Justia Civil Procedure Opinion Summaries

Plaintiffs, who are probationers, sued several Pennsylvania judges, probation officers, and the county warden, alleging they were detained without a finding that such detention was necessary to prevent flight or further crimes. They claimed their due process rights were violated as they were held for months without adequate preliminary hearings or credible probable-cause findings.The United States District Court for the Western District of Pennsylvania denied a preliminary injunction and later granted summary judgment for the defendants on both claims. The court held that the plaintiffs' novel claim for a new procedural right conflicted with Supreme Court precedent and found no genuine dispute of material fact regarding the county's adherence to existing constitutional rules in initial hearings.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that probationers do not have a due process right to a finding of necessity before being detained between preliminary and revocation hearings. The Supreme Court's decisions in Morrissey v. Brewer and Gagnon v. Scarpelli established that a finding of probable cause at a preliminary hearing is sufficient to warrant continued detention for a reasonable time until the revocation hearing.However, the Third Circuit found material factual disputes regarding whether the county followed due process rules, particularly concerning the adequacy of notice given to probationers before preliminary hearings. The court reversed and remanded the case in part, allowing plaintiffs to proceed with their claim that the county did not follow established due process procedures. View "Horton v. Rangos" on Justia Law

The Public Interest Legal Foundation (PILF) requested records from the Secretary of the Commonwealth of Pennsylvania under the National Voter Registration Act of 1993 (NVRA). PILF sought documents related to a "glitch" in the Pennsylvania Department of Transportation's system that allowed ineligible persons to register to vote. The Secretary denied the request, leading PILF to file a lawsuit claiming an informational injury due to the denial of access to the records.The United States District Court for the Middle District of Pennsylvania initially dismissed the suit for lack of statutory notice but found that PILF had standing based on an informational injury. After PILF provided the required notice and refiled the suit, the District Court granted and denied parts of both parties' summary judgment motions, ruling that PILF was entitled to some records but not others. The District Court did not reassess PILF's standing in light of the Supreme Court's decision in TransUnion v. Ramirez.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that PILF lacked standing. The court held that PILF did not demonstrate a concrete harm or adverse effects from the denial of information, as required by TransUnion. The court emphasized that PILF's inability to study and analyze the records or produce educational materials did not constitute a concrete injury related to the NVRA's purpose of increasing voter participation. Consequently, the Third Circuit vacated the District Court's orders and remanded the case with instructions to dismiss it. View "The Public Interest Legal Foundation v. Secretary Commonwealth of Pennsylvania" on Justia Law

The appellants, Robin and Louie Joseph Aquilino, filed for Chapter 7 bankruptcy in April 2020 and retained the law firm Spector Gadon Rosen & Vinci P.C. (Spector Gadon) as their counsel. They agreed to pay a flat fee of $3,500 and a $335 filing fee, which Spector Gadon disclosed to the Bankruptcy Court. However, due to the complexity of the case, Spector Gadon billed the Aquilinos for additional post-petition services, resulting in a fee agreement of $113,000, which was not disclosed to the Bankruptcy Court as required by 11 U.S.C. § 329(a) and Bankruptcy Rule 2016(b).The Bankruptcy Court for the District of New Jersey found that Spector Gadon violated the disclosure requirements and sanctioned the firm by ordering the disgorgement of collected fees and cancellation of the remaining fee agreement. Spector Gadon appealed, and the United States District Court for the District of New Jersey reversed the Bankruptcy Court's decision, concluding that Spector Gadon was entitled to a jury trial under the Seventh Amendment.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the Bankruptcy Court had "core" jurisdiction over the fee disclosure issue under 28 U.S.C. § 157(b)(1). The Third Circuit held that the Seventh Amendment did not entitle Spector Gadon to a jury trial in the § 329(a) proceeding because the sanctions imposed were equitable in nature, designed to restore the status quo, and did not involve legal claims. The Third Circuit also found that the Bankruptcy Court did not abuse its discretion in imposing sanctions, as it considered all relevant factors, including the Debtors' misconduct.The Third Circuit reversed the District Court's judgment and reinstated the Bankruptcy Court's sanctions order. View "In re Aquilino" on Justia Law

Mesabi Metallics Company LLC (Mesabi) filed for Chapter 11 bankruptcy in 2016 and emerged successfully in 2017. During the bankruptcy proceedings, Mesabi initiated an adversary proceeding against Cleveland-Cliffs, Inc. (Cliffs), alleging tortious interference, antitrust violations, and civil conspiracy. Mesabi claimed Cliffs engaged in anti-competitive conduct to impede Mesabi's business operations. To facilitate discovery, the parties entered a stipulated protective order allowing documents to be designated as confidential. Mesabi later moved to unseal certain documents filed under seal to support a petition in the Minnesota Court of Appeals.The United States Bankruptcy Court for the District of Delaware, applying the common law right of access, held that Cliffs had not met the burden to keep the documents sealed. The court relied on the Third Circuit's precedent in In re Avandia, which requires a showing that disclosure would cause a clearly defined and serious injury. Recognizing potential ambiguity in the law, the Bankruptcy Court certified the question for direct appeal to the United States Court of Appeals for the Third Circuit.The Third Circuit clarified that the sealing of documents in bankruptcy cases is governed by 11 U.S.C. § 107, not the common law right of access. Section 107 imposes a distinct burden, requiring protection of trade secrets or confidential commercial information without the need for balancing public and private interests. The court vacated the Bankruptcy Court's decision and remanded for application of the correct standard under § 107. Additionally, the Third Circuit held that the Bankruptcy Court lacked jurisdiction to grant a third party's motion to intervene and unseal documents while the appeal was pending, vacating those orders as well. View "ESML Holdings Inc v. Mesabi Metallics Compay LLC," on Justia Law

Plaintiffs alleged that an automobile manufacturer designed, manufactured, and sold defective vehicles, specifically Dodge "muscle" cars with defective rear differentials. They filed a complaint asserting state and federal causes of action based on fraud and breach of warranty. The District Court dismissed the fraud counts and some warranty counts, allowing plaintiffs to amend their complaint. After amending, the District Court dismissed the fraud counts again and some warranty counts, but allowed two warranty counts to proceed.The United States District Court for the District of Delaware initially dismissed the complaint without prejudice, allowing plaintiffs to amend it. After the plaintiffs amended their complaint, the District Court dismissed the fraud counts and some warranty counts with prejudice, but allowed two warranty counts to proceed. The plaintiffs then moved to certify the dismissal of their fraud counts for appeal under 28 U.S.C. § 1292(b) or for final judgment under Rule 54(b). The District Court denied the request for certification under § 1292(b) but granted the request for final judgment under Rule 54(b) for the fraud counts.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the District Court's Rule 54(b) judgment was not final. The Court of Appeals held that the fraud and warranty counts constituted a single claim for purposes of Rule 54(b) because they were alternative theories of recovery based on the same factual situation. As a result, the judgment did not dispose of all the rights or liabilities of one or more of the parties. Consequently, the Court of Appeals dismissed the appeal for lack of jurisdiction and instructed the District Court to vacate its order directing the entry of a partial final judgment. View "Diaz v. FCA US LLC" on Justia Law

Jeffrey Herrera filed a pro se complaint alleging that he was detained for several months beyond his maximum release date, which he claimed violated the Eighth Amendment. Herrera was arrested in September 2012, sentenced in March 2013 to 36 to 72 months’ imprisonment, and released on parole in December 2014. After violating parole, his sentence was reduced in January 2017 to 30 to 66 months, with credit for time served. Despite this, Herrera claimed he was detained until October 2019, seven months past his maximum release date of March 2019.The United States District Court for the Middle District of Pennsylvania dismissed Herrera’s complaint under 28 U.S.C. § 1915(e), reasoning that his claim must be brought as a habeas corpus petition under 28 U.S.C. § 2254 and that his claim for damages was barred by Heck v. Humphrey, 512 U.S. 477 (1994). The court also found that any amendment to the complaint would be futile. Herrera’s motions for reconsideration and relief from judgment were denied, with the court maintaining that his claim was barred by Heck and the statute of limitations.The United States Court of Appeals for the Third Circuit reviewed the case and determined that Heck does not apply to Herrera’s overdetention claim because it does not imply that his conviction or sentence were invalid. The court found that Herrera plausibly pleaded an Eighth Amendment overdetention claim, as he alleged that prison officials were aware of his overdetention and failed to act, resulting in his prolonged detention. However, the court noted that the claim might be time-barred under Pennsylvania’s two-year statute of limitations but remanded the case to allow Herrera to amend his complaint to address potential tolling of the statute of limitations. The Third Circuit vacated the District Court’s order and remanded for further proceedings. View "Herrera v. Pennsylvania Board of Probation and Parole" on Justia Law

Prestige Home Care Agency, operated by Nursing Home Care Management Inc., did not compensate its employees for travel time between clients' homes. The U.S. Department of Labor (DOL) sued Prestige for this and other violations of the Fair Labor Standards Act (FLSA). The District Court found Prestige's actions to be willful violations of the FLSA and granted summary judgment in favor of the DOL. Prestige appealed the summary judgment, the exclusion of its expert witness, and the denial of its motion for sanctions against the DOL.The District Court for the Eastern District of Pennsylvania excluded Prestige’s expert witness, denied Prestige’s motion for sanctions, and granted summary judgment for the DOL on all claims. The court found that Prestige willfully violated the FLSA by not compensating for travel time, failing to pay for short breaks, improperly compensating overtime, and not keeping accurate records.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that travel time between job sites during the workday is compensable under the FLSA. It affirmed the District Court’s finding that Prestige violated the FLSA’s recordkeeping requirements and acted willfully in its violations, extending the statute of limitations to three years. The court also upheld the District Court’s calculation of back wages and liquidated damages, finding the DOL’s estimates sufficient given Prestige’s inadequate records.The Third Circuit found no abuse of discretion in the District Court’s exclusion of Prestige’s expert witness, who made several legal errors in his report. The court also upheld the denial of sanctions against the DOL, as the documents in question were already in Prestige’s possession and had little impact on the case. The Third Circuit affirmed the District Court’s judgment in all respects. View "Secretary United States Department of Labor v. Nursing Home Care Management Inc." on Justia Law

A Harrisburg, Pennsylvania ordinance prohibits persons to “knowingly congregate, patrol, picket or demonstrate in a zone extending 20 feet from any portion of an entrance to, exit from, or driveway of a health care facility.” Individuals purporting to provide “sidewalk counseling” to those entering abortion clinics claimed that the ordinance violated their First Amendment rights to speak, exercise their religion, and assemble, and their due process and equal protection rights. The court determined that the ordinance was content-neutral because it did not define or regulate speech by subject-matter or purpose, so that intermediate scrutiny applied, and reasoned that it must accept as true (on a motion to dismiss) claims that the city did not consider less restrictive alternatives. The claims proceeded to discovery. In denying preliminary injunctive relief, the court ruled that plaintiffs did not demonstrate a likelihood of success on the merits. The Third Circuit vacated. In deciding whether to issue a preliminary injunction, plaintiffs normally bear the burden of demonstrating likelihood of prevailing on the merits. In First Amendment cases where the government bears the burden of proof on the ultimate question of a statute’s constitutionality, plaintiffs must be deemed likely to prevail for purposes of considering a preliminary injunction unless the government has shown that plaintiffs’ proposed less restrictive alternatives are less effective than the statute. View "Reilly v. City of Harrisburg" on Justia Law

Deadline for petition to Tax Court is jurisdictional and cannot be waived for equitable reasons. When spouses file a joint tax return, each is jointly and severally liable for the tax due, 26 U.S.C. 6013(d); the IRS may grant relief where it would be “inequitable to hold the individual liable.” Rubel and her ex-husband filed joint income tax returns, 2005-2008. They had an unpaid tax liability for each year. In 2015, Rubel sought relief under the innocent spouse relief provisions. On January 4, 2016, the IRS denied relief for tax years 2006-2008. On January 13, the IRS sent a denial for 2005. The determinations stated that Rubel could appeal to the Tax Court within 90 days; Rubel needed to file a petition by April 4 for the 2006-2008 tax years and by April 12 for 2005. Rubel submitted additional information to the IRS. In a March 3 letter, the IRS stated that it “still propose[d] to deny relief” and, incorrectly, “Your time to petition … will end on Apr. 19.” Rubel mailed a petition on April 19. The Third Circuit affirmed the Tax Court’s dismissal. The deadline set forth in 26 U.S.C. 6015(e)(1)(A), is jurisdictional and cannot be altered, regardless of the equities of the case. View "Rubel v. Commissioner Internal Revenue" on Justia Law

The consolidated appeals involve allegations that the companies holding the patents for Lipitor and Effexor XR delayed entry into the market by generic versions of those drugs by engaging in an overarching monopolistic scheme that involved fraudulently procuring and enforcing the underlying patents and then entering into a reverse-payment settlement agreement with a generic manufacturer. In 2013, the Supreme Court recognized that reverse payment schemes can violate antitrust laws and that it is normally not necessary to litigate patent validity to answer the antitrust question. The district judge dismissed most of plaintiffs’ claims. The Third Circuit remanded after rejecting an argument that plaintiffs’ allegations required transfer of the appeals to the Federal Circuit, which has exclusive jurisdiction over appeals from civil actions “arising under” patent law, 28 U.S.C. 1295(a)(1). Not all cases presenting questions of patent law necessarily arise under patent law; here, patent law neither creates plaintiffs’ cause of action nor is a necessary element to any of plaintiffs’ well-pleaded claims. The court remanded one of the Lipitor appeals, brought by a group of California pharmacists and involving claims solely under California law, for jurisdictional discovery and determination of whether remand to state court was appropriate. View "In re: Lipitor Antitrust Litigation" on Justia Law