Justia Civil Procedure Opinion Summaries

Andrew Morgan, a millwright laborer, was employed by Allison Crane & Rigging LLC until his termination on November 18, 2020. Morgan injured his lower back on September 29, 2020, and was diagnosed with a bulged or herniated disc by a chiropractor. He was placed on light duty and given restrictions on bending and lifting. Despite these accommodations, Morgan was terminated, allegedly for failing to follow company policies and not showing up for work on November 17, 2020. Morgan filed a lawsuit claiming disability-based discrimination, retaliation, and failure to accommodate under the ADA and PHRA, as well as wrongful discharge under Pennsylvania common law.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of Allison Crane. The court held that Morgan did not establish an actual or perceived disability under the ADA and PHRA, as his testimony about the chiropractor's diagnosis was inadmissible hearsay and he failed to provide necessary medical evidence. The court also found that Morgan's back pain was transitory and minor, thus not qualifying as a disability. Additionally, the court dismissed Morgan's wrongful discharge claim for lack of prima facie evidence of protected activity.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court applied an incorrect legal standard. The Third Circuit clarified that under the ADA Amendments Act of 2008, temporary impairments can qualify as disabilities if they substantially limit major life activities. The court reversed the District Court's dismissal of Morgan's back pain-based discrimination claims, vacated the dismissal of his retaliation and failure to accommodate claims, and affirmed the dismissal of his wrongful discharge claim. The case was remanded for further proceedings consistent with the Third Circuit's opinion. View "Morgan v. Allison Crane & Rigging LLC" on Justia Law

Plaintiffs Tommy Coleman and Jason Perkins, who worked as oil and gas pipeline inspectors for System One Holdings, LLC, were paid a flat daily rate without overtime compensation, even when working over forty hours a week. They filed a lawsuit claiming this violated the Fair Labor Standards Act (FLSA) and sought unpaid overtime on behalf of themselves and a putative class of similarly compensated inspectors.The United States District Court for the Western District of Pennsylvania reviewed the case. System One moved to dismiss and compel arbitration, arguing that the plaintiffs had signed arbitration agreements enforceable under the Federal Arbitration Act (FAA). The plaintiffs countered that they fell under the transportation workers' exemption to the FAA. The District Court, following the precedent set in Guidotti v. Legal Helpers Debt Resolution, L.L.C., ordered limited discovery into the arbitrability of the claims before deciding on the motion to compel arbitration. System One's motion for reconsideration of this order was denied.The United States Court of Appeals for the Third Circuit reviewed the case to determine if it had jurisdiction over the interlocutory appeal from the District Court's order. The Third Circuit held that it lacked appellate jurisdiction because the District Court's order did not formally deny the motion to compel arbitration but rather deferred its decision pending limited discovery. The court emphasized that the FAA permits appeals from specific types of orders, and the order in question did not fall within those categories. Consequently, the appeal was dismissed for lack of jurisdiction. View "Coleman v. System One Holdings LLC" on Justia Law

Fernando Nunez, Jr., an inmate in Pennsylvania, filed a lawsuit against officials of the Pennsylvania Department of Corrections (DOC) under the Religious Land Use and Institutionalized Persons Act (RLUIPA). Nunez, a devout Muslim, claimed that the DOC violated his religious rights by denying him accommodations to consummate his marriage and have ongoing conjugal visits, engage in congregate prayer with visitors, and undergo a religious circumcision.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the DOC. The court concluded that the DOC had compelling interests in denying Nunez's requests and that there were no less restrictive alternatives available. The court relied on affidavits from DOC officials, which cited concerns about safety, security, health, and resource constraints. The court found that Nunez failed to disprove that the DOC's policies were the least restrictive means of furthering these interests.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court did not properly hold the DOC to its burden under RLUIPA. The Third Circuit concluded that the DOC failed to provide sufficient evidence to support its claims of compelling interests and did not adequately consider less restrictive alternatives. The court emphasized that RLUIPA requires a rigorous and fact-intensive inquiry and that the DOC's "mere say-so" was insufficient to meet this standard. The Third Circuit vacated the District Court's judgment and remanded the case for further proceedings, allowing the DOC to supplement the record to meet its burden under RLUIPA. View "Nunez v. Wolf" on Justia Law

Gary Lall, born in Trinidad and Tobago, applied for a Certificate of Citizenship in 1990 through his adoptive parents, who were naturalized U.S. citizens. The government erroneously approved his application after he turned eighteen, issuing a certificate stating he "became a citizen." However, Lall had not met the statutory requirements for citizenship. The error was discovered shortly after issuance, but the government waited twenty-one years to cancel the certificate. Lall, incarcerated at the time, filed a declaratory judgment action seeking recognition of his citizenship.The United States District Court for the Western District of Pennsylvania dismissed Lall's declaratory judgment action, finding he never obtained citizenship. Concurrently, the government initiated removal proceedings, and an Immigration Judge (IJ) ordered Lall's removal, rejecting his claim to citizenship. Lall appealed both the District Court's dismissal and the IJ's removal order.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that Lall never satisfied the statutory requirements for citizenship under the relevant sections of the Immigration and Nationality Act (INA) as they existed in 1991. The court emphasized that a Certificate of Citizenship is only prima facie evidence of citizenship and does not confer citizenship if statutory requirements are unmet. The court also ruled that equitable estoppel could not be used to confer citizenship, as courts lack the power to grant citizenship contrary to statutory requirements. Consequently, the Third Circuit affirmed the District Court's dismissal of Lall's declaratory judgment action and denied his petition for review of the IJ's removal order. View "Lall v. USICE" on Justia Law

Alison George sought to represent a class and obtain damages from Rushmore Service Center, LLC, based on a letter that identified Premier Bankcard, LLC as the “current/original creditor” instead of the actual credit card company. George alleged that this violated the Fair Debt Collection Practices Act (FDCPA) by failing to identify the creditor to whom the debt was owed and providing misleading information. She claimed that this would confuse the least sophisticated consumer about the legitimacy of the debt.The United States District Court for the District of New Jersey granted Rushmore’s motion to stay proceedings and compel individual arbitration. George lost in arbitration, where the arbitrator ruled in favor of Rushmore, finding that George was not misled because she admitted she did not read the letter. The District Court then declined to vacate the arbitration award, rejecting George’s arguments that the arbitrator disregarded evidence and law.The United States Court of Appeals for the Third Circuit reviewed the case and focused on whether George had standing to sue. The court concluded that George lacked standing from the outset because her complaint did not allege any specific adverse effects or confusion she personally experienced due to the letter. The court held that confusion alone is insufficient to establish a concrete injury under Article III. Consequently, the Third Circuit vacated the District Court’s orders and remanded with instructions to dismiss the case for lack of standing. The court declined to vacate the arbitration award itself, leaving its enforceability to be determined in a jurisdictionally correct proceeding. View "George v. Rushmore Service Center LLC" on Justia Law

Delaware residents and organizations challenged two new state gun laws in federal court. One law bans the possession, manufacture, sale, and transport of "assault weapons," while the other bans magazines that hold more than seventeen rounds. The plaintiffs argued that these laws violate the Second and Fourteenth Amendments and sought a preliminary injunction to prevent their enforcement.The United States District Court for the District of Delaware consolidated three related cases and held a preliminary-injunction hearing. The plaintiffs did not present live witnesses or evidence that Delaware had attempted to enforce the laws against them. The court found that the plaintiffs were unlikely to succeed on the merits because the laws were consistent with the nation's historical tradition of firearm regulation. It also found that the plaintiffs had not demonstrated irreparable harm, as they still had access to other means of self-defense. Consequently, the court denied the preliminary injunction.The United States Court of Appeals for the Third Circuit reviewed the District Court's decision. The appellate court emphasized that a preliminary injunction is an extraordinary remedy that should not be granted automatically, even if the plaintiffs are likely to succeed on the merits. The court found that the plaintiffs had not shown irreparable harm, as they did not provide evidence that the laws were being enforced against them or that they had an urgent need for the banned firearms and magazines. The court also noted that the plaintiffs delayed seeking the injunction, which undermined their claim of urgency. The Third Circuit affirmed the District Court's denial of the preliminary injunction, stating that the plaintiffs had other avenues for prompt relief, such as an accelerated trial. View "Delaware State Sportsmens Association Inc v. Delaware Department of Safety and Homeland Security" on Justia Law

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

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

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

Elfido Gonzalez Castillo, a Mexican citizen, was admitted to the U.S. as a lawful permanent resident in 1989. In 2009, he applied for naturalization but failed to disclose pending criminal charges for sexually abusing his niece. He was naturalized in October 2009 and later pled guilty to third-degree sexual assault. In 2019, the government sought to revoke his naturalization, which was granted in 2022. Subsequently, the Department of Homeland Security issued a Notice to Appear (NTA) for removal proceedings, charging Castillo with removability for a child abuse conviction. The NTA was filed in the Cleveland Immigration Court, and hearings were conducted remotely.The Immigration Judge (IJ) denied Castillo’s application for cancellation of removal. Castillo appealed to the Board of Immigration Appeals (BIA), arguing he was not removable because he was a U.S. citizen at the time of his conviction. The BIA applied Sixth Circuit law, as the NTA was filed in Cleveland, and dismissed the appeal. Castillo filed three petitions for review in the Third Circuit, asserting that venue was proper there because the IJ completed the proceedings while he was detained in Pennsylvania.The United States Court of Appeals for the Third Circuit reviewed the case to determine the proper venue for Castillo’s petitions. The court concluded that the IJ completed the proceedings in Cleveland, Ohio, where the NTA was filed and administrative venue vested. Therefore, venue did not lie in the Third Circuit but in the Sixth Circuit. The Third Circuit held that it had the inherent power to transfer the case to the appropriate venue and decided to transfer Castillo’s petitions to the United States Court of Appeals for the Sixth Circuit. View "Castillo v. Attorney General United States of America" on Justia Law