discharge, the City began collection actions in state court for these properties. Thomas sought relief in federal court, claiming the City’s actions violated the bankruptcy discharge. The U.S. District Court for the Eastern District of Pennsylvania initially found for Thomas, but the U.S. Court of Appeals for the Third Circuit vacated that decision, instructing that only the Bankruptcy Court could address contempt allegations. On remand, the Bankruptcy Court declined to hold the City in contempt, relying on its earlier 2013 sua sponte ruling that the City had not received constitutionally adequate notice. The District Court affirmed this decision. The United States Court of Appeals for the Third Circuit reviewed the case. The Third Circuit held that the City had actual notice of the bankruptcy and discharge orders and that the 2013 Bankruptcy Court ruling did not provide a reasonable basis for the City’s subsequent conduct. The court found that civil contempt sanctions were warranted as to the 1618 Property, but not the 1620 Property, because Thomas had not shown he met his payment obligations for the latter. The court affirmed in part, vacated in part, and remanded for further proceedings to determine damages for the 1618 Property. View "Thomas v. City of Philadelphia" on Justia Law

Secretary United States Department of Labor v. Comprehensive Healthcare Management Services LLC

2026-06-03T09:00:12-08:00

Comprehensive Healthcare Management Services LLC acquired numerous healthcare facilities in Pennsylvania beginning in 2014. The United States Department of Labor investigated these facilities for wage and hour violations under the Fair Labor Standards Act (FLSA). The Department’s Secretary filed suit in 2018 on behalf of nearly 6,000 employees, alleging that Comprehensive failed to maintain accurate records and did not properly compensate employees for all hours worked, including overtime and time worked during meal breaks. Evidence at trial revealed systemic errors in Comprehensive’s payroll and recordkeeping systems, leading to employees being paid for scheduled rather than actual hours, unpaid work during meal breaks, and improper calculation of overtime rates. The United States District Court for the Western District of Pennsylvania held a bench trial and found in favor of the Secretary. The District Court found the Secretary’s witnesses credible and Comprehensive’s witnesses lacking credibility. It concluded that Comprehensive had violated the FLSA by failing to keep accurate records, not compensating for all hours worked, miscalculating overtime, and misclassifying employees as exempt. The court awarded $35,804,438.20 in damages, which included compensation for “overtime gap time”—hours worked in a week beyond 40 for which regular pay was not provided. On appeal, the United States Court of Appeals for the Third Circuit reviewed the case. The court held that claims for “overtime gap time” are not cognizable under the FLSA, as the statute only requires payment of minimum wages and overtime, and does not cover unpaid non-overtime hours in overtime weeks. The court reversed the District Court’s award on that ground. The Third Circuit affirmed the District Court’s findings regarding Comprehensive’s FLSA violations and its application of the burden of proof, finding no clear error. However, it vacated and remanded the exemption analysis for further proceedings, instructing the District Court to apply current legal standards. View "Secretary United States Department of Labor v. Comprehensive Healthcare Management Services LLC" on Justia Law

USA v. Dangleben

2026-06-01T09:00:39-08:00

The case centers on a defendant who was initially charged in the Virgin Islands Superior Court with first-degree murder and a firearm offense, and released pretrial with a condition not to possess weapons. Several months later, the defendant became involved in a shootout with police, resulting in the death of a detective. Upon investigation, authorities found a firearm, ammunition, and drugs in his vehicle. A federal grand jury subsequently indicted the defendant on charges including using a firearm during a crime of violence resulting in death, which made him eligible for the federal death penalty. The predicate crimes underlying these charges were all violations of Virgin Islands territorial law. After indictment, the prosecution indicated it would not recommend the death penalty but acknowledged that only the Attorney General could make the final decision. At the defendant’s request, and with the government’s agreement, the United States District Court of the Virgin Islands set a deadline for the government to provide notice if it intended to seek the death penalty. The government missed this deadline but ultimately filed a notice to seek the death penalty over a year later, after a change in federal policy. The District Court struck the notice as untimely and dismissed several counts relying on territorial offenses as predicate crimes of violence under federal firearm law. The United States Court of Appeals for the Third Circuit reviewed the case. It held that a district court has the authority to set and enforce deadlines for the government to provide notice of intent to seek the death penalty under 18 U.S.C. § 3593(a), and found no abuse of discretion in enforcing the deadline set. The court also held that Virgin Islands territorial offenses qualify as predicate crimes of violence for purposes of 18 U.S.C. § 924(c)(1)(A). The court affirmed the order striking the death penalty notice, but reversed and remanded the dismissal of counts based on territorial predicates. View "USA v. Dangleben" on Justia Law

Laureano v. Attorney General

2026-05-29T09:00:38-08:00

A citizen of the Dominican Republic entered the United States as a lawful permanent resident in 1994. She suffered abuse from her partner, who later involved her in a drug-trafficking scheme without her consent. In 2007, she pled guilty to conspiracy to possess with intent to distribute one kilogram or more of heroin, served a prison sentence, and was ordered removed from the United States in 2008. She unlawfully reentered the country in 2009 and remained until her 2023 arrest. Following the reinstatement of her prior removal order, she applied for withholding of removal and relief under the Convention Against Torture (CAT), fearing harm from her former partner if returned to the Dominican Republic. An Immigration Judge denied her applications, finding her conviction was a presumptive “particularly serious crime” (PSC) under the Attorney General’s decision in Matter of Y-L-, and that she had not rebutted the presumption. The judge also rejected her CAT claim, concluding she failed to establish it was more likely than not she would face torture with government acquiescence upon return. The Board of Immigration Appeals (BIA) adopted the Immigration Judge’s decision, and dismissed her appeal. The United States Court of Appeals for the Third Circuit reviewed the case. The court held that it had jurisdiction over both the CAT and withholding claims, even though the petitioner did not challenge the underlying removal order and the government did not contest the timeliness of the petition. The court unanimously denied her petition for review of the CAT claim, holding that the BIA did not err in denying relief. However, the panel was evenly divided on the statutory withholding claim: one judge would have denied the petition, one would have granted and remanded, and one would have dismissed for lack of jurisdiction. As a result, the denial of statutory withholding was left intact by an equally divided court. View "Laureano v. Attorney General" on Justia Law

SLT Imports Inc v. SAR Transport Systems Pvt Ltd

2026-05-28T09:00:11-08:00

SLT Imports, a New Jersey company, agreed to finance the importation of goods for Krishna Food Corp. from Bikaji Foods International in India, using SAR Transport Systems as the maritime carrier. Under the arrangement, Krishna would pay SAR by drawing from SLT’s bank facility, and SAR was required to release cargo only upon presentation of an endorsed bill of lading (BOL). SLT later discovered that SAR had delivered goods to Krishna without receiving endorsed BOLs, instead accepting letters of indemnity. SLT alleged that SAR breached the contract and committed fraud in the execution by issuing BOLs with terms it did not intend to honor. The U.S. District Court for the District of New Jersey granted SAR’s motion for judgment on the pleadings, dismissing SLT’s breach-of-contract claim as waived and time-barred under the Carriage of Goods by Sea Act (COGSA), and rejecting SLT’s fraud-in-the-execution claim. The District Court found that SLT failed to allege facts establishing fraud in the execution, and that even if it had, the claim was barred by COGSA’s one-year statute of limitations. The Court also held that the deviation doctrine and equitable estoppel did not apply. SLT’s motion for reconsideration was denied. On appeal, the U.S. Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. It held that SLT did not adequately plead fraud in the execution, as the allegations amounted to breach of contract rather than fraud. The Third Circuit further concluded that SLT’s claim was time-barred by COGSA’s one-year limitation period and that neither the deviation doctrine nor equitable estoppel could circumvent this bar. The Court affirmed the judgment of the District Court, including the denial of leave to amend and the denial of reconsideration. View "SLT Imports Inc v. SAR Transport Systems Pvt Ltd" on Justia Law

USA v. Girard

2026-05-26T09:00:11-08:00

This case concerns two defendants, Paul Girard and Kareem Harry, who were tried and convicted in the U.S. Virgin Islands for multiple drug, firearm, and racketeering offenses connected to a violent criminal enterprise. Their trial took place in March 2022, shortly after COVID-19 restrictions on in-person court proceedings were partially lifted. On the first day of trial, public access to the courtroom was restricted, and spectators—including the defendants’ mothers—were directed to an overflow room with an audiovisual feed. Although the court later allowed some spectators into the courtroom, federal marshals continued to prevent the defendants’ mothers from entering for several days, even when seats were available. Following their convictions, Girard and Harry moved for a new trial in the District Court of the Virgin Islands, arguing that these restrictions violated their Sixth Amendment right to a public trial. The District Court held a hearing but ultimately found that public access was provided through the overflow room and that any interruptions in the audiovisual feed were brief. The court denied the motions for a new trial, concluding that the public was not excluded from the proceedings. On appeal, the United States Court of Appeals for the Third Circuit reviewed the case for plain error due to the lack of adequate contemporaneous objections during trial. The Third Circuit found that the defendants’ Sixth Amendment rights were violated when the courtroom was closed to all spectators on the first day and when their mothers were excluded on subsequent days without justification. However, the court held that these errors did not seriously affect the fairness, integrity, or public reputation of the proceedings. The court also rejected Harry’s claims regarding his rights to compulsory process and due process. Accordingly, the Third Circuit affirmed the judgments of conviction. View "USA v. Girard" on Justia Law

In re Whittaker, Clark & Daniels Inc

2026-05-19T09:00:14-08:00

Whittaker, Clark & Daniels, Inc. and three affiliates, with a history of manufacturing, storing, and distributing asbestos-containing talc, faced thousands of personal injury and environmental claims. After a $29 million verdict against Whittaker in South Carolina, a state court there appointed a receiver to administer Whittaker’s assets. Whittaker’s board, without consulting the receiver, authorized and filed a Chapter 11 bankruptcy petition in the United States Bankruptcy Court for the District of New Jersey. The Debtors’ estates were largely depleted by a 2004 asset sale to Brenntag, which expressly excluded liability for pre-sale asbestos and environmental claims. The Debtors, now essentially shells, sought to settle successor liability claims against Brenntag for $535 million, but some talc claimants had already asserted such claims against Brenntag in state courts. The South Carolina receiver and the Official Committee of Talc Claimants challenged the bankruptcy filing’s validity, arguing that only the receiver could authorize such a filing under the South Carolina court's order. The receiver’s motion to dismiss the bankruptcy petition as unauthorized was denied by the Bankruptcy Court, which found the South Carolina order did not divest Whittaker’s board of its authority. The United States District Court for the District of New Jersey affirmed. In parallel, the Committee contested whether certain “product-line” successor liability claims belonged to the Debtors’ estates or to individual creditors. The Bankruptcy Court, referencing Third Circuit precedent, held that such claims were property of the bankruptcy estates. The United States Court of Appeals for the Third Circuit affirmed both lower court decisions. It held that Whittaker’s Chapter 11 filing was valid, as the South Carolina court’s receivership order did not displace the board’s authority under New Jersey law, which governs corporate internal affairs. The court further held that successor liability claims based on product-line theory, even if nominally assertable by creditors outside bankruptcy, are property of the bankruptcy estate when they address a general injury to the debtor that results in secondary harm to all creditors. Accordingly, the judgments below were affirmed. View "In re Whittaker, Clark & Daniels Inc" on Justia Law

USA v. Evans

2026-05-19T09:00:13-08:00

A man checked into a hotel room in New Jersey in April 2021 and later moved to a larger room, turning in his key for the first room. After the initial room was cleaned, hotel staff discovered two handguns and letters with distinctive handwriting in the room’s safe. Police, notified by the hotel manager, linked the man to the room and discovered he had an outstanding arrest warrant. After a standoff, police arrested the man in his new hotel room. A search warrant was obtained and, upon execution, police found large quantities of various drugs, drug packaging materials, cash, and additional evidence hidden above the room’s ceiling tiles, including drug trafficking paraphernalia and letters matching those previously found. A federal grand jury indicted the man for being a felon in possession of firearms, possessing fentanyl and methamphetamine with intent to distribute, and possessing a firearm in furtherance of a drug-trafficking crime. He moved to suppress the evidence obtained from the hotel room, arguing the search exceeded the warrant’s scope. The United States District Court for the District of New Jersey denied the motion, finding probable cause supported the warrant and, alternatively, the good-faith exception applied. At trial, the court allowed a detective to give lay opinion testimony about drug trafficking based on his experience. The jury found the defendant guilty on all charges, and he was sentenced to 192 months’ imprisonment. On appeal, the United States Court of Appeals for the Third Circuit reviewed three claims: that the search of the ceiling was improper, that improper lay opinion testimony was admitted, and that the court erred in denying a spoliation instruction related to missing body camera footage. The Third Circuit held the search did not violate the Fourth Amendment, the admission of some improper lay opinion testimony was harmless given overwhelming evidence, and the denial of a spoliation instruction was not an abuse of discretion. The court affirmed the convictions and sentence. View "USA v. Evans" on Justia Law

Sociedad Concesionaria Metropolitana de Salud S.A. v. Webuild S.P.A

2026-05-18T09:00:12-08:00

A Chilean company contracted with an Italian construction firm to design and build a hospital in Santiago, Chile, with disputes to be resolved by arbitration in Chile. The Italian firm later underwent a restructuring proceeding in Italy, during which it spun off its operating business and merged into another Italian company, Webuild S.p.A., which acquired most of its assets. After the contract was terminated due to project delays, arbitration in Chile resulted in an award in favor of the Chilean company and against the original Italian firm. The Chilean courts reduced but otherwise affirmed the arbitral award, and further appeal was denied. Seeking to enforce the arbitral award in the United States, the Chilean company brought an action in the United States District Court for the District of Delaware against Webuild, claiming it was the successor in interest to the award debtor. The company asked the District Court to assert quasi in rem jurisdiction by attaching Webuild’s shares in a Delaware subsidiary. The District Court granted Webuild’s motion to dismiss for lack of personal jurisdiction, holding that there were insufficient contacts between the forum, Webuild, and the underlying controversy. The District Court also held that, even if an exception to the minimum contacts requirement applied, it would not permit jurisdiction here because no court had yet determined that Webuild was indeed liable for the arbitral debt. On appeal, the United States Court of Appeals for the Third Circuit held that, under the Supreme Court’s decision in Shaffer v. Heitner, a court may exercise traditional quasi in rem jurisdiction to enforce a foreign arbitral award in an action to collect on an already adjudicated debt, without requiring minimum contacts. The appellate court vacated the District Court’s dismissal and remanded for a determination of whether Webuild is the successor in interest to the original award debtor. View "Sociedad Concesionaria Metropolitana de Salud S.A. v. Webuild S.P.A" on Justia Law

McGoveran v. Amazon Web Services Inc

2026-05-12T09:00:11-08:00

A group of Illinois residents called John Hancock to discuss their retirement accounts. John Hancock routed these calls through Amazon Connect, a service provided by Amazon Web Services. During these calls, Pindrop Security, using its cloud-based biometric technology, authenticated the callers by analyzing their voiceprints. The plaintiffs alleged that Amazon and Pindrop collected their biometric information without the required consent, in violation of the Illinois Biometric Information Privacy Act (BIPA). The plaintiffs first brought their claims against Amazon in Illinois state court, but after Amazon removed the case to the United States District Court for the Southern District of Illinois, that court dismissed the case for lack of personal jurisdiction. The plaintiffs then filed a similar complaint in the United States District Court for the District of Delaware, adding Pindrop as a defendant. The District of Delaware initially dismissed the case on extraterritoriality grounds, but after amended complaints, dismissed all claims against Pindrop based on BIPA’s financial-institution exemption and most claims against Amazon, except the claim under Section 15(b) for collecting biometric data without written consent. The court later granted Amazon judgment on the pleadings as to a Section 15(d) claim and ultimately granted summary judgment in favor of Amazon, closing the case. The court also denied the plaintiffs’ motions related to discovery extensions and voluntary dismissal of certain plaintiffs. On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court in all respects. The Third Circuit held that Pindrop was exempt from BIPA under the financial-institution exemption, that the District Court did not abuse its discretion in denying discovery extensions or the voluntary dismissal motion, and that the extraterritoriality doctrine barred the plaintiffs’ BIPA claims against Amazon because the relevant conduct did not occur primarily and substantially in Illinois. The court also affirmed the judgment on the pleadings for the Section 15(d) claim. View "McGoveran v. Amazon Web Services Inc" on Justia Law

In Re: BPS Direct, LLC

2026-05-11T09:00:11-08:00

Several individuals sued two outdoor retailers, alleging that the retailers used third-party “Session Replay Code” on their websites to record users’ activities, including keystrokes, clicks, and text entries, without user consent. This code operated invisibly to typical users and transmitted the recorded data to outside providers, which could aggregate and store the information, including potentially sensitive details. Among the plaintiffs, two made purchases on the websites and entered personal information such as names, addresses, and complete credit or debit card numbers; the other six only browsed and did not provide identifying data. The lawsuits were consolidated and transferred to the U.S. District Court for the Eastern District of Pennsylvania. That court dismissed the complaint, ruling that none of the plaintiffs sufficiently alleged an “injury in fact” necessary for Article III standing. The District Court reasoned that only the sharing of highly sensitive information, like medical or financial data, would establish standing, and it dismissed with prejudice the claims of the six plaintiffs who did not make purchases (and thus did not provide sensitive data). As for the two plaintiffs who did make purchases, the court dismissed their claims without prejudice, allowing them to amend if they could allege sharing of highly sensitive information. On appeal, the United States Court of Appeals for the Third Circuit held that the two purchasing plaintiffs (Cornell and Montecalvo) alleged an injury analogous to the common-law tort of intrusion upon seclusion, since their complete credit or debit card numbers were surreptitiously recorded and transmitted. Thus, the Third Circuit reversed the dismissal as to those two plaintiffs and remanded for further proceedings. However, the court affirmed (as modified to be without prejudice) the dismissal of the claims brought by the other six plaintiffs, holding that their allegations did not establish a concrete injury sufficient for standing. View "In Re: BPS Direct, LLC" on Justia Law

USA v. Newkirk

2026-05-01T09:00:11-08:00

Steven Newkirk was investigated for drug-related activities, leading law enforcement to obtain a warrant to search his apartment. During the search, officers found a loaded, stolen firearm, ammunition, drug paraphernalia, heroin, and significant amounts of marijuana. Newkirk, a convicted felon with a history of drug-distribution offenses, was initially detained by New Jersey authorities and later charged federally with being a felon in possession of a firearm. He spent approximately two weeks in state custody, then was released on bond with conditions that were gradually relaxed over several years. During his pretrial release, Newkirk had repeated violations, including multiple positive drug tests. Despite these issues, Newkirk engaged in community work, notably founding a nonprofit aimed at reducing gang violence. The United States District Court for the District of New Jersey presided over Newkirk’s guilty plea to the firearm charge. At sentencing, the advisory Sentencing Guidelines range was 92 to 115 months' imprisonment. Newkirk requested probation or, alternatively, a significantly reduced sentence. The District Court, highlighting his community service and personal development, sentenced him to time served—approximately two weeks. The Government objected, arguing the sentence was unreasonably low, and appealed. The United States Court of Appeals for the Third Circuit reviewed the case. It found that the District Court’s sentence was both procedurally and substantively unreasonable. Procedurally, the sentencing court failed to sufficiently address the risk of unwarranted sentencing disparities and the need for general deterrence, and did not adequately justify the extraordinary downward variance. Substantively, the court held that no reasonable sentencing court would have imposed such a short sentence given the offense and Newkirk’s history. The Third Circuit vacated the sentence and remanded for resentencing, instructing the District Court to give serious consideration to a substantially longer sentence. View "USA v. Newkirk" on Justia Law

Kendig v. Stolar

2026-04-28T09:00:48-08:00

Corey Kendig was involved in a fatal altercation outside a Pennsylvania tavern in October 2020. After being confronted and physically attacked by Jeremy Jones and his friends, Kendig, while in a chokehold on the ground, discharged his firearm and fatally shot Jones. Kendig was immediately taken into custody, treated for his injuries, and subsequently charged by Trooper Nicholas Stolar with criminal homicide, aggravated assault, and recklessly endangering another person. At trial, Kendig was acquitted of all charges by a jury. Following his acquittal, Kendig brought a civil action in the United States District Court for the Western District of Pennsylvania against Trooper Stolar and the Pennsylvania State Police, asserting claims under 42 U.S.C. § 1983 for false arrest, false imprisonment, and malicious prosecution, arguing that he was arrested and charged without probable cause in violation of his Fourth Amendment rights. The District Court granted summary judgment for Stolar, finding that Stolar was entitled to qualified immunity because he did not violate a clearly established constitutional right by omitting facts relevant to Kendig’s self-defense from the affidavit of probable cause. The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that, while facts known to an officer supporting an affirmative defense like self-defense may be exculpatory and relevant to probable cause for certain offenses, the law was not clearly established at the time of Kendig’s arrest that an officer was constitutionally required to include such facts in a probable cause affidavit. Therefore, Stolar was entitled to qualified immunity. The Third Circuit affirmed the District Court’s order granting summary judgment in favor of Stolar. View "Kendig v. Stolar" on Justia Law

USA v. Lyons

2026-04-28T09:00:48-08:00

Aaron Lyons, after being caught with a gun at age eighteen on a Pittsburgh playground, pleaded guilty to possessing an offensive weapon under Pennsylvania law and was sentenced to probation. Following completion of his probation, he was again found with a firearm and subsequently pleaded guilty in federal court to being a felon in possession of a firearm. The court explained to Lyons that his prior conviction made it unlawful for him to possess a gun and that the federal offense carried significant penalties. At the time, prevailing case law did not require the government to prove that Lyons knew of his status as someone previously convicted of a crime punishable by more than one year. After Lyons’s federal conviction, the Supreme Court in Rehaif v. United States clarified that, for a conviction under the relevant statute, the government must prove the defendant knew of his felony status. Lyons filed a motion under 28 U.S.C. § 2255 in the U.S. District Court for the Western District of Pennsylvania, arguing his guilty plea was unknowing since he was not told of the knowledge-of-status element. The District Court dismissed the motion without an evidentiary hearing, ruling that Lyons had procedurally defaulted his claim by not raising it earlier, and that he failed to show actual innocence. The United States Court of Appeals for the Third Circuit reviewed the appeal and affirmed the District Court’s decision. The court held that Lyons’s Rehaif-based argument was not novel enough to excuse procedural default, as the underlying legal theory was reasonably available before Rehaif was decided. Furthermore, the appellate court found the record conclusively established that Lyons knew his status, making an evidentiary hearing unnecessary. The denial of the § 2255 motion was thus affirmed. View "USA v. Lyons" on Justia Law

In re: Whittaker Clark & Daniels

2026-04-27T09:00:10-08:00

Whittaker, Clark & Daniels, Inc. and three affiliates, historically involved in the manufacture and distribution of asbestos-containing talc, faced thousands of personal injury and environmental claims. Over the years, the companies divested their operating assets, notably selling them to Brenntag North America in 2004 while expressly excluding pre-sale asbestos and environmental liabilities. As liabilities mounted, one plaintiff obtained a large jury verdict in South Carolina and successfully moved to put Whittaker into receivership, with a receiver appointed to administer its assets. Following the South Carolina receivership, Whittaker's board authorized a Chapter 11 bankruptcy filing in the United States Bankruptcy Court for the District of New Jersey without consulting the receiver. The receiver moved to dismiss the bankruptcy, arguing that under the receivership order, only he had authority to file such a petition. The Bankruptcy Court denied the motion, finding that the receivership order did not displace the board’s authority. The United States District Court for the District of New Jersey affirmed this ruling. While bankruptcy proceedings moved forward, the Debtors negotiated a $535 million settlement with Brenntag to resolve successor liability claims. However, the Official Committee of Talc Claimants argued that certain product-line successor liability claims belonged exclusively to talc creditors and not to the bankruptcy estate. The United States Court of Appeals for the Third Circuit reviewed two central issues. First, it held that the propriety of Whittaker’s bankruptcy petition did not affect the bankruptcy court’s subject matter jurisdiction and that, under New Jersey law, the board retained authority to file for bankruptcy because the South Carolina receiver had not obtained recognition or ancillary receivership in New Jersey. Second, the court held that product-line successor liability claims, like other derivative claims based on injury to the debtor and available to all creditors, are property of the bankruptcy estate under 11 U.S.C. § 541(a)(1). Accordingly, the Third Circuit affirmed the lower courts’ judgments. View "In re: Whittaker Clark & Daniels" on Justia Law

Wexler v. Hawkins

2026-04-22T09:00:12-08:00

In June 2019, a confrontation occurred between a Philadelphia Police Department officer and a civilian near a parade route. The officer told the civilian, who was walking her bike, she could not proceed in a certain direction. An altercation followed, during which the officer used a choke hold and both parties sustained minor injuries. The civilian requested medical assistance and the officer’s identification, after which the officer escalated the charges against her. Based on the officer’s account, a detective recommended multiple criminal charges, including aggravated assault. The civilian was detained overnight, but charges were later dismissed. At trial in the U.S. District Court for the Eastern District of Pennsylvania, the plaintiff brought federal and state claims against the involved officers. The jury found for the plaintiff on all counts, awarding $6,000 in compensatory damages and $1 million in punitive damages—split evenly between the two defendants. The District Court reduced the punitive damages to $250,000 for each defendant, otherwise denying post-trial motions, and awarded attorneys’ fees to the plaintiff. On appeal, the United States Court of Appeals for the Third Circuit reviewed the denial of the detective’s motion for judgment as a matter of law de novo. The Third Circuit held that the detective had probable cause to recommend charges based on the information he had at the time, entitling him to judgment as a matter of law on the false arrest, false imprisonment, and malicious prosecution claims. Regarding punitive damages, the court found the $250,000 award against the officer constitutionally excessive under Supreme Court due-process standards and reduced it to $12,000. The court reversed the judgment against the detective, vacated the judgment against the officer as to punitive damages, and remanded for proceedings consistent with its opinion, including reconsideration of attorneys’ fees. View "Wexler v. Hawkins" on Justia Law

Johnson & Johnson v. Samsung Bioepis Co Ltd

2026-04-14T09:00:13-08:00

The case involves a dispute between two biopharmaceutical companies over the distribution of a biosimilar drug following the expiration of a key patent. After Janssen’s patent for the composition of its biologic drug expired, Samsung sought to introduce its biosimilar product. Janssen and Samsung had previously settled related patent litigation through an agreement that granted Samsung a limited license to enter the market at a set date and restricted Samsung’s ability to sublicense, except to certain commercialization partners. Samsung subsequently entered into agreements with both Sandoz and Quallent, a subsidiary of the Cigna Group, allowing Quallent to distribute the biosimilar under its own label. Janssen argued that the sublicense to Quallent violated the settlement agreement and would cause it irreparable harm by altering market dynamics, reducing its market share and negotiation leverage, and sought a preliminary injunction to prevent Samsung from supplying Quallent during the litigation. The United States District Court for the District of New Jersey denied Janssen’s motion for a preliminary injunction. The court found that while Janssen was likely to succeed on the merits of its breach-of-contract claim, it had not demonstrated irreparable harm because any injury could be measured and compensated by monetary damages. The court credited Samsung’s expert's view that harm to Janssen would be quantifiable, did not find persuasive evidence of brand loyalty or reputational harm, and concluded that Janssen’s asserted loss of negotiation leverage was too speculative. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s denial for abuse of discretion and affirmed. The Court held that loss of market share in a complex market does not categorically constitute irreparable harm in contract cases, and that mere difficulty in calculating damages does not meet the threshold for irreparable harm. The Court concluded that Janssen had not shown the requisite irreparable harm to justify preliminary injunctive relief. View "Johnson & Johnson v. Samsung Bioepis Co Ltd" on Justia Law

American Society for Testing & Materials v. UPCODES Inc

2026-04-07T10:00:57-08:00

A non-profit organization that develops and sells technical standards for use in industry brought suit against a for-profit company that operates an online library of building codes. The for-profit company published on its website the full text of several copyrighted standards developed by the non-profit, which had been incorporated by reference into the International Building Code. This building code, in turn, was adopted as law by the City of Philadelphia and other jurisdictions. The for-profit company made these incorporated standards freely available, though it also sold premium subscriptions for enhanced features. The non-profit derived significant revenue from licensing and selling its standards, including those incorporated into law, and did not authorize the copying. The case was first heard in the U.S. District Court for the Eastern District of Pennsylvania. After limited discovery and a hearing, the District Court denied the non-profit’s motion for a preliminary injunction, concluding that the for-profit company was likely to succeed on its fair use defense. The District Court found that the company’s publication of the standards for the purpose of public access to the law was transformative, even though the use was commercial in part, and that the standards, as incorporated into law, were primarily factual in nature. The District Court also found that copying the entire standards was reasonable because the law incorporated those standards in full, and that the effect on the market for the standards was at best equivocal. On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s denial of the preliminary injunction. The Third Circuit held that the for-profit company is likely to succeed on the merits of its fair use defense, as three of the four statutory fair use factors favored fair use and the fourth was equivocal. The order denying the preliminary injunction was affirmed. View "American Society for Testing & Materials v. UPCODES Inc" on Justia Law

Kalshiex LLC v. Flaherty

2026-04-06T10:00:36-08:00

KalshiEX LLC operates a federally licensed designated contract market (DCM) that allows users to trade event contracts, including those based on sports outcomes. In late 2024, after Kalshi began offering sports-related event contracts similar to those offered by a competitor, New Jersey issued a cease-and-desist letter. The state asserted that Kalshi’s activities violated the New Jersey Constitution and state gambling laws, particularly regarding betting on collegiate sports, and threatened legal action with significant penalties if Kalshi continued its operations within New Jersey. In response, Kalshi initiated proceedings in the United States District Court for the District of New Jersey, seeking a preliminary injunction to prevent enforcement of New Jersey’s gambling laws against its federally regulated contracts. The District Court granted the injunction, finding that Kalshi had a reasonable likelihood of success on the merits, would suffer irreparable harm without relief, and that the public interest favored enjoining enforcement of potentially preempted state law. New Jersey appealed this decision. The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error, legal conclusions de novo, and the decision to grant the preliminary injunction for abuse of discretion. The Third Circuit affirmed the District Court’s order. The appellate court held that the Commodity Exchange Act (CEA) grants the Commodity Futures Trading Commission (CFTC) exclusive jurisdiction over swaps, including sports-related event contracts traded on CFTC-licensed DCMs. Both field and conflict preemption principles bar New Jersey from enforcing its gambling laws against these contracts. The court concluded that Kalshi demonstrated a likelihood of success on the preemption claim, irreparable harm in the absence of an injunction, and that the equities and public interest favored injunctive relief. Accordingly, the court affirmed the preliminary injunction. View "Kalshiex LLC v. Flaherty" on Justia Law

USA v. Miller

2026-04-03T10:00:54-08:00

Between April 2020 and September 2021, the defendant orchestrated a scheme to defraud federal relief programs, including the Paycheck Protection Program, Economic Injury Disaster Loan program, and Pandemic Unemployment Assistance program, leading to losses exceeding $2 million. He submitted multiple fraudulent loan applications using his own identity, corporate entities, his wife’s and neighbor’s information, and the personal information of at least thirteen other family members and associates. These individuals provided their details to facilitate the fraud and, upon receiving illicit funds, paid kickbacks to the defendant. The defendant’s wife was found to have gone beyond simply providing her information, including contacting a lender and fleeing with the defendant to avoid law enforcement. His neighbor also played a more active role and later pleaded guilty to wire fraud. The United States District Court for the Middle District of Pennsylvania accepted the defendant’s guilty plea to bank fraud, aggravated identity theft, and unlawful monetary transactions. At sentencing, the District Court applied a four-level enhancement under U.S.S.G. § 3B1.1(a), finding that the scheme was “otherwise extensive,” and included at least three “participants” (the defendant, his wife, and his neighbor), plus thirteen non-participants. The court overruled the defendant’s objections, adopted the Presentence Investigation Report, and imposed a 149-month sentence. On appeal, the United States Court of Appeals for the Third Circuit reviewed whether the District Court correctly applied the four-level enhancement, specifically whether the wife and neighbor qualified as “participants.” The appellate court held that the phrase “otherwise extensive” in the guideline is ambiguous, and that the District Court’s reliance on the commentary and prior precedent was ultimately appropriate. The Third Circuit found any legal error by the District Court was harmless and affirmed the sentence, holding that the enhancement was properly applied under the correct legal standard. View "USA v. Miller" on Justia Law

Cardenas v. Attorney General United States of America

2026-03-31T10:00:56-08:00

A citizen of the Dominican Republic entered the United States without authorization as a child and lived with his mother, brother, and stepfather. The stepfather, who was not an authorized resident at the time, severely abused both the petitioner and his mother. After enduring years of abuse, the petitioner left home as a teenager but continued to support his mother, who later developed significant mental health issues linked to her trauma. The stepfather eventually gained lawful permanent resident (LPR) status and later threatened the petitioner again. The petitioner was charged with removability for lacking valid entry documents. He conceded removability but sought relief through two forms of cancellation: one, a special rule for individuals abused by a parent who is or was an LPR or citizen; the other, cancellation of removal for non-lawful permanent residents based on hardship to a qualifying relative. The Immigration Judge denied both applications, finding the petitioner ineligible for special rule cancellation because the stepfather was not an LPR at the time of the abuse, and finding insufficient evidence of exceptional and extremely unusual hardship to the mother to grant cancellation of removal. On appeal, the Board of Immigration Appeals (BIA) affirmed the Immigration Judge, agreeing that the abuser had to be an LPR at the time of the abuse and that the hardship to the mother did not meet the statutory threshold. The petitioner then sought review in the United States Court of Appeals for the Third Circuit. The Third Circuit held that the special rule for cancellation does not require the abuser to have been an LPR at the time of the abuse; it is sufficient if the abuser is or was an LPR at any time before relief is adjudicated. The court thus granted the petition on this claim and remanded for further proceedings. However, it denied the petition regarding cancellation of removal, finding substantial evidence supported the BIA’s conclusion on hardship. View "Cardenas v. Attorney General United States of America" on Justia Law

DiFraia v. Ransom

2026-03-31T10:00:56-08:00

A Pennsylvania state prisoner with a history of opioid addiction participated in a prison Medication Assisted Treatment program, receiving Suboxone to help control his cravings. After prison officials twice accused him of possessing contraband and diverting his medication to other prisoners, he was removed from the treatment program. Instead of abruptly ending his medication, a prison doctor tapered his doses over a week to reduce withdrawal symptoms. The prisoner later suffered withdrawal effects and mental health challenges but was not reinstated in the program despite his requests. He claimed the diversion finding was unfair but did not allege personal animus or pretext by the officials involved. He filed a pro se lawsuit in the U.S. District Court for the Middle District of Pennsylvania against various prison officials and a doctor, alleging violations of the Eighth Amendment (cruel and unusual punishment), the Americans with Disabilities Act (ADA), and a state-law negligence claim. The District Court dismissed all claims, finding the federal claims inadequately pleaded and the state-law claim procedurally improper for lack of a certificate of merit under Pennsylvania law. The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court affirmed the dismissal of the Eighth Amendment claim, holding that the complaint failed to allege deliberate indifference to medical needs as required by precedent; the officials’ actions were judged to be good-faith medical decisions, not constitutionally blameworthy conduct. The court also affirmed dismissal of the ADA claim, finding no plausible allegation that the prisoner was excluded from treatment “by reason of” his disability, but rather for diversion of medication. However, the court vacated the dismissal of the state-law negligence claim, as recent Supreme Court precedent abrogated the procedural requirement relied upon by the District Court, and remanded for further proceedings on that claim. View "DiFraia v. Ransom" on Justia Law

McCarthy v. DEA

2026-03-27T10:00:55-08:00

An attorney representing a party before a federal appellate court submitted two briefs containing summaries of prior administrative agency decisions. These summaries were provided by a non-attorney, who had used artificial intelligence (AI) to generate them. The attorney made minor edits but did not verify the existence or accuracy of the cited authorities before filing the briefs. Seven of the eight cited authorities were inaccurately described, and one did not exist. The government identified these issues in its response, but even after reading the government’s brief and suspecting that AI had been used, the attorney did not check the citations or correct the record. He characterized the errors as immaterial in a reply brief, again without verification. Only after the court ordered him to provide copies of the cited decisions did the attorney confirm the inaccuracies and the nonexistence of one adjudication. Following the discovery of these misrepresentations, the United States Court of Appeals for the Third Circuit ordered the attorney to show cause why he should not be sanctioned. In response, the attorney admitted to his failures, demonstrated contrition, and described corrective actions taken. He requested and received a hearing regarding potential sanctions. The United States Court of Appeals for the Third Circuit held that the attorney violated Pennsylvania Rule of Professional Conduct 1.1, which requires competent representation, by failing to thoroughly verify citations and relying on unverified, AI-generated summaries. The court found that while the attorney’s conduct did not rise to a knowing violation of the duty of candor under Rule 3.3, his overall lack of diligence warranted discipline. The court imposed a public reprimand, with notice to other courts and disciplinary authorities, but did not impose monetary sanctions, citing mitigating factors including the novelty of AI issues and the attorney’s post-hearing candor. View "McCarthy v. DEA" on Justia Law

USA v. Anderson

2026-03-26T10:00:55-08:00

Law enforcement officers executed a search warrant at a residence where a firearm was discovered in a bag containing the defendant’s identification and two loaded magazines. The defendant was present in the bedroom with the bag and was on parole for a prior state offense. DNA swabs taken from the firearm, along with a sample from the defendant, were analyzed by the Pennsylvania State Police Crime Laboratory, which identified multiple DNA contributors but could not conclusively match the DNA to the defendant. The DNA evidence was then submitted to a private company using TrueAllele probabilistic genotyping software, which calculated an extremely high likelihood ratio indicating the DNA was much more likely to include the defendant as a contributor. The defendant moved to exclude the TrueAllele evidence in the United States District Court for the Middle District of Pennsylvania, arguing it was unreliable under Daubert v. Merrell Dow Pharmaceuticals, Inc. and Rule 702 of the Federal Rules of Evidence. After a two-day Daubert hearing featuring expert testimony from both sides, the District Court found that the government met its burden to demonstrate the reliability of TrueAllele and denied the motion to exclude. The District Court also rejected the defendant’s motion to dismiss the indictment on Second Amendment grounds. The defendant ultimately pleaded guilty, preserving his right to appeal these rulings, and was sentenced to 78 months of imprisonment, consecutive to an anticipated state sentence. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s Daubert ruling for abuse of discretion and its Second Amendment analysis de novo. The Third Circuit held that TrueAllele’s methodology was sufficiently reliable for admissibility, finding that it satisfied factors such as testability, low error rates, presence of governing standards, peer review, and general acceptance in the relevant scientific community. The Court also affirmed the District Court’s rejection of the defendant’s constitutional and sentencing challenges, and the judgment was affirmed. View "USA v. Anderson" on Justia Law

International Brotherhood of Electrical Workers Local Union 29 v. Energy Harbor Nuclear Corp

2026-03-23T10:00:38-08:00

Energy Harbor Nuclear Corporation operated a power plant in Pennsylvania, where its employees were represented by the International Brotherhood of Electrical Workers, Local 29. After a 2021 dispute over health care benefit contributions, an arbitrator found that Energy Harbor had underpaid and ordered it to make additional contributions for 2021. Later, the parties entered into a new collective-bargaining agreement (CBA) on October 1, 2021, which included a broad arbitration clause and a merger clause voiding prior agreements not incorporated into the new CBA. When the union later alleged that Energy Harbor similarly underpaid contributions for 2022, it filed a grievance, contending that Energy Harbor failed to adjust 2022 contributions as required by the prior arbitration award. The United States District Court for the Western District of Pennsylvania reviewed the matter after the union sought to compel arbitration. The District Court, adopting a magistrate judge’s recommendation, held that the broad arbitration clause in the new CBA covered the dispute regarding the 2022 contributions. The court reasoned that because the grievance referenced the contribution-increase provision of the CBA, the dispute was subject to arbitration, and found no evidence that the parties intended to exclude such claims from arbitration. On appeal, the United States Court of Appeals for the Third Circuit reversed. The Third Circuit held that, although the arbitration clause was broad, the union’s grievance regarding 2022 contributions did not arise under the new CBA but instead relied on the prior arbitration award, which was not incorporated into the new agreement. The court concluded that the dispute had “nothing to do with” the rights under the CBA because there was no evidence of a required increase in Energy Harbor’s health care plan costs from 2021 to 2022. The Third Circuit reversed and remanded with instructions to grant summary judgment for Energy Harbor. View "International Brotherhood of Electrical Workers Local Union 29 v. Energy Harbor Nuclear Corp" on Justia Law

USA v. Lyttle

2026-03-16T10:00:13-08:00

A resident of New York, originally from Jamaica, ran a fraudulent scheme with several family members. The operation targeted elderly Americans by falsely informing them they had won a Publishers Clearing House lottery, but required them to pay taxes or fees in advance to claim their prizes. Victims were instructed to send cash, wire money, or ship car parts to the group’s businesses in New York, which were then used to launder the proceeds through various bank accounts and entities in the United States and Jamaica. Following an investigation initiated by a victim’s family, the United States Postal Inspection Service uncovered the network. Multiple individuals, including the defendant, his ex-wife, his son, and a former partner, were indicted. The United States District Court for the Middle District of Pennsylvania held a jury trial, resulting in convictions on charges including conspiracy to commit wire and mail fraud, mail fraud, wire fraud, transportation of fraudulently obtained goods, and conspiracy to launder money. The District Court sentenced the defendant to 97 months’ imprisonment and ordered restitution, also applying a sentencing enhancement for his managerial role. The United States Court of Appeals for the Third Circuit reviewed the case. The court found that the defendant had not preserved his argument regarding the foreseeability of a victim’s use of a credit card for a wire fraud conviction, and regardless, the evidence supported the jury’s verdict. The appellate court also held that the District Court did not err in applying the managerial sentencing enhancement, as evidence showed the defendant exercised control over others in the criminal activity. Finally, the court determined that the District Court did not abuse its discretion by admitting two evidentiary exhibits related to the defendant’s knowledge of lottery scams. The Third Circuit affirmed the judgment of the District Court. View "USA v. Lyttle" on Justia Law

United States v. Gascot Concepcion

2026-03-10T10:00:53-08:00

Carlos Gascot Concepcion was apprehended at the St. Thomas airport while traveling to Puerto Rico with a suitcase containing over one kilogram of high-purity cocaine. The cocaine was vacuum-sealed, wrapped, hidden inside a backpack, and labeled with a trafficker’s brand. Alongside the cocaine, agents found some cash, two cell phones, and small amounts of a green leafy substance. At trial, the government’s expert testified that the quantity, packaging, and purity of the cocaine were consistent with distribution, not personal use. Concepcion’s defense centered on the claim that he intended to consume the cocaine himself, supported only by his father’s testimony about Concepcion’s history of marijuana use. The District Court of the Virgin Islands presided over Concepcion’s trial. After evidence was presented, Concepcion requested a jury instruction on the lesser-included offense of simple possession, arguing that there was sufficient evidence for the jury to consider personal use. The District Court denied this request, finding no rational basis for a jury to conclude Concepcion lacked intent to distribute, given the overwhelming evidence to the contrary. The jury subsequently convicted Concepcion of possession with intent to distribute, and he was sentenced accordingly. The United States Court of Appeals for the Third Circuit reviewed the District Court’s refusal to give the lesser-included offense instruction for abuse of discretion. The appellate court held that a district court need only instruct on a lesser-included offense if the evidence would allow a rational jury to acquit on the greater charge and convict on the lesser. Here, the appellate court agreed that the evidence overwhelmingly established intent to distribute, and that no rational jury could find otherwise. The Third Circuit affirmed the District Court’s judgment and conviction order. View "United States v. Gascot Concepcion" on Justia Law

Massey v. Borough of Bergenfield

2026-03-06T11:00:12-08:00

The plaintiff, a white male, served for decades in the Borough of Bergenfield’s Police Department and was acting as Officer In Charge in 2019. When the Chief position became available, he sought the promotion but was denied in favor of another candidate, an Arab-Muslim male. The plaintiff alleged that the decision was based on racial and religious discrimination, pointing to statements and actions by council members and the Borough Administrator suggesting that race and religion played a role. He brought claims under New Jersey’s Law Against Discrimination (NJLAD), 42 U.S.C. § 1983 (Equal Protection), and 42 U.S.C. § 1981. The case was first reviewed by the U.S. District Court for the District of New Jersey, which granted summary judgment in favor of the defendants on all claims. Regarding the NJLAD claim, the court relied on New Jersey’s “Background Circumstances Rule,” requiring majority-group plaintiffs to show that they were victimized by an employer who discriminates against the majority. The court also found that the plaintiff failed to adequately rebut the defendants’ justifications. It further held that § 1983 did not provide a remedy for employment discrimination claims and that § 1981 did not support a private cause of action. The U.S. Court of Appeals for the Third Circuit reviewed the case de novo. The court held that the Background Circumstances Rule is incompatible with the text of the NJLAD and predicted that the Supreme Court of New Jersey would follow the U.S. Supreme Court’s ruling in Ames v. Ohio Dep’t of Youth Servs., striking down the rule for state law claims. It reversed the District Court’s summary judgment on the NJLAD and § 1983 claims, finding genuine disputes of material fact requiring a trial. The court affirmed the summary judgment on the § 1981 claim and remanded for further proceedings. View "Massey v. Borough of Bergenfield" on Justia Law

RTI Restoration Technologies Inc v. International Painters and Allied Trades Industry Pension Fund

2026-03-03T11:01:01-08:00

The case involves a multi-employer pension fund seeking to collect withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 from two corporate entities, which the fund alleged were successors to a defunct contributing employer. The companies denied any liability, contending they had never agreed to make contributions to the fund, were not under common control with the original employer, and were not otherwise subject to the fund’s claims. After the fund notified the companies of the alleged liability several years after the original employer ceased operations, the companies sought a declaratory judgment in federal court to clarify that they were not liable. The fund counterclaimed for withdrawal liability, as well as damages and interest. The United States District Court for the District of New Jersey found genuine disputes of material fact regarding whether the companies could be treated as employers under the applicable law, thus precluding summary judgment on that issue. Nevertheless, the District Court granted judgment in favor of the companies on a separate basis: it concluded that the fund’s eight-year delay in providing notice and demanding payment of withdrawal liability failed to meet the statutory requirement under 29 U.S.C. § 1399(b)(1) that such notice be given “as soon as practicable.” The court reasoned that this requirement is an independent statutory element—not an affirmative defense subject to waiver or arbitration—and that the fund’s failure to comply with it barred any recovery. On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that timely notice and demand is a necessary element for a withdrawal liability claim to accrue under the MPPAA; if the fund fails to act “as soon as practicable,” its claim cannot proceed, regardless of whether the issue is raised in arbitration or by the parties. Arbitration was not required in this circumstance, and the District Court properly resolved the question. View "RTI Restoration Technologies Inc v. International Painters and Allied Trades Industry Pension Fund" on Justia Law

USA v. Abrams

2026-02-23T11:00:12-08:00

The case concerns a defendant who, as the sole operator of a clean energy startup, misled investors by supplying them with altered documents, forged signatures, and false financial information to exaggerate his company’s position and prospects. After obtaining nearly $1 million from a university-affiliated incubator and several individual investors, he quickly withdrew large sums, routed money through his own accounts in suspicious transfers, and used most of the funds to purchase a personal residence. He repeatedly lied to investors and federal agents to conceal his activities. Despite red flags, the investors disbursed funds based on his representations. A federal grand jury in the United States District Court for the Middle District of Pennsylvania indicted him on multiple counts, including wire fraud, mail fraud, aggravated identity theft, money laundering, unlawful monetary transactions, obstruction of justice, and making false statements. At trial, the defendant made a generalized motion for acquittal under Rule 29, which the District Court denied. The jury found him guilty on all counts. The District Court sentenced him to 72 months in prison and imposed over $1.1 million in restitution, later amended to include attorneys’ fees incurred by the victims. On appeal to the United States Court of Appeals for the Third Circuit, the defendant raised sufficiency-of-the-evidence challenges, argued instructional error regarding the aggravated identity theft counts, and disputed the restitution award for attorneys’ fees. The Third Circuit held that a non-specific Rule 29 motion does not preserve all sufficiency arguments for appeal and that, under plain-error review, the evidence supported all convictions. The court found no instructional error or constitutional vagueness in the aggravated identity theft statute. However, it held that the Mandatory Victims Restitution Act does not authorize restitution for attorneys’ fees. The convictions and sentence were affirmed, the restitution order for attorneys’ fees was vacated, and the case was remanded for entry of an amended judgment. View "USA v. Abrams" on Justia Law

DLJ Mortgage Capital Inc v. Stevens

2026-02-18T13:00:12-08:00

Carlton Stevens mortgaged several adjacent plots of land in St. Croix in 1997 to secure a loan, but eventually defaulted on the payments and died in 2011. Banco Popular, the original mortgagee, assigned its rights to DLJ Mortgage Capital. In 2018, DLJ initiated a foreclosure action in the Superior Court of the Virgin Islands against Stevens’s heirs, the IRS (which held expired tax liens), and other subordinate lienholders. DLJ sought debt recovery, foreclosure, quiet title, and reformation of the mortgage to correct a scrivener’s error omitting a plot (20-BC). The IRS removed the case to the District Court of the Virgin Islands, where it was dismissed as a party after the tax liens were found expired. The heirs initially failed to appear, resulting in defaults, but later filed an answer with numerous affirmative defenses, and the defaults were vacated by stipulation. DLJ moved for summary judgment on the debt and foreclosure claims, but the heirs did not respond. Subsequently, the District Court asked DLJ for evidence supporting reformation, and gave the heirs an opportunity to object. The heirs submitted a brief opposition on equitable grounds but provided no evidence. The District Court granted summary judgment against the heirs and an appearing lienholder, default judgment against others, and reformed the mortgage to include plot 20-BC, finding its omission a mutual mistake. On appeal, the United States Court of Appeals for the Third Circuit reviewed the summary judgment de novo and the mutual mistake finding for clear error. The Third Circuit held that a party forfeits affirmative defenses not raised in opposition to summary judgment, even if previously pled in an answer, and found no extraordinary circumstances to address the forfeited arguments. The Court also concluded that the District Court’s finding of mutual mistake warranting reformation was not clearly erroneous, and affirmed the District Court’s summary judgment and reformation order. View "DLJ Mortgage Capital Inc v. Stevens" on Justia Law

Defense Distributed v. Attorney General New Jersey

2026-02-12T11:00:36-08:00

A Texas-based company distributed files online that enabled the 3D printing of functional, untraceable firearms. After New Jersey’s Attorney General issued a cease-and-desist letter and the state legislature enacted a statute prohibiting the distribution of such files to unlicensed individuals, the company and an affiliated nonprofit restricted New Jersey residents from accessing these files. The plaintiffs challenged the actions, alleging violations of the First, Second, and Fourteenth Amendments. Initially, the plaintiffs filed suit in the Western District of Texas, which dismissed the case for lack of personal jurisdiction. Plaintiffs then filed a similar suit in the District of New Jersey, alleging the statute constituted criminal censorship. After complex procedural maneuvers—including appeals and transfers between Texas and New Jersey, and requests for retransfer—the litigation proceeded in the District of New Jersey, which consolidated the relevant cases. The United States Court of Appeals for the Third Circuit reviewed the District of New Jersey’s decision to dismiss the complaint with prejudice. The Third Circuit affirmed the lower court’s rulings. It held that the district court did not abuse its discretion in denying retransfer to Texas. The court further held that the plaintiffs lacked standing to bring a Second Amendment claim, as there were no allegations that any plaintiff or member was prevented from 3D-printing a firearm. The court also found the statute was not void for vagueness under the Due Process Clause, as it provided fair notice of prohibited conduct. Finally, the court held that plaintiffs failed to plead sufficient facts showing that the computer code at issue was expressive and entitled to First Amendment coverage, as the complaint did not detail the nature or expressive use of the files. The dismissal with prejudice was affirmed. View "Defense Distributed v. Attorney General New Jersey" on Justia Law

Knieling v. Fook

2026-02-11T11:00:36-08:00

Tammy Knieling worked as a chef and deck hand on a chartered boat owned by William Poston and captained by Don Fung Fook. During a voyage, Knieling broke and dislocated her left middle finger while following an order to release the dinghy line. Despite the injury, she continued her work and did not miss any wages. After returning ashore, she was treated for the injury, which resulted in permanent loss of some range of motion. A medical expert suggested possible future treatments, including exercises, injections, and potentially surgery, but could not confirm if she had reached maximum medical improvement or if further treatments would be necessary or effective. Knieling brought suit against both Fook and Poston in the District Court of the Virgin Islands, which conducted a bench trial. The District Court dismissed her claims against Fook but found Poston liable under the Jones Act for negligence, awarding past medical expenses and pain and suffering. The court also found Poston liable for medical expenses under admiralty law but determined Knieling had already recovered these. It declined to award her living expenses, punitive damages, or attorney’s fees, finding she neither took time off work nor incurred additional living costs, and that Poston’s delay in payment was not in bad faith. On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that Knieling could not recover maintenance because she did not miss work or incur additional living expenses. The court also held that her claim for future medical expenses was too speculative, as there was insufficient evidence regarding her need for further treatment. However, if she requires curative treatment in the future, she may bring a new claim. Finally, the court affirmed the denial of punitive damages, attorney’s fees, and costs due to the absence of bad faith by the defendants. View "Knieling v. Fook" on Justia Law

USA v. Smith

2026-02-03T11:48:52-08:00

Dameia Smith, an IRS tax examining clerk, was involved in a series of criminal acts beginning with the armed robbery of a restaurant employee in September 1998. After learning that the victim was cooperating with authorities, Smith accessed the IRS database to obtain her address and expressed intentions to prevent her from testifying, including stating he would kill her. In January 1999, Smith drove to the victim’s home with a firearm and attempted to persuade a friend to kill her; when the friend refused, Smith coerced him into an attempted bank robbery. The plan failed, and Smith was arrested after his friend began cooperating with law enforcement. Smith was tried in the United States District Court for the Eastern District of Pennsylvania on six counts, including Hobbs Act robbery, unauthorized computer access, solicitation to commit murder of a federal witness, attempted murder of a federal witness, and using a firearm during and in relation to a crime of violence under 18 U.S.C. § 924(c). The jury initially convicted Smith only of unauthorized computer access, but on retrial, convicted him on all charges. Smith’s § 924(c) conviction was predicated on either solicitation or attempted murder, with a general verdict form not specifying which. The District Court imposed a lengthy sentence and later denied Smith’s motion for relief under 28 U.S.C. § 2255, finding attempted murder of a federal witness was a crime of violence under the elements clause. Subsequent remands and appeals followed Supreme Court decisions narrowing the scope of qualifying predicates for § 924(c). On appeal, the United States Court of Appeals for the Third Circuit held that attempted murder of a federal witness categorically qualifies as a “crime of violence” under 18 U.S.C. § 924(c)'s elements clause because it necessarily requires proof of the attempted use of physical force. The court also found no reasonable probability that Smith’s § 924(c) conviction was based solely on solicitation, an invalid predicate, rendering any instructional error harmless. The Third Circuit affirmed the District Court’s denial of relief. View "USA v. Smith" on Justia Law

Abramowski v. Nuvei Corp

2026-02-03T11:48:52-08:00

Several shareholders of Paya Holdings, Inc.—who were originally sponsors of a special purpose acquisition company that merged with Paya—held “Earnout Shares” subject to contractual transfer restrictions. Under the Sponsor Support Agreement (“SSA”), these shares could not be transferred until October 2025 unless a “Change in Control” occurred and the price per share exceeded $15.00. If the price was below $15.00, the Earnout Shares would be automatically forfeited prior to consummation of the change. In January 2023, Nuvei Corporation agreed to purchase all Paya shares for $9.75 per share in a tender offer. The offer required that tendered shares be freely transferable. The appellants attempted to tender their Earnout Shares, but Nuvei rejected them, citing the SSA’s restrictions. The shareholders sued Nuvei in the U.S. District Court for the District of Delaware, alleging that Nuvei violated the SEC’s Best Price Rule, which requires the highest consideration paid to any shareholder in a tender offer to be paid to all shareholders of that class. The District Court dismissed the suit for failure to state a claim, reasoning that no consideration was actually paid to the appellants because their shares were not validly tendered due to the transfer restrictions. On appeal, the U.S. Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The Third Circuit held that the Best Price Rule does not require a tender offeror to purchase shares that are subject to self-imposed transfer restrictions. The Rule mandates equal payment only for shares “taken up and paid for” pursuant to a tender offer, and it is silent regarding whether offerors must accept all tendered shares. Therefore, Nuvei was not required to purchase the appellants’ restricted shares, and dismissal of their claim was proper. View "Abramowski v. Nuvei Corp" on Justia Law

Essintial Enterprise Solutions LLC v. SBA

2026-02-03T11:48:51-08:00

Essintial Enterprise Solutions, LLC, a staffing and services company, received a $7 million Paycheck Protection Program (PPP) loan during the COVID-19 pandemic. The company calculated its loan amount based on its reported payroll costs, which included payments made to both employees and independent contractors. After the loan was issued and the company applied for forgiveness, its bank approved forgiveness of the full amount. However, the Small Business Administration (SBA) reviewed the forgiveness request and determined that payments made to independent contractors were not eligible as “payroll costs” under the CARES Act, resulting in only partial forgiveness. The SBA forgave approximately $3.7 million and denied forgiveness for the remainder that was based on contractor payments. Essintial challenged the SBA’s decision by filing suit in the United States District Court for the Middle District of Pennsylvania. The company argued that the SBA’s interpretation of “payroll costs” was erroneous and violated the Administrative Procedure Act (APA). The District Court agreed with Essintial, granting summary judgment in its favor. It held that the SBA’s exclusion of independent contractor payments from payroll costs was arbitrary and capricious, and ordered full loan forgiveness for Essintial. On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory definition of “payroll costs” in the CARES Act de novo. The Third Circuit held that the SBA’s interpretation was correct: payments to independent contractors by a business are not included as “payroll costs” for PPP loan forgiveness purposes. The court concluded that the CARES Act provides two separate definitions of “payroll costs” depending on the borrower’s type, and Essintial’s payments to independent contractors did not qualify. The Third Circuit reversed the District Court’s judgment and remanded for further proceedings. View "Essintial Enterprise Solutions LLC v. SBA" on Justia Law

Michelin v. Warden Moshannon Valley Correctional Center

2026-02-02T10:00:15-08:00

Two individuals, one a Nigerian citizen and another a Jamaican citizen, were held in U.S. immigration detention for extended periods following the completion of criminal sentences or pending immigration proceedings. Both petitioned for writs of habeas corpus in the United States District Court for the Western District of Pennsylvania, challenging their prolonged detention without individualized bond hearings as violations of their Fifth Amendment rights. The District Court granted both petitions, ordered bond hearings, and both individuals were subsequently released on bond. Following their success, each petitioner sought attorneys’ fees and costs under the Equal Access to Justice Act (EAJA). The District Court found that the government’s position in opposing the habeas petitions was not "substantially justified" and awarded fees: $18,224.58 to the Nigerian petitioner and $15,841.60 to the Jamaican petitioner. The government appealed these fee awards to the United States Court of Appeals for the Third Circuit. The United States Court of Appeals for the Third Circuit addressed whether a habeas corpus petition challenging immigration detention under 28 U.S.C. § 2241 qualifies as a “civil action” under the EAJA, thus entitling prevailing parties to attorneys’ fees and costs. The Third Circuit held that such habeas actions are indeed “civil actions” within the meaning of the EAJA, relying on longstanding legal tradition and statutory interpretation. The court further affirmed that the government’s position in the Nigerian petitioner’s case was not substantially justified, due to the lengthy detention without a bond hearing. Accordingly, the Third Circuit affirmed the District Court’s awards of attorneys’ fees and costs to both petitioners. View "Michelin v. Warden Moshannon Valley Correctional Center" on Justia Law

Sargent v. School District of Philadelphia

2026-02-02T10:00:14-08:00

Three parents of students in Philadelphia challenged the School District’s 2022 Admissions Policy for four selective public high schools. Prior to 2022, admissions decisions were made by individual schools using academic criteria, attendance, and sometimes additional requirements such as interviews and writing samples. After a report identified geographic disparities in school representation, and following the School District’s public commitments to anti-racism and equity, a new centralized policy was adopted. This policy introduced revised academic standards, eliminated certain prior requirements, and implemented a zip code preference favoring applicants from six areas with high Black and Hispanic populations. Qualified applicants from these zip codes received automatic admission, while others had to enter a lottery for remaining seats. The parents, whose children lived outside the preferred zip codes and met the new criteria but were not admitted to their first-choice schools, filed suit in the United States District Court for the Eastern District of Pennsylvania. They alleged violations of Title VI, the Equal Protection Clause, and related state constitutional provisions, arguing that the new process was racially discriminatory. The District Court granted summary judgment for the School District, finding that no reasonable factfinder could conclude the policy had a racially discriminatory purpose or impact. The court applied rational basis review, holding the policy was rationally related to legitimate interests such as increasing access for underrepresented geographic areas. On appeal, the United States Court of Appeals for the Third Circuit held that, viewing the evidence in the light most favorable to the parents, a reasonable factfinder could conclude the Admissions Policy had both discriminatory purpose and impact. The Third Circuit vacated the District Court’s judgment and remanded for further proceedings, directing that strict scrutiny must be applied if a discriminatory purpose and impact are found. View "Sargent v. School District of Philadelphia" on Justia Law

United States v. Abrams

2026-01-30T10:00:14-08:00

The appellant in this case was the sole owner and operator of a clean energy startup. In order to attract investment, he provided prospective investors with forged business agreements, altered financial statements, and other documents that misrepresented the company’s assets, operational history, and business relationships. He also fabricated the signatures of various business partners and used personal information of others without authorization. Investors provided nearly $1 million based on these representations. The appellant then diverted a substantial portion of the funds for personal use, including the purchase of a residence, and obscured these transactions through rapid transfers among several accounts. He continued to mislead investors about the use of their funds and the status of the business. When questioned by federal agents, he made a series of false statements regarding his activities. A grand jury in the U.S. District Court for the Middle District of Pennsylvania indicted the appellant on multiple counts, including wire fraud, mail fraud, aggravated identity theft, money laundering, unlawful monetary transactions, obstruction of justice, and making false statements. After a nine-day jury trial, the jury found him guilty on all counts. The District Court sentenced him to 72 months’ imprisonment and ordered restitution of approximately $1.2 million, including attorneys’ fees incurred by victims. The United States Court of Appeals for the Third Circuit reviewed the case. On appeal, the appellant challenged the sufficiency of the evidence, the jury instructions, the constitutionality of the aggravated identity theft statute, denial of a good faith instruction, and the restitution order. The Court held that a general Rule 29 motion does not preserve all sufficiency arguments for appeal and found no plain error in the conviction. It also found the jury instructions and statute to be proper and the denial of the good faith instruction not to be an abuse of discretion. However, the Court held that the Mandatory Victims Restitution Act does not authorize restitution for attorneys’ fees, vacated that portion of the restitution order, and remanded for entry of an amended judgment. All other aspects of the conviction and sentence were affirmed. View "United States v. Abrams" on Justia Law

Phath v. Central Transport LLC

2026-01-28T10:00:14-08:00

Rodney Phath applied for a truck driving position with Central Transport LLC. He had the necessary qualifications and disclosed during the hiring process that he had a fifteen-year-old armed robbery conviction, for which he had served six years in prison. Upon learning of this conviction, Central Transport immediately decided not to hire him. Phath then filed a lawsuit, alleging that Central Transport violated a Pennsylvania statute that restricts how employers may use criminal history information in employment decisions. The United States District Court for the Eastern District of Pennsylvania dismissed Phath’s claim. The court reasoned that the Pennsylvania Criminal History Record Information Act did not apply in this instance because Central Transport had learned of Phath’s conviction directly from him, rather than from a state agency’s records. On appeal, the United States Court of Appeals for the Third Circuit reviewed the matter de novo. The Third Circuit held that the Act’s protections are triggered whenever an employer receives information that is part of an applicant’s criminal history record information file, regardless of the source of that information. The court concluded that nothing in the statute requires the information to come specifically from a state agency’s file. Thus, by learning of Phath’s conviction—even through his own disclosure—Central Transport was subject to the Act’s provisions, including restrictions on how it may use that information and requirements for notifying the applicant if rejected on that basis. As a result, the Third Circuit reversed the District Court’s dismissal and remanded the case for further proceedings, holding that the Act applies even when an applicant self-discloses criminal history information. View "Phath v. Central Transport LLC" on Justia Law

Sports Enterprises Inc v. Goldklang

2026-01-21T10:00:07-08:00

A minor league baseball team in Oregon lost its longstanding affiliation with a Major League Baseball (MLB) club after MLB restructured its relationship with minor league teams in 2020. The team’s owner alleges that a minority owner of an MLB franchise, who also served on the board and a negotiation committee of the national minor league association, acted to reduce the number of minor league clubs for personal gain, which resulted in the team’s exclusion from the new affiliation structure. The owner claims that the association’s rules left it dependent on the board and committee members to protect its interests. The United States District Court for the District of New Jersey dismissed the owner’s complaint, finding that it failed to plausibly allege the existence of a fiduciary relationship between the board member and the team. The owner appealed, arguing that fiduciary duties arose under Florida’s non-profit statute, by contract, or by implication due to the structure of the association and the interactions between the parties. The United States Court of Appeals for the Third Circuit reviewed the District Court’s dismissal de novo. The Third Circuit held that Florida’s non-profit statute does not create a fiduciary duty from a director to the members of the non-profit, only to the corporation itself. The court also found no express or implied fiduciary duty arising from contractual provisions or the surrounding circumstances. The court distinguished direct and derivative actions and concluded that the complaint did not allege facts to support a direct or implied fiduciary relationship. Accordingly, the Third Circuit affirmed the District Court’s dismissal of the complaint for failure to state a claim. View "Sports Enterprises Inc v. Goldklang" on Justia Law