Justia Civil Procedure Opinion Summaries

In 1992, Grant was convicted of homicide and other crimes that he had committed while he was a juvenile. He was sentenced to life imprisonment under the then-mandatory Sentencing Guidelines. Parole is unavailable to those convicted of federal crimes, so the sentence effectively condemned Grant to die in prison. In 2012, the U.S. Supreme Court held (Miller v. Alabama) that the Eighth Amendment permits a life-without-parole (LWOP) sentence for a juvenile homicide offender only if the sentencer could have imposed a lesser punishment based on the offender’s youth at the time of the offense.At Miller’s resentencing, the judge recognized that youth can impair judgment and thereby mitigate culpability, stated that a life sentence for Grant would be too harsh, given his juvenile offender status and individual circumstances, and sentenced Grant to a term of 60 years on his homicide-related convictions with an undisturbed five-year consecutive sentence, Grant argued that his 65-year sentence violates Miller because it incarcerates him to his life expectancy, thereby amounting to a de facto LWOP sentence. Grant contends that Miller forbids such a sentence for a juvenile homicide offender unless he or she is incorrigible, which Grant is not. The Third Circuit affirmed. Miller only entitled Grant to a sentencing hearing at which the district court had the discretion to impose a sentence less than LWOP in view of Grant’s youth at the time of his offenses; that is what he received. View "United States v. Grant" on Justia Law

On various dates between March and July 2020, the Governor and Secretary of Health of the Commonwealth of Pennsylvania entered orders to address the COVID-19 pandemic. Plaintiffs, Pennsylvania citizens, elected officials, and businesses, challenged three pairs of directives: stay-at-home orders, business closure orders, and orders setting congregation limits in secular settings. The district court concluded that the orders violated the U.S. Constitution. While the appeal was pending, circumstances changed: more than 60% of Pennsylvanians have received a COVID vaccine. An amendment to the Pennsylvania Constitution and a concurrent resolution of the Commonwealth’s General Assembly now restricts the Governor’s authority to enter the same orders. In addition, the challenged orders have expired by their own terms. The Third Circuit vacated the judgment and dismissed an appeal as moot. No exception to the mootness doctrine applies View "County of Butler v. Governor of Pennsylvania" on Justia Law

The Borough brought misdemeanor criminal charges against the owner for abandoning inoperable vehicles, appliances, and other trash on his property, in violation of ordinances and statutes. During a status conference, the judge stated that, after the expiration of 20 days, the Borough could enter and start the clean-up; 21 days after the hearing, the Borough began cleaning the property without the owners’ permission or a warrant. Believing some of the removed items to be valuable, the owners sent a cease-and-desist letter and eventually filed suit under 42 U.S.C. 1983 with state law claims for conversion and trespass.The district court that it lacked jurisdiction under the Rooker-Feldman doctrine, which precludes federal district courts from exercising jurisdiction over appeals from state court judgments. Meanwhile, the owner was convicted of the public nuisance charge. The Third Circuit reversed. The Rooker-Feldman doctrine is narrow and defeats federal subject-matter jurisdiction only under limited circumstances. There is a precise four-pronged inquiry. When even one of the four prongs is not satisfied, it is not proper to dismiss on Rooker-Feldman grounds. This case does not satisfy all four prongs. Any injury the owners suffered was not “caused by” a state court judgment; even if the Borough lacked independent authority to seize the property, the state court “acquiesced in” or “ratified” the Borough’s seizure of the property rather than having “produced” it. The owners did not challenge the state court judgment but brought independent constitutional claims. View "Vuyanich v. Borough of Smithton" on Justia Law

Plaintiffs brought a putative class action against the School District, claiming that shortcomings in the District’s translation and interpretation services violated the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400.The Third Circuit affirmed summary judgment in favor of the District, based on failure to exhaust administrative remedies. A “systemic exception” to IDEA’s administrative exhaustion requirement applies where plaintiffs “allege systemic legal deficiencies and, correspondingly, request system-wide relief" that cannot be addressed through the administrative process. The fact that a complaint is structured as a class action seeking injunctive relief, without more, does not excuse exhaustion; the systemic exception applies when plaintiffs challenge policies that threaten basic IDEA goals, not mere components of special education programs. Both named plaintiffs could bring the same IDEA claim from their complaint before a hearing officer who could then order that the District provide each parent with translated individualized education plans, more qualified or consistent interpretation services, or whatever process would ensure meaningful participation for that parent. Both the claim and the relief would be individualized, even if the relief could create spillover benefits for other parents. View "T.R. v. School District of Philadelphia" on Justia Law

The hospital, located in Philadelphia, received a reclassification into the New York City area, which would sizably increase the hospital’s Medicare reimbursements due to that area’s higher wage index, 42 U.S.C. 1395ww(d). Although a statute makes such reclassifications effective for three fiscal years, the agency updated the geographical boundaries for the New York City area before the close of that period and reassigned the hospital to an area in New Jersey with an appreciably lower wage index. The hospital successfully sued three agency officials in the Eastern District of Pennsylvania.The Third Circuit vacated and remanded for dismissal. The Medicare Act, 42 U.S.C. 1395oo(f)(1), channels reimbursement disputes through administrative adjudication as a near-absolute prerequisite to judicial review. The hospital did not pursue its claim through administrative adjudication before suing in federal court. By not following the statutory channeling requirement, the hospital has no valid basis for subject-matter jurisdiction. View "Temple University Hospital, Inc. v. Secretary United States Department of Health & Human Services" on Justia Law

Valeant develops and manufactures generic pharmaceuticals. Appellants purchased stock in Valeant after Valeant changed its business model to focus more on acquiring new drugs from other companies rather than developing its own. Valeant made promising representations about its financial performance based on its new business model. The price of Valeant stock skyrocketed nearly 350% in 2015. Before the district court addressed class certification in a putative class action on behalf of investors who purchased Valeant stock in 2015, alleging that the price was artificially inflated as a result of deceptive practices, the Appellants filed an “opt-out” complaint bringing the same claims in their individual capacities. The district court dismissed that complaint as untimely under the two-year limitations period.The Third Circuit vacated the dismissal. Putative class members may recover as part of the class or seek individual recourse. Members may initially proceed as part of a class, but certification may be denied later or members may discover that their individual claims are more valuable than the class claims and decide to pursue an opt-out complaint even if certification is likely. In either case, members are generally allowed to initiate an individual action. When a class complaint is filed, the limitations period governing the individual claims of putative members is tolled to protect the rights of putative members while avoiding needless identical lawsuits. Nothing further, such as a certification denial, is required to benefit from tolling. View "Aly v. Valeant Pharmaceuticals International, Inc." on Justia Law

Mondelli suffers from paranoid schizophrenia and major depression. During his daily 12-hour visits with his mother at Berkeley Heights, Mondelli allegedly observed inadequate care. Mondelli regularly complained to staff, the New Jersey Board of Health, and the Office of the Ombudsman for the Institutionalized Elderly. After several contentious visits, including police calls, Mondelli’s visits were limited to one to two hours per day in the lobby. Mondelli’s mother died.Mondelli filed suit, claiming ADA violations and intentional infliction of emotional distress. Despite several deadline extensions, Mondelli never cooperated in discovery. Mondelli explained that he suffers from various physical and mental health conditions; was found incompetent to stand trial in the Municipal Court of Fanwood; and has been unable to properly communicate with his lawyer. Mondelli supplied letters from physicians and a psychiatrist. The case was administratively terminated for 180 days, after which Mondelli moved to reopen. The district court denied Mondelli’s motion and, weighing the “Poulis” factors, dismissed his complaint with prejudice, finding that Mondelli was personally responsible for his failure to prosecute; that defendants were prejudiced by his failure to prosecute; that Mondelli had a history of dilatoriness; that no sanction other than dismissal would be appropriate; and that Mondelli’s ADA claim lacked merit.The Third Circuit vacated. There was verifiable evidence that placed Mondelli’s competency at issue; the court must examine his competency, as required by Federal Rule of Civil Procedure 17. View "Mondelli v. Berkeley Heights Nursing and Rehabilitation Center" on Justia Law

Brace, a farmer, owns hundreds of acres in Erie County, Pennsylvania. He cleared 30 acres of wetlands, draining it to grow crops. In 1994, the Third Circuit affirmed that Brace had violated the Clean Water Act. In 2012, Brade bought 14 additional acres of wetlands. Again, he engaged in clearing, excavation, and filling without required permits. During a second suit under the Act, Brace’s counsel submitted perfunctory pleadings and failed to cooperate in discovery, repeatedly extending and missing deadlines. Counsel submitted over-length briefs smuggling in extra-record materials. The court repeatedly struck Brace’s materials but generally chose leniency. Eventually, the court struck Brace’s opposition to summary judgment after analyzing the “Poulis factors,” then granted the government summary judgment on liability, holding that Brace had violated the Act. The court ordered Brace to submit a proposed deed restriction and restoration plan.The Third Circuit rejected Brace’s appeal. While “it stretches credulity [to believe that Brace had] no idea how counsel [wa]s conducting this case,” the court gave Brace the benefit of the doubt. Brace’s lawyer’s misconduct forced the government to waste time and money “deciphering incomprehensible pleadings, scouring through noncompliant briefs, and moving again and again for compliance" to no avail. Counsel acted in bad faith; repeated orders to show cause, warnings, and threats of sanctions did not deter counsel’s chronic misbehavior. The sanction “was hardly an abuse of discretion.” View "United States v. Brace" on Justia Law

Three clients filed separate discrimination cases, which were consolidated for discovery. The defendants obtained summary judgment. The clients filed a notice of appeal, then hired Paddick, who entered into a contingency fee agreement with each client, providing that Paddick would serve as counsel on remand and promising Paddick a 40 percent fee of any trial or settlement proceeds. Paddick prevailed in the appeal, then took 24 depositions, presented two oral arguments, attended two settlement conferences, and filed nine substantive motions or responses. When it came time to retain an expert witness, Paddick was unable to advance the necessary funds. The clients terminated their relationship with Paddick and retained Thompson to pursue their claims for a 35 percent contingent fee. Paddick informed Thompson of his work, noting that “fees remain due.” Thompson did not respond. The case settled for $380,000; Thompson’s share was $133,000. The district court acknowledged the settlements and dismissed the cases.A month later, Paddick successfully moved to intervene to enforce an attorney’s charging lien against the settlement proceeds. The Third Circuit affirmed an order that Thompson pay Paddick $54,562.73 from Thompson’s portion of the recovery. The district court had ancillary enforcement jurisdiction to resolve Paddick’s lien motion. The clients did not produce clear and convincing evidence of duress; imperfect representation does not necessarily bar Paddick from recovery. A client “should never be made to pay twice.” View "Butt v. United Brotherhood of Carpenters & Joiners of America" on Justia Law

Doe became a TCNJ tenure-track Assistant Professor in 2016, after giving birth to her third child. She alleges that the Dean and the Department Chair suggested that they were relieved that she would not need pregnancy-related accommodations in the future. Doe received positive reviews for 2017. Doe claims that after she became pregnant again, she was reassigned to a less desirable class. After Doe had her fourth child, the Dean, the Chair, and others, repeatedly asked whether she was done having children. She notified TCNJ that she was pregnant again. In 2018, a TCNJ professor attended the same class that the professor had positively reviewed in 2017 but entered a negative review; Doe claims there were no material changes. The Chair reported “non-material deficiencies” after having given her a positive review in 2017. Doe complained to the Provost, who allegedly “placed a record of discipline” in Doe’s personnel file for the Reappointment Committee. She claims she “suffered emotional trauma, became depressed, and had a miscarriage,” and that she was falsely accused of canceling classes, supported by “doctored” student comments. Doe was not reappointed.She filed suit, alleging gender, national origin, and pregnancy discrimination, and retaliation under Title VII of the Civil Rights Act. The Third Circuit affirmed the denial of her motion to proceed anonymously. Doe’s case does not merit appellate review under the collateral order doctrine. Nothing indicated that Doe’s interest in anonymity outweighs the public’s interest in open judicial proceedings. View "Doe v. The College of New Jersey" on Justia Law