3d Circuit Case Commentaries

Commerce Clause Tax-Refund Litigation in the Virgin Islands: (1) No § 1331 Jurisdiction for 33 V.I.C. § 1692 Refund Claims Absent a “Substantial” Federal Issue, and (2) a Two-Year Personal-Injury Limitations Period for Direct Commerce Clause Claims

Date: Feb 8, 2026

Commerce Clause Tax-Refund Litigation in the Virgin Islands: (1) No § 1331 Jurisdiction for 33 V.I.C. § 1692 Refund Claims Absent a “Substantial” Federal Issue, and (2) a Two-Year Personal-Injury...

MSI Building Supplies Inc. v. United States Virgin Islands — Commentary

Date: Feb 8, 2026

Federal Jurisdiction and Limitations Rules for USVI Excise-Tax Refund Litigation: No Grable “Substantial Federal Issue” for 33 V.I.C. § 1692 Claims; Two-Year Personal-Injury Limitations for Direct...

PPP “Payroll Costs” Exclude a Business’s Payments to Independent Contractors Under CARES Act § 636(a)(36)(A)(viii)

Date: Feb 6, 2026

PPP “Payroll Costs” Exclude a Business’s Payments to Independent Contractors Under CARES Act § 636(a)(36)(A)(viii) I. Introduction Essintial Enterprise Solutions, LLC v. SBA (3d Cir. Feb. 3, 2026)...

Attempted Murder of a Federal Witness Categorically Qualifies as a § 924(c) “Crime of Violence” Under the Elements Clause

Date: Feb 6, 2026

Attempted Murder of a Federal Witness Categorically Qualifies as a § 924(c) “Crime of Violence” Under the Elements Clause Case: United States v. Dameia Smith (3d Cir. Feb. 3, 2026) (precedential)...

Speculation About Wet or Worn Stairs Cannot Defeat Summary Judgment in FTCA Premises-Liability Claims

Date: Feb 5, 2026

Speculation About Wet or Worn Stairs Cannot Defeat Summary Judgment in FTCA Premises-Liability Claims Case: Naomi Speaks v. United States of America; Elwyn Industries, Inc. Court: United States Court...

Best Price Rule Does Not Compel Purchase of Tendered Shares Subject to Transfer Restrictions

Date: Feb 5, 2026

Best Price Rule Does Not Compel Purchase of Tendered Shares Subject to Transfer Restrictions Case: Pawneet Abramowski v. Nuvei Corp. (3d Cir. Feb. 3, 2026) Court: U.S. Court of Appeals for the Third...

EAJA Fee-Shifting Applies to § 2241 Immigration-Detention Habeas Petitions as “Any Civil Action”

Date: Feb 5, 2026

EAJA Fee-Shifting Applies to § 2241 Immigration-Detention Habeas Petitions as “Any Civil Action” Case: Adewumi Abioye v. Warden Moshannon Valley Correctional Center (consolidated with Adolph Michelin...

EAJA “Any Civil Action” Unambiguously Covers § 2241 Habeas Challenges to Civil Immigration Detention

Date: Feb 5, 2026

EAJA “Any Civil Action” Unambiguously Covers § 2241 Habeas Challenges to Civil Immigration Detention I. Introduction In Adolph Michelin v. Warden Moshannon Valley Correctional Center (consolidated...

Third Circuit: Zip-Code “Golden Ticket” Admissions and Racial Proportionality Evidence Can Trigger Arlington Heights Strict Scrutiny; “Before-and-After” and Individual Harm Evidence Permitted

Date: Feb 4, 2026

Third Circuit: Zip-Code “Golden Ticket” Admissions and Racial Proportionality Evidence Can Trigger Arlington Heights Strict Scrutiny; “Before-and-After” and Individual Harm Evidence Permitted...

“Likely” Is Not “Reasonably Certain”: Forfeiture of Obvious-Causation and Strict Medical-Certainty Proof of Causation in Pennsylvania Personal-Injury Product Cases

Date: Feb 2, 2026

“Likely” Is Not “Reasonably Certain”: Forfeiture of Obvious-Causation and Strict Medical-Certainty Proof of Causation in Pennsylvania Personal-Injury Product Cases 1. Introduction In Joseph Riad v....

Settlement-Meeting Disclosures Can Trigger UFTA Inquiry Notice and Start the One-Year Discovery Limitations Period

Date: Feb 2, 2026

Settlement-Meeting Disclosures Can Trigger UFTA Inquiry Notice and Start the One-Year Discovery Limitations Period Court: United States Court of Appeals for the Third Circuit Date: January 30, 2026...

Forfeiture on Review, Late-Evidence Deadlines, and Due Process Bias Claims in Non-LPR Cancellation Cases

Date: Feb 2, 2026

Forfeiture on Review, Late-Evidence Deadlines, and Due Process Bias Claims in Non-LPR Cancellation Cases 1. Introduction In David Camargo Gomez v. Attorney General United States of America (3d Cir....

Hopes of Leniency Are Not Brady/Giglio Material: No Disclosure Duty Without an Actual Pretrial Leniency Understanding

Date: Feb 2, 2026

Hopes of Leniency Are Not Brady/Giglio Material: No Disclosure Duty Without an Actual Pretrial Leniency Understanding Introduction In Rafael Mueses Popote, the United States Court of Appeals for the...

United States v. Abrams: General Rule 29 Motions Do Not Preserve Later-Articulated Sufficiency Theories; MVRA § 3663A(b)(4) Does Not Authorize Restitution for Attorneys’ Fees

Date: Feb 2, 2026

United States v. Abrams: General Rule 29 Motions Do Not Preserve Later-Articulated Sufficiency Theories; MVRA § 3663A(b)(4) Does Not Authorize Restitution for Attorneys’ Fees Court: U.S. Court of...

Third Circuit: (1) Bare Rule 29 Motions Do Not Preserve Later-Articulated Sufficiency Theories; (2) MVRA § 3663A(b)(4) Does Not Authorize Restitution for Attorneys’ Fees — United States v. James P. Abrams

Date: Feb 2, 2026

Third Circuit: Bare Rule 29 Motions Do Not Preserve Later-Articulated Sufficiency Arguments, and MVRA § 3663A(b)(4) Does Not Permit Restitution for Victims’ Attorneys’ Fees Case: United States v....

Self-Defense Does Not Bar § 2K2.1(b)(6)(B) Enhancement Where Deadly Force Was Unreasonable and Retreat Was Available—Especially for a Felon in Illegal Possession

Date: Feb 1, 2026

Self-Defense Does Not Bar § 2K2.1(b)(6)(B) Enhancement Where Deadly Force Was Unreasonable and Retreat Was Available—Especially for a Felon in Illegal Possession 1. Introduction United States v....

CHRIA § 9125 Applies When an Employer Receives Self-Disclosed Conviction Information

Date: Jan 31, 2026

CHRIA § 9125 Applies When an Employer Receives Self-Disclosed Conviction Information 1. Introduction In Rodney Phath v. Central Transport LLC (3d Cir. Jan. 28, 2026), the U.S. Court of Appeals for...

Comparator Specificity and Retaliation Causation: No Prima Facie ADEA/PHRA Case Without Truly Similar Comparators or a Causally Suggestive Timeline

Date: Jan 29, 2026

Comparator Specificity and Retaliation Causation: No Prima Facie ADEA/PHRA Case Without Truly Similar Comparators or a Causally Suggestive Timeline Introduction In William Richter v. Duquesne...

Title VII “Reasonable Accommodation” Must Be Reasonable for the Employee, and “Undue Hardship” Is Generally Not Resolved on a Motion to Dismiss

Date: Jan 29, 2026

Title VII “Reasonable Accommodation” Must Be Reasonable for the Employee, and “Undue Hardship” Is Generally Not Resolved on a Motion to Dismiss Case: Theodore Federoff v. Geisinger Clinic Court:...

Qualified Immunity Bars COVID-19 Nursing-Home Policy Damages Claims Absent Fact-Specific, Clearly Established Authority

Date: Jan 29, 2026

Qualified Immunity Bars COVID-19 Nursing-Home Policy Damages Claims Absent Fact-Specific, Clearly Established Authority Introduction In Estate of Frances D. DeRosa v. Philip Murphy (3d Cir. Jan. 23,...